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Louisiana Pigment Company, L.P.

Parent Companies:
KRONOS Louisiana, Inc.
Tioxide Americas, Inc.
EPA Facility ID:
100000089183
Other ID:
70669KRNSL3300B
Facility DUNS:
809154958
Parent Company #1 DUNS:
607121258
Parent Company #2 DUNS:
83977561

Location:

Address:
3300 Bayou D'Inde Road
Westlake, LA 70669
County:
CALCASIEU
Lat / Long:
30.196, -93.307 (Get map)
Method:
Interpolation - Photo
Description:
Center of Facility
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Louisiana Pigment Company, L.P.
Phone:
(337) 882-7000
Address:
3300 Bayou D'Inde Road
Westlake, LA 70669 -9638
Foreign Address:

Person responsible for RMP implementation:

Name:
Dr. Timothy J. Hall
Title:
Plant Manager

Emergency contact:

Name:
Dr. Timothy J. Hall
Title:
Plant Manager
Phone:
(337) 882-7018
24-hour phone:
(337) 882-7000
Ext or PIN:

Other contacts:

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

Safety:

Local Emergency Planning Committee:
Calcasieu Parish LEPC
Full-Time Equivalent Employees:
305
Covered by OSHA PSM:
No
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
0520-00142-V8
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Feb. 11, 2014
Inspecting Agency:
OSHA
Using Predictive Filing:
No

Processes:

Titanium Tetrachloride
RMP ID:
1000051344
CBI claimed:
No
Program Level:
2
NAICS:
Synthetic Dye and Pigment Manufacturing (32513)
Chemical name
CAS#
Quantity (lbs.)
CBI
Titanium tetrachloride [Titanium chloride (TiCl4) (T-4)-]
7550-45-0
970,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
May 13, 2014
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000041686

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 Titanium Tetrachloride)
CBI claimed:
No
Percent weight:
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
518.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • Enclosures
not considered:
  • Dikes
  • 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 Titanium Tetrachloride)
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:
  • Enclosures
not considered:
  • Dikes
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Emergency shutdown
not considered:
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers

4. Flammables: Worst-case

None

5. Flammables: Alternative release

None

6. Five-year accident history

Sept. 7, 2011 at 10:23
ID:
1000033464
NAICS:
Synthetic Dye and Pigment Manufacturing (32513)
Duration:
27 minutes
Chemicals involved:
  • Titanium tetrachloride [Titanium chloride (TiCl4) (T-4)-]
  • Chlorine
Release events:
Gas release
Weather conditions at time of event
Wind speed:
7.0 miles/h NE
Temperature:
75.00 ℉
Atmospheric stability:
C
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
0
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$56765
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
10
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Equipment failure
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • New process controls

7. Prevention: Program level 3

No Prevention Program level 3

8. Prevention Program level 2

Titanium Tetrachloride, Synthetic Dye and Pigment Manufacturing (32513)
Prevention Program ID:
1000033794
Safety Review Date
Dec. 7, 2012, since latest RMP submission
PHA Update Date
, since latest RMP submission
Safety Regulations
  • NFPA 58
  • ASTM Standards
  • ANSI Standards
  • ASME Standards
Hazards Identified
  • Toxic Release
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
  • Water Curtain
  • Enclosure
  • Neutralization
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Dec. 31, 2013, since latest RMP submission
Training Review Date
March 27, 2014, since latest RMP submission
Maintenance Review Date
Aug. 22, 2013, since latest RMP submission
Maintenance Inspection Date
Feb. 27, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Management of Change Review Date
Pre-startup Review Date
Compliance Audit Date
Sept. 24, 2012
Compliance Audit Change Completion Date
Sept. 24, 2015
Incident Investigation Date
July 12, 2013
Incident Invest. Change Completion Date
March 14, 2014
Participation Plan Review Date
Hot Work Review Date
Contractor Safety Review Date
, since latest RMP submission
Contractor Safety Eval. Date
, since latest RMP submission

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:
March 25, 2014
Local Response Agency:
Local Response Agency Phone:
(337) 439-9911
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



11496 LDEQ Facility ID Number



Louisiana Pigment Company, L.P. (Louisiana Pigment) is one of the world's newest titanium dioxide manufacturing plants, beginning production in April 1992. The facility, located near Lake Charles, Louisiana, is comprised of a 40-acre "state-of-the-art" plant site with an additional 100+ acres used for parking, administrative offices, training area, and an industrial waste landfill.



The Accidental Release Prevention and Emergency Response Policies



Louisiana Pigment is dedicated to operating a manufacturing facility that maintains a strong respect for our environment and a safe work place for all employees. Louisiana Pigment takes great pride in our efforts to continuously evaluate the operation of our process, equipment function and efficiency, and procedures, both management and process, to find ways of improving our ability to prevent accidents from occurring and to minimize the impact if the worst occurs.



Procedures have been developed to enhance our ability to evaluate events that have a potential for unfavorable results. Computer tracking databases have been purchased and developed that provide management an overall view of the process and maintenance activities. An event database has been developed to track both safety and environmental events, including the implementation of any corrective actions that have been determined by an investigative team and/or management that is necessary to prevent a reoccurrence in the future.



Louisiana Pigment participates in the OSHA's Voluntary Protection Program, VPP. Louisiana Pigment received our first OSHA Star in 2005, and successfully recertified under the program in 2010 and most recently in March 2014.



Chemical Manufacture Process



Product Utilization



Louisiana Pigment manufactures in excess of 150,000 metric tons per year of titanium dioxide by utilizing the chloride process. Titanium dioxide is used in industry for generating brilliantl
y hued paints, in the manufacturing of primers and base coats, in automotive finishes, and in coatings for the exterior of buildings. Beyond this, titanium dioxide can be found in materials such as high-quality papers, color plastics, furniture panels, textile fibers, glass, ink, porcelain, toothpaste, cosmetics, candy, food coloring, PVC, white sidewall tires, and a growing list of other items. Plastics are transparent and acquire their gleaming whites and opacities through the addition of titanium dioxide. Titanium dioxide also improves the physical properties of many plastics. It absorbs ultraviolet light, making the material more resistant to weathering.



Manufacturing Process



The chloride process at Louisiana Pigment uses high-grade titanium ores (natural rutile, titanium ores, or synthetic rutile) to recover titanium dioxide (TiO2). This is done by first producing titanium tetrachloride (TiCl4) as an intermediate product, then oxidizing it to form TiO2 particles to the purity required for further processing and finishing treatment.



The two steps that most characterize the Chloride Process are the continuous chlorination of ore in the fluidized bed chlorinator and the continuous oxidation of titanium tetrachloride in the gas phase to titanium dioxide using a burner. These two steps are completely dependent upon each other since the chlorine released by oxidation is recycled to the chlorinator. Through the use of analytical measurement and computer control technology, it is possible to optimize essential production variables, reduce down time to a minimum, and operate machinery at maximum safety standards. On the premise that operating conditions are kept at an optimum for every step of the chloride process, 90-95% of the titanium dioxide contained in the original ore can be recovered and used in the end product.



Accidental Release Prevention Program and Chemical-Specific Prevention Steps



The Federal Clean Air Act (CAA) Amendments of 1990 a
dded Section 112 to the CAA, which mandated the U.S. Environmental Protection Agency (EPA) to establish a regulatory program to prevent serious chemical accidents that may potentially affect public health and the environment. The resulting regulations referred to as EPA's Accident Prevention program (Risk Management Planning), required certain companies, municipalities, and industries to provide information about potential risks associated with their operations. Louisiana Pigment assessed its operation and determined that titanium tetrachloride is stored at the facility in excess of the threshold quantity.



Louisiana Pigment has made a commitment to our employees and community that we will endeavor to provide a safe workplace for our employees and to conduct our business as a responsible member of our surrounding community. In keeping with this policy, Louisiana Pigment endeavors to extend attention to risk management "beyond our fence line." Louisiana Pigment's Risk Management Program and internal initiatives comprises a series of management practices that support the goal of preventing fires, explosions, accidental chemical release, and encourage safety at the plant and at home. Louisiana Pigment is committed to the Responsible Care Guiding Principles:



1.To recognize and respond to community concerns about chemicals and our operations.

2.To make health, safety, and environmental considerations a priority in our planning for all existing and new plants and processes.

3.To operate our plants and processes in a manner that protects the environment, health, and safety of our employees, and the public.



Risk Management is an interdisciplinary effort composed of Management Practices divided into four elements:



1.Management Leadership

2.Technology

3.Facilities

4.Personnel



Collectively, these practices encompass process safety from the design stage through operation, maintenance, and training. Louisiana Pigment believes that adherence to the Managem
ent Practices provides for a continuous evaluation of our safety and environmental systems.



Louisiana Pigment utilizes elements of OSHA's PSM standard in various management systems. Underscoring our systems is the belief that all prevention activities begin with management leadership and are effectively conducted via employee participation. Louisiana Pigment has implemented several new programs to encourage all employees and resident contractors to have a primary role in assessing their work environment and to recommend changes.



1.Survey, Consider, Analyze, and Notify (SCAN) is a program that provides all employees a method to identify and correct unsafe conditions, recommend improvements to job task, and other recommendations to improve the workplace to Management.



2.Safe Track is a behavioral observation program in which employees volunteer and are trained as observers. The observers then participated in reviewing actual job tasks completed in the field. This provides an opportunity to observe and make changes that could improve the safety of conducting the task in the field.



3.Incident Investigations may be conducted to determine, both direct and indirect causal factors, for an event and make recommendations to minimize the reoccurrence of the event.



Louisiana Pigment continues to empha and encourages all employees, including contractors to participate in all the programs and the individual Safety Committees in a strong effort to make Louisiana Pigment a safe work environment.



Five-Year Accident History



In the past five years, Louisiana Pigment has only had one event that occurred on September 7, 2011. The incident occurred when two holes developed in the bottom head of the Aluminum Chloride Generator (C335-B). The event released approximately 1.5 pounds of chlorine and 855.3 pounds of titanium tetrachloride. Since the wind direction was out of the northeast, Louisiana Pigment issued a Shelter in Place for the facilities downwind o
f the release until the release was secured.



Emergency Response Program



At Louisiana Pigment we work hard to ensure the best operating conditions, but we make sure our personnel are prepared for the worst. Our emergency preparedness and response plans are supported and thoroughly tested. There are five key components for a quality emergency preparedness and response plan; Personnel Resources, Planning, Communications, and Alliances. The program includes many methods and activities such as:



1.Extensive training in our operational processes, maintenance activities, and specific job safety training.

2.Providing workplace monitoring to control and identify areas where appropriate personal protective equipment may be necessary.

3.Providing state-of -the-art personal protective equipment, available to all personnel working at our facility.

4.Utilizing employee input through our employee Safety Committees, SCAN Card and SafeTrack Observation programs.

5.Maintaining an Employee Safety and Activities Team (ESAT) which promotes safety awareness through the use of employee involvement and various award programs.

6.Providing an on-site Medical Department to provide immediate care for employees in need.



Louisiana Pigment maintains a voluntary on-site emergency response team. This team is comprised of chemical response, fire brigade, structural rescue, and emergency medical members. Routine training of the team provides opportunities to maintain and enhance their skills.



Louisiana Pigment is an active member of the Local Emergency Planning Committee (LEPC), the Southwest Mutual Aid Organization and the Community Awareness Emergency Response (CAER) program. Louisiana Pigment installed a Community Awareness Siren that can be activated by the plant to notify the surrounding community of a release that may require them to Shelter in Place.



Maintaining a commitment to our employees and community is an on-going effort. Continually pursuing opportunities
for improvements in our environmental and safety programs which may include interactions with our local community help Louisiana Pigment to be a responsible member of our surrounding community.



Planned Changes to Improve Safety



Louisiana Pigment endeavors to provide a safe work place for all personnel who work at the site. To this end, safety systems such as incident investigation, corrective action tracking, near miss reporting, SCAN, and Safe Track and internal auditing have been developed and continuously improved. An excellent base of safety systems exists to ensure safe work procedures and proper personal protective equipment.



Recognizing that human behavior plays an integral role in safety performance, Louisiana Pigment has focused more attention in recent years to the human dimension of safety. A safety culture has been established that makes safety a value in all aspects of our operation. Key to this culture is full management commitment to safety along with employee awareness and commitment, both on-the-job and off-the-job. Employees throughout the organization are trained to champion safety by demonstrating safe behavior and watching out for co-workers.



Louisiana Pigment is careful to include contract personnel in all aspects of the safety improvement process. The Safety Council of Southwest Louisiana is used for basic training of contract personnel, a commitment made by all industry associated with the Lake Area Industrial Alliance (LAIA). Proof of this basic training is verified for each contract employee entering the site. Additional safety training is provided by the contractors for their employees. Finally, each contract employee receives process-specific safety training in the area in which he/she will work.



Summary



Louisiana Pigment is one of the world's newest titanium dioxide manufacturing plants, beginning production in 1992. The facility is designed and constructed using state-of-the-art technology for process contro
l and employs environmental technology that meets and/or exceeds the regulatory requirements. We have established internal systems to evaluate and improve our manufacturing process, environmental controls, and safety programs that provide for ownership and accountability. These policies and procedures, including the Risk Management Plan, are in place to ensure that we will continue to operate the facility while maintaining our commitment for an environmental secure and safe workplace to our employees and the community.