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CERTAINTEED CORPORATION

Parent Companies:
SAINT-GOBAIN CORPORATION
EPA Facility ID:
100000098869
Other ID:
70664CRTNTPETEM
Facility DUNS:
2358265
Parent Company DUNS:
275517225

Location:

Address:
3300 PETE MANENA ROAD
WESTLAKE, LA 70669
County:
CALCASIEU
Lat / Long:
30.227, -93.298 (Get map)
Method:
Interpolation - Map
Description:
Plant Entrance (General)
Horizonal accuracy:
30 m
Horizontal reference datum:
World Geodetic System of 1984
Source map scale:
24000

Owner/Operator:

Name:
CERTAINTEED CORPORATION
Phone:
(337) 882-1441
Address:
P.O. BOX 1189
SULPHUR, LA 70664
Foreign Address:

Person responsible for RMP implementation:

Name:
Hiram Pabon
Title:
PSM/EHS Manager

Emergency contact:

Name:
Hiram Pabon
Title:
PSM/EHS Manager
Phone:
(337) 708-2716
24-hour phone:
(337) 499-1659
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(337) 882-1441
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Calcasieu Parish LEPC
Full-Time Equivalent Employees:
43
Covered by OSHA PSM:
Yes
EPCRA section 302:
No
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Feb. 26, 2015
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

PVC MANUFACTURING
RMP ID:
1000064326
CBI claimed:
No
Program Level:
3
NAICS:
Plastics Material and Resin Manufacturing (325211)
Chemical name
CAS#
Quantity (lbs.)
CBI
Vinyl chloride [Ethene, chloro-]
75-01-4
1,200,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Franciscus Prawiro
Address:
8235 YMCA Plaza Drive
Suite 300
Baton Rouge, LA 70810
Foreign Address:

Phone:
(225) 408-2858

Latest RMP Submission:

Date:
Aug. 12, 2015
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000050978

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

None

3. Toxics: Alternative release

None

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 PVC MANUFACTURING)
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 PVC MANUFACTURING)
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

No Registered Accidents

7. Prevention: Program level 3

PVC MANUFACTURING, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000053398
Safety Review Date
May 11, 2015, since latest RMP submission
PHA Update Date
July 11, 2014, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
June 29, 2015, since latest RMP submission
Training Review Date
Feb. 25, 2015, since latest RMP submission
Maintenance Review Date
July 3, 2012, since latest RMP submission
Maintenance Inspection Date
Jan. 19, 2013, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 25, 2015
Management of Change Review Date
June 22, 2010
Pre-startup Review Date
May 29, 2015
Compliance Audit Date
Feb. 23, 2013
Compliance Audit Change Completion Date
Dec. 31, 2016
Incident Investigation Date
May 28, 2015
Incident Invest. Change Completion Date
Dec. 31, 2016
Participation Plan Review Date
July 22, 2013
Hot Work Review Date
March 24, 2009
Contractor Safety Review Date
Jan. 15, 2012, since latest RMP submission
Contractor Safety Eval. Date
Feb. 23, 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:
April 30, 2015
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

The CertainTeed Corporation (CertainTeed), Lake Charles Polymer Plant located in Calcasieu Parish, Louisiana produces a high quality polyvinyl chloride (PVC) polymer resin with a maximum capacity production rate of 1,500,000 pounds per day. Currently the dry bulk polymerization process produces a normal operating rate of approximately 1,000,000 pounds per day.



ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES

CertainTeed is a subsidiary of Compagnie de Saint-Gobain (Saint-Gobain), who has based its development upon respect for people and their environment. This commitment is formalized in the Principles of Conduct and Action. Adherence to these principles is a condition for belonging to our company.



EHS (Environmental, Health and Safety) are fundamental values for Saint-Gobain. The EHS policy guides Saint-Gobain over the long term, bringing benefits to both people and their environment, and assuring the success of our strategy.



Health and Safety, which together form the first pillar of our EHS policy, contribute directly to the improvement of the working conditions and to the well-being of everyone. All work-related accidents and occupational illnesses are, by their very nature, unacceptable. We work tirelessly to achieve the only possible goal: zero work-related accidents and zero occupational illnesses.



Potential of the environment is the second pillar of our EHS policy, requiring our constant commitment and attention. It is essential to mobilize all our employees, in all countries, to achieve the only acceptable goal: zero environmental accidents and the maximum possible reduction of the impact of our activities.



Responsibility for the implementation of the Group's EHS policy lies at all levels of the organization. Within the general framework established by Saint-Gobain, each Sector defines a specific action plan related to its particular activities and processes. The delegations coordinate general EHS actions across business units,
particularly those related to the specific conditions of the country. The entire local management is committed to ensuring the full implementation and application of the EHS policy.



The Lake Charles Polymer Plant EHS Policy states that all employees, contractors and visitors at the Lake Charles Plant have a right to expect a safe, healthy, and injury-free workplace. Furthermore, the policy includes a pledge that the highest priority of actions and guidance will be to ensure the health and safety of all employees and our environment.



The Lake Charles Plant is committed to complying with all Saint-Gobain, CertainTeed Siding Products Group, OSHA, and site specific Environmental, Health and Safety policies. Additionally, we are committed to continually improving our EHS standards and performance.



Furthermore, the CertainTeed Lake Charles Polymer Plant is registered to the ISO 14001:2004 Standard and utilizes this documented system to manage the required elements of the CAA Risk Management Program. The Plant Technical Manager has overall responsibility for both programs, ISO 14001 and RMP. The Plant EHS Manager has responsibility for managing the OSHA Process Safety Management Program at the Lake Charles Polymer Plant. The Technical Manager works closely with the EHS Manager to ensure that the implementation and integration of all the applicable RMP elements are successful and sustained in conformance with the applicable requirements.



FACILITY BACKGROUND AND REGULATED SUBSTANCE HANDLED

CertainTeed Corporation has manufactured polyvinyl chloride (PVC) polymer in the Lake Charles, Louisiana area since 1975. The polymer resin is produced from vinyl chloride (CAS #75-01-4) monomer. This colorless gas with a sweet smell is a toxic, flammable carcinogen that can be formed in the environment when soil organisms break down "chlorinated" solvents.



At the CertainTeed Lake Charles Polymer Plant two reactor trains are available to produce PVC. The Poly1 react
or train has six reactors, and the Poly2 reactor train has three reactors. The nine reactors are identical in design, size, capacity, and operation. The two reactor trains produce PVC resin using the same formulation and additives, resulting in the production of a single type and grade of PVC resin. Currently, due to economic condition, only Poly 1 is producing PVC resin, as Poly 2 has been idled.



The vinyl chloride monomer (VCM) feedstock is received from an offsite source via pipeline. The VCM is polymerized in a two-step process utilizing a pre-polymerizer and an autoclave (reactor). The VCM is stored in the VCM storage tanks. From the VCM storage tanks, the VCM is transferred to the VCM day tank. The VCM day tank charges the pre-polymerizers and the autoclaves. When the polymerization is complete in the autoclave, the dry PVC powder is degassed of its residual vinyl chloride in four sequential degassing cycles. The residual VCM vapor is sent to the VCM vapor recovery area. The stripped PVC powder is transferred to product classification and subsequently stored for railcar load-out.



In the VCM recovery area, residual VCM vapor is condensed and returned to the VCM day tank. Non condensable vapors from the VCM vapor recovery area are routed to the thermal oxidizers. Condensed water is sent to a wastewater stripper for removal of entrained VCM, and the wastewater stripper overheads are routed to the thermal oxidizers.



GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS

CertainTeed has deployed the facility's Process Safety Management (PSM) and Risk Management Plan (RMP) activities and address the requirement for a compliance audit every three (3) years as defined in 29 CFR 1910.119, "Process Safety Management of Highly Hazardous Chemicals" and 40 CFR Part 68, "Chemical Accident Prevention Provisions." These regulations are performance-based management system regulations intended to prevent explosions and catastr
ophic releases of highly hazardous chemicals.



CertainTeed originally designed the Plant and has maintained the minimal inventory approach to storing and handling VCM and other hazardous materials on site. The VCM raw material storage vessel receives inventory from an industrial neighbor via above ground pipeline. This requires no loading or offloading facilities. If the supply is stopped, CertainTeed's production will have to cease in a six-to-eight-hour time frame. This stored quantity (63,680 gal. capacity) is manageable within the boundaries of the facility. The total volume of material can be contained locally with its concrete containment walls. Fumes and fire can be managed locally with automatic stationed fire cannons and a deluge system.



The PVC process equipment has multi-safety systems in the event of temperature, pressure, or reaction swings (high or low). Process deviation procedures are located in the "Production Procedure" Manual. Standard operating procedures outline how to recognize process deviations and how to correct problems.



VCM has a permissible exposure limit (PEL) of 1 part per million for an eight-hour time-weighted average. With such a low biological index, CertainTeed has placed area monitors that alarm if there is an indication of vinyl chloride in any part of the Plant. When the alarm sounds, protective measures are used to protect the employees and others that may be on site including evacuation of non-essential personnel from the immediate area while operations and maintenance personnel don respiratory protection until the source has been repaired.



The Plant also has a Management of Change (MOC) process in place to evaluate any changes in the process for potential risks that a change could introduce so protective measures can be implemented to eliminate or minimize any such risks. Pre-startup Safety Reviews (PSSRs) are also conducted prior to start-up after a change is implemented to confirm equipment is installed
as designed, procedures and other documentation are updated, and personnel are trained on the change.



FIVE-YEAR ACCIDENT HISTORY

CertainTeed is proud that the facility has had no incidents that impacted the public in the last five years and are required to be reported per the RMP regulations. However, on April 19, 2015 there was an incident that released approximately 250 pounds of vinyl chloride, which, to the best of our knowledge, had no impact on the environment. A release of this amount is less than the alternate release evaluated with the offsite consequence analysis, which is predicted to result in no offsite impact.



EMERGENCY RESPONSE PROGRAM

CertainTeed has developed emergency plans and programs to address internal and external response actions, and to evaluate risks of existing and new equipment systems. The facility's Emergency Response Plan (ERP) includes the following features:

- Material Risk Identification

- Measures and controls

- Emergency Procedures

- Site Evaluation

- Emergency Response/Evacuation

- Hurricane/Severe Weather Procedures

- Fire/Explosion/Bomb Threat Procedures

- ISO 14001:2004 Registered

The facility also actively participates in the Calcasieu Parish Office of Emergency Preparedness programs and has been a member of the Southwest Louisiana Mutual Aid Association since 1975. CertainTeed conducts readiness training and exercises to ensure effective emergency response capability is available, if necessary. These exercises are evaluated to assess results and implement corrective actions.



PLANNED CHANGES TO IMPROVE SAFETY

Continuous improvement is driven by Saint-Gobain's EHS Frame of Reference which is derived from the concept of the "Deming wheel" represented by the "Plan Do Check Act" cycle. The Frame of Reference also describes the EHS management system that the site managers must implement. This principle allows Saint-Gobain to implement and continually improve the EHS management system extended to all process
es, products and services throughout their life cycle. This continuous loop is perpetuated until an interdependent autonomous EHS culture is realized.



A recent example of continuous improvement is the incident investigation and implementation of actions resulting from the investigation. Action items include completing a procedure review, and additional engineering measures have been identified to improve the safety of the operation. The engineering scope has been developed, and detailed plans to implement the work are being developed at this time. Visual inspections and confirmation of operating procedures are performed prior to the start of each batch.