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Denka Performance Elastomer LLC

Parent Companies:
EPA Facility ID:
100000084927
Other ID:
70068DPNTD560HW
Facility DUNS:
74730909

Location:

Address:
560 Highway 44
LaPlace, LA 70068
County:
ST. JOHN THE BAPTIST
Lat / Long:
30.052, -90.523 (Get map)
Method:
Interpolation - Photo
Description:
Plant Entrance (General)
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Denka Performance Elastomer LLC
Phone:
(504) 536-1141
Address:
560 Highway 44
LaPlace, LA 70068 -6908
Foreign Address:

Person responsible for RMP implementation:

Name:
Jorge Lavastida
Title:
Plant Manager

Emergency contact:

Name:
Patrick Walsh
Title:
PSM Leader
Phone:
(985) 536-5731
24-hour phone:
(251) 321-5989
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
St. John The Baptist Parish
Full-Time Equivalent Employees:
271
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
3000-V5,2249-V7
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Aug. 25, 2014
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Neoprene Process - DIBN
RMP ID:
1000060560
CBI claimed:
No
Program Level:
3
NAICS:
Synthetic Rubber Manufacturing (325212)
Chemical name
CAS#
Quantity (lbs.)
CBI
Nitrogen Tetroxide
10544-72-6
30,000
No
Public OCA Chemical
0
No
Chloroprene Process
RMP ID:
1000060561
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
1,3-Butadiene
106-99-0
1,400,000
No
Pentane
109-66-0
287,000
No
Chlorine
7782-50-5
1,052,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Chlorine Sto. - Tank Cars
RMP ID:
1000060562
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Chlorine
7782-50-5
9,000,000
No
Public OCA Chemical
0
No
Butadiene R/C Unloading
RMP ID:
1000060563
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
1,3-Butadiene
106-99-0
5,775,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Patrick Walsh
Address:
560 Hwy 44
LaPlace, LA 70068 -6908
Foreign Address:

Phone:
(985) 536-5731

Latest RMP Submission:

Date:
Feb. 26, 2015
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000048405

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Chloroprene Process)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by refrigeration
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps

3. Toxics: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Neoprene Process - DIBN)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
TRACE
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in Chlorine Sto. - Tank Cars)
CBI claimed:
No
Percent weight:
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Excess flow valve
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Flares
  • Scrubbers
  • Emergency shutdown

4. Flammables: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Chloroprene Process)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Blast walls

5. Flammables: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Chloroprene Process)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Excess flow valve

6. Five-year accident history

Dec. 15, 2014 at 01:37
ID:
1000037401
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Duration:
2 minutes
Chemicals involved:
  • Chlorine
Release events:
Gas release
Weather conditions at time of event
Wind speed:
None
Temperature:
None ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
Yes
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
1
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$0
Known off-site impacts
Deaths:
0
Hospitalizations:
1
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Human Error
Contributing factors:
  • Human error
Off-site responders notified:
Notified Only
Changes introduced as a result of the accident:
  • Re-trained employees on proper procedure
June 7, 2011 at 13:32
ID:
1000037481
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Duration:
1 minutes
Chemicals involved:
  • Chlorine
Release events:
Gas release
Weather conditions at time of event
Wind speed:
None
Temperature:
None ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
Yes
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
1
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$0
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Human Error
Contributing factors:
  • Human error
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Revised training
  • Revised operating procedures

7. Prevention: Program level 3

Neoprene Process - DIBN, Synthetic Rubber Manufacturing (325212)
Prevention Program ID:
1000050364
Safety Review Date
Sept. 30, 2014, since latest RMP submission
PHA Update Date
Sept. 30, 2014, since latest RMP submission
PHA Techniques
  • What if
  • Checklist
Hazards Identified
  • None
Process Controls
  • Alarms
  • Emergency Air Supply
Mitigation Systems
  • Dikes
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
  • Process Detection
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
Procedure Review Date
Sept. 30, 2014, since latest RMP submission
Training Review Date
April 1, 2014, since latest RMP submission
Maintenance Review Date
Aug. 12, 2014, since latest RMP submission
Maintenance Inspection Date
July 15, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 17, 2014
Management of Change Review Date
Oct. 21, 2014
Pre-startup Review Date
May 9, 2014
Compliance Audit Date
Oct. 30, 2013
Compliance Audit Change Completion Date
Dec. 31, 2014
Incident Investigation Date
Jan. 7, 2014
Incident Invest. Change Completion Date
March 12, 2014
Participation Plan Review Date
Jan. 13, 2015
Hot Work Review Date
June 15, 2014
Contractor Safety Review Date
Jan. 15, 2015, since latest RMP submission
Contractor Safety Eval. Date
Feb. 4, 2015, since latest RMP submission
Chloroprene Process, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000050365
Safety Review Date
Jan. 27, 2014, since latest RMP submission
PHA Update Date
Jan. 27, 2014, since latest RMP submission
PHA Techniques
  • What if/Checklist
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
Process Controls
  • Relief Valves
  • Interlocks
  • Rupture Disks
Mitigation Systems
  • Sprinkler System
Monitoring Systems
  • Perimeter Monitors
Changes since PHA
  • Process Parameters
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
Procedure Review Date
Jan. 5, 2015, since latest RMP submission
Training Review Date
Jan. 9, 2015, since latest RMP submission
Maintenance Review Date
Nov. 13, 2014, since latest RMP submission
Maintenance Inspection Date
Aug. 19, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Jan. 7, 2015
Management of Change Review Date
Oct. 21, 2014
Pre-startup Review Date
Nov. 25, 2014
Compliance Audit Date
Oct. 28, 2013
Compliance Audit Change Completion Date
Dec. 15, 2018
Incident Investigation Date
Nov. 29, 2014
Incident Invest. Change Completion Date
Aug. 1, 2015
Participation Plan Review Date
Jan. 13, 2015
Hot Work Review Date
June 15, 2014
Contractor Safety Review Date
Jan. 15, 2015, since latest RMP submission
Contractor Safety Eval. Date
Feb. 4, 2015, since latest RMP submission
Chlorine Sto. - Tank Cars, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000050366
Safety Review Date
Jan. 27, 2014, since latest RMP submission
PHA Update Date
Jan. 27, 2014, since latest RMP submission
PHA Techniques
  • What if
Hazards Identified
  • Toxic release
  • Overpressurization
Process Controls
  • Relief Valves
  • Rupture Disks
  • Excess Flow Device
Mitigation Systems
  • None
Monitoring Systems
  • Perimeter Monitors
Changes since PHA
  • Reduced Inventory
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 5, 2015, since latest RMP submission
Training Review Date
Jan. 9, 2015, since latest RMP submission
Maintenance Review Date
June 25, 2014, since latest RMP submission
Maintenance Inspection Date
July 22, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Nov. 25, 2014
Management of Change Review Date
Oct. 21, 2014
Pre-startup Review Date
Nov. 25, 2014
Compliance Audit Date
Oct. 29, 2013
Compliance Audit Change Completion Date
Nov. 30, 2015
Incident Investigation Date
Dec. 15, 2014
Incident Invest. Change Completion Date
May 12, 2015
Participation Plan Review Date
Jan. 13, 2015
Hot Work Review Date
June 15, 2014
Contractor Safety Review Date
Jan. 15, 2015, since latest RMP submission
Contractor Safety Eval. Date
Feb. 4, 2015, since latest RMP submission
Butadiene R/C Unloading, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000050367
Safety Review Date
Sept. 27, 2012, since latest RMP submission
PHA Update Date
Sept. 27, 2012, since latest RMP submission
PHA Techniques
  • What if/Checklist
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
Process Controls
  • None
Mitigation Systems
  • Sprinkler System
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
  • Process Detection
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
Procedure Review Date
Jan. 5, 2015, since latest RMP submission
Training Review Date
Jan. 9, 2015, since latest RMP submission
Maintenance Review Date
July 21, 2014, since latest RMP submission
Maintenance Inspection Date
Feb. 27, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Sept. 29, 2014
Management of Change Review Date
Oct. 21, 2014
Pre-startup Review Date
Nov. 25, 2014
Compliance Audit Date
Oct. 28, 2013
Compliance Audit Change Completion Date
Dec. 15, 2018
Incident Investigation Date
Nov. 29, 2014
Incident Invest. Change Completion Date
Aug. 1, 2015
Participation Plan Review Date
Jan. 13, 2015
Hot Work Review Date
June 15, 2014
Contractor Safety Review Date
Jan. 15, 2015, since latest RMP submission
Contractor Safety Eval. Date
Feb. 4, 2015, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
Dec. 4, 2014
Local Response Agency:
Local Response Agency Phone:
(504) 652-3000
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

Executive Summary

EPA Facility Identifier 1000 0008 4927





Correction Summary for 11/10/2015



On November 1, 2015, E.I. DuPont de Nemours & Company sold site assets related to the DuPont Performance Elastomers business at the Pontchartrain Site, EPA Facility Identifier 1000 0008 4927, to Denka Performance Elastomer LLC (DPE). This correction submittal dated on or around 11/10/2015 is only to remove Dupont Pontchartrain Site from section 1.1.a in RMP Submittal and enter the new owner, Denka Performance Elastomer LLC (DPE) into the RMP Database in section 1.1.a for the EPA Facility Identifier 1000 0008 4927.



Prior Introduction



DPE offers a wide variety of polymer products that have end-use applications in automotive systems, wire and cable, construction, chemical processing, the general rubber industry, and in high-performance parts with excellent temperature, oil, and chemical resistance. Examples of the end products that are made with DPE materials include:



- Coatings - from rainwear to liners for roofs and tanks,

- Automotive products - from power steering pressure hoses to high performance timing belts,

- Wire and cable insulation - from electrical wiring to nuclear power station cable, and

- Industrial application - from microwave door enclosures to acid hoses.



The Environmental Protection Agency promulgated the Risk Management Plan (RMP) rule to comply with the Clean Air Act Amendments of 1990. RMP is a communication process designed to help the public, emergency responders and regulatory agencies understand the risks associated with certain types of facilities. This executive summary, one of the requirements under the RMP, is provided in compliance with 40 CFR A? 68.15.



Accidental Release and Emergency Response Policies



The DPE Pontchartrain Site is committed to operating and ma
intaining all the processes in a safe and responsible manner. The site is committed to the safety and well being of employees and the community. Corporate and site's main goals are to prevent all accidental releases, process safety incidents and employee injuries. Systems and procedures are in place to assure the safety of the working environment. The progress against goals is constantly assessed and communicated to the employees. Achievement of these goals is recognized and rewarded, while failure to attain them is regarded as unacceptable performance.



The emergency response policy is to respond immediately to any accidental releases or process safety incidents to minimize impact on the employees, public and the environment. The emergency response teams provide coverage 24 hours a day. These employees are trained on how to handle emergency situations.



This document provides a brief overview of the comprehensive risk management activities that have been designed and implemented at this site, including:



- A description of the facility and use of substances regulated by EPA's RMP regulation;

- An overview of the accidental release prevention programs;

- A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule;

- An overview of the emergency response program;

- An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting employees, the public, and the environment; and

- The certification required by EPA's RMP rule.



Site Identification and Regulated Substances



DPE Pontchartrain Site operates on approximately 1,138 acres in Sections 90, 91, 92 and 93 of Township 115, Range 7 East in St. John the Baptist Parish, Louisiana, on property owned by DuPont. Approximately 200 acres are used for actual manufacturing activities. The site is located one mile west of LaPlace at 560 Highway 44 at approximately River Mile 136 on the Mississippi
River.



At this site, DPE manufactures neoprene a synthetic rubber that has been produced for nearly 83 years; chloroprene, which is used as the raw material in the production of neoprene; and ACR (2,3-dichloro-1,3-butadiene) which is used as an additive in some types of neoprene. Some of neoprene's end uses are: adhesives and sealant, power transmission belts and hoses for automobiles, and wire and cable jacketing.



This site uses the following chemicals listed under the RMP regulation:



Toxics



- Chlorine

- Nitrogen Tetroxide (Louisiana's list)



Flammables



- 1,3-Butadiene

- Pentane



The production areas covered at this site were divided in to four processes per guidance given by the Louisiana Department of Environmental Quality during their March 2004 RMP inspection. The first process is the portion of the neoprene process which uses nitrogen tetroxide to manufacture DIBN (diisobutylene nitrosate) an inhibitor in the manufacture of neoprene. The process hazard analysis (PHA) information in Section 7 was obtained from PHA 14-341. This PHA covers the portion of the neoprene process where nitrogen tetroxide is used.



The second process is the chloroprene process, which uses chlorine, pentane and 1,3-butadiene as raw materials. The process hazard analyses (PHA) information in Section 7 was obtained from PHA 13-337. While several PHAs cover this area of the plant, this is the most recent PHA completed for the portion of the process where one of these three chemicals are used and it covers chlorine process equipment.



The third process is the chlorine storage facilities. Chlorine is used as one of the raw materials in the production of chloroprene. It is received in tank cars and stored in five refrigerated bullets. The process hazard analyses (PHA) information in Section 7 was obtained from PHA 13-337.



The fourth process is the butadiene railcar unloading facilities. Butadiene is a raw material used in the manufacture of chloroprene
. Butadiene is received in railcars and unloaded into a storage sphere, from the sphere is fed into the process. The process hazard analyses (PHA) information in Section 7 was obtained from PHA 11-328.





General Accidental Release Prevention Program and Chemical - Specific Prevention Steps



DPE takes a systematic, proactive approach to preventing accidental releases of hazardous chemicals. The Process Safety Management (PSM) program follows OSHA's Guidelines and is directed toward preventing serious, process-related incidents which might affect plant personnel, off-site communities, the environment, or result in significant property loss or loss of business. It involves the application of systems and controls to chemical and manufacturing processes in a way that hazards are identified, understood and controlled so that process-related injuries and incidents are prevented. The process safety management systems include the following items:



- A thorough understanding of the process technology, including the safe limits of the processes and the proper materials of construction for equipment;

- Proper design and installation of equipment;

- Systematic process hazard reviews to identify and address process hazards;

- Written operating and maintenance procedures;

- Extensive training for all persons who operate or maintain chemical process equipment;

- Mechanical integrity testing and preventive maintenance for early detection of potential equipment problems;

- Mechanical quality assurance programs to ensure that the correct spare parts are installed whenever maintenance is performed;

- Procedures to identify and manage both obvious and subtle changes in technology, equipment, and personnel, that could have an effect on the site's safety and environmental performance;

- Pre-startup safety reviews for newly installed or modified equipment;

- Compliance audits to ensure that process safety management principles, procedures, and regulations are effectiv
e and properly implemented;

- Investigation of actual and potential incidents to identify and implement corrective actions;

- Participation of all employees in the process safety management system;

- Documented safe work practices, including hot work procedures requiring the issuance of hot work permits;

- Contractor safety management system to ensure that work done by contractors is performed safely and in compliance with DPE standards;

- Storage of covered chemicals is minimized to meet business needs. The maximum storage of chlorine tank cars and butadiene is used only rarely and for short periods because of differences between shipments and/or to accommodate supplier's production schedule.



In addition to the practices described above, processes are designed to include multiple layers of safeguards. Examples of these include:



- Automatic valves for rail cars, which isolate the supply of materials from the rail car in the event of a process upset;

- Computer display and control of process parameters;

- Interlocks to automatically shut down processes for certain process deviations;

- Low concentration chlorine detectors that sound an alarm and provide an alarm signal to the computerized process control system when a leak is detected;

- Emergency scrubber system to prevent emissions from reaching the environment;

- Isolation valves which can be operated remotely from the process control system;

- Deluge systems built into the process to quickly suppress chemical fumes or fires;

- Check valves to prevent cross contamination of chemicals;

- Fire prevention activities like electrical grounding, inerting flammables with nonflammable gases and hot work permitting; and

- Operator surveillance during transfer of hazardous materials from shipping containers.



Five Year Accident History



Records of all significant accidental chemical releases that occur are kept. No off-site injuries, evacuations, sheltering in place, property damage or environm
ental damage has occurred involving materials and processes covered under the EPA's RMP rule during the last five years. It should be noted that there was one chlorine related incident with on-site injury within the past six month period. Details are included in Section 6 within this submittal.



Emergency Response Plan



The site has an Emergency Response Plan, which establishes procedures and responsibilities for the various functions involved in handling any plant emergency, either internal or external to this site. This plan consolidates all the federal, states, and local regulatory requirements for emergency response planning. Drills are conducted on a regular basis and are coordinated with the Local Emergency Planning Committee.



Planned Changes to Improve Safety



As part of the site's process hazards review procedures, all of the processes are thoroughly studied on a periodic basis to identify risk reduction opportunities. As a result of these studies, the site continues to implement a number of activities to help identify new risk reduction opportunities and maintain those already implemented. A few of those activities are:



- Continue to improve the control of the process by installing better instrumentation, more automatic process shutdown interlocks, and upgraded computer control systems as replacements are needed;

- Continue to perform preventive maintenance inspections and improve procedures;

- Continue improvement of training programs; and

- Continue conducting process safety audits to identify any deficiencies in the management systems.



It should be noted that our certifying official has changed since the last submittal. It should also be noted that some of the maximum intended inventories (section 1.17.c) have been updated and as noted above the Site recently experienced a chlorine release with on-site injury with details cited in Section 6 of this submittal.