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Intercontinental Terminals Co.-Anchorage Terminal

Parent Companies:
Intercontinental Terminals Company, LLC
EPA Facility ID:
100000107163
Other ID:
Facility DUNS:
0
Parent Company DUNS:
67280073

Location:

Address:
2449 North River Road
Port Allen, LA 70767
County:
WEST BATON ROUGE
Lat / Long:
30.483, -91.203 (Get map)
Method:
Interpolation - Map
Description:
Process Unit Area Centroid
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Intercontinental Terminals Company
Phone:
(225) 389-0170
Address:
2449 North River Road
Port Allen, LA 70767
Foreign Address:

Person responsible for RMP implementation:

Name:
Jeffrey C. Ratcliff
Title:
SHES Manager

Emergency contact:

Name:
Terry Taylor
Title:
Terminal Manager
Phone:
(225) 389-0170
24-hour phone:
(225) 405-9591
Ext or PIN:
16

Other contacts:

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

Safety:

Local Emergency Planning Committee:
West Baton Rouge Parish LEPC
Full-Time Equivalent Employees:
20
Covered by OSHA PSM:
Yes
EPCRA section 302:
No
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
3120-00002-V0
OSHA Star/Merit Ranking
Yes
Last Safety Inspection Date:
Feb. 12, 2009
Inspecting Agency:
EPA
Using Predictive Filing:
Yes

Processes:

Crude Butadiene
RMP ID:
1000049415
CBI claimed:
No
Program Level:
3
NAICS:
Other Chemical and Allied Products Merchant Wholesalers (42469)
Chemical name
CAS#
Quantity (lbs.)
CBI
2-Butene-cis
590-18-1
15,000
No
Isoprene [1,3-Butadiene, 2-methyl-]
78-79-5
120,000
No
2-Butene-trans [2-Butene, (E)]
624-64-6
22,500
No
1,3-Butadiene
106-99-0
12,840,000
No
Butane
106-97-8
1,070,000
No
Butene
25167-67-3
6,420,000
No
2-Methylpropene [1-Propene, 2-methyl-]
115-11-7
6,420,000
No
2-Butene
107-01-7
37,500
No
1-Butene
106-98-9
52,500
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Dilute Propylene
RMP ID:
1000049416
CBI claimed:
No
Program Level:
3
NAICS:
Other Chemical and Allied Products Merchant Wholesalers (42469)
Chemical name
CAS#
Quantity (lbs.)
CBI
Propane
74-98-6
1,076,400
No
Propylene [1-Propene]
115-07-1
1,943,500
No
Butane
106-97-8
50,800
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Refined Butadiene
RMP ID:
1000049417
CBI claimed:
No
Program Level:
3
NAICS:
Other Chemical and Allied Products Merchant Wholesalers (42469)
Chemical name
CAS#
Quantity (lbs.)
CBI
1,3-Butadiene
106-99-0
22,900,000
No
Public OCA Chemical
0
No
Chemical Grade Propylene
RMP ID:
1000049418
CBI claimed:
No
Program Level:
3
NAICS:
Other Chemical and Allied Products Merchant Wholesalers (42469)
Chemical name
CAS#
Quantity (lbs.)
CBI
Propylene [1-Propene]
115-07-1
1,172,000
No
Public OCA Chemical
0
No
Isobutylene
RMP ID:
1000049419
CBI claimed:
No
Program Level:
3
NAICS:
Other Chemical and Allied Products Merchant Wholesalers (42469)
Chemical name
CAS#
Quantity (lbs.)
CBI
2-Methylpropene [1-Propene, 2-methyl-]
115-11-7
5,500,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Intercontinental Terminals Company, LLC
Address:
2449 North River Road
Baton Rouge, LA 70767
Foreign Address:

Phone:
(225) 389-0170

Latest RMP Submission:

Date:
April 15, 2014
Type:
Resubmission
Reason:
Newly regulated substance above TQ in already covered process (40 CFR 68.190(b)(3))
Registered:
Yes
RMP ID:
1000040061

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 Refined Butadiene)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • Fire Walls
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 Refined Butadiene)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • Fire wall
not considered:
  • Dikes
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Water curtain
  • Excess flow valve

6. Five-year accident history

Aug. 12, 2013 at 14:00
ID:
1000032880
NAICS:
Other Chemical and Allied Products Merchant Wholesalers (42469)
Duration:
3 hours and 20 minutes
Chemicals involved:
  • 1,3-Butadiene
Release events:
Gas release
Weather conditions at time of event
Wind speed:
3.0 miles/h WSW
Temperature:
75.00 ℉
Atmospheric stability:
E
Precipitation present:
Yes
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:
$0
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
40
Sheltered-in-place:
100
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Equipment failure
  • Maintenance activity/inactivity
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Revised maintenance
  • Revised operating procedures

7. Prevention: Program level 3

Crude Butadiene, Other Chemical and Allied Products Merchant Wholesalers (42469)
Prevention Program ID:
1000042636
Safety Review Date
June 20, 2013, since latest RMP submission
PHA Update Date
May 21, 2013, since latest RMP submission
PHA Techniques
  • What if
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Polymerization
  • Overpressurization
  • Overfilling
  • Equipment failure
  • Cooling loss
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Nov. 7, 2013, since latest RMP submission
Training Review Date
Feb. 26, 2014, since latest RMP submission
Maintenance Review Date
May 15, 2013, since latest RMP submission
Maintenance Inspection Date
Dec. 9, 2013, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Feb. 20, 2011
Management of Change Review Date
Dec. 11, 2013
Pre-startup Review Date
Dec. 11, 2013
Compliance Audit Date
Oct. 19, 2012
Compliance Audit Change Completion Date
May 1, 2013
Incident Investigation Date
Aug. 22, 2013
Incident Invest. Change Completion Date
Dec. 9, 2013
Participation Plan Review Date
Dec. 11, 2013
Hot Work Review Date
March 18, 2014
Contractor Safety Review Date
Oct. 27, 2009, since latest RMP submission
Contractor Safety Eval. Date
April 30, 2013, since latest RMP submission
Dilute Propylene, Other Chemical and Allied Products Merchant Wholesalers (42469)
Prevention Program ID:
1000042637
Safety Review Date
Feb. 7, 2014, since latest RMP submission
PHA Update Date
Oct. 4, 2011, since latest RMP submission
PHA Techniques
  • What if
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
  • Overfilling
  • Equipment failure
  • Cooling loss
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Fire Walls
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Nov. 7, 2013, since latest RMP submission
Training Review Date
Feb. 26, 2014, since latest RMP submission
Maintenance Review Date
May 15, 2013, since latest RMP submission
Maintenance Inspection Date
Aug. 31, 2011, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Oct. 24, 2011
Management of Change Review Date
Dec. 11, 2013
Pre-startup Review Date
Dec. 11, 2013
Compliance Audit Date
Oct. 19, 2012
Compliance Audit Change Completion Date
May 1, 2013
Incident Investigation Date
Aug. 22, 2013
Incident Invest. Change Completion Date
Dec. 9, 2013
Participation Plan Review Date
Nov. 12, 2013
Hot Work Review Date
March 18, 2014
Contractor Safety Review Date
Oct. 27, 2009, since latest RMP submission
Contractor Safety Eval. Date
April 30, 2013, since latest RMP submission
Refined Butadiene, Other Chemical and Allied Products Merchant Wholesalers (42469)
Prevention Program ID:
1000042633
Safety Review Date
Dec. 27, 2013, since latest RMP submission
PHA Update Date
Oct. 4, 2011, since latest RMP submission
PHA Techniques
  • What if
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Polymerization
  • Overpressurization
  • Overfilling
  • Equipment failure
  • Cooling loss
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Backup Pump
  • Grounding Equipment
Mitigation Systems
  • Fire Walls
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Nov. 7, 2013, since latest RMP submission
Training Review Date
Feb. 26, 2014, since latest RMP submission
Maintenance Review Date
May 15, 2013, since latest RMP submission
Maintenance Inspection Date
Dec. 9, 2013, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Feb. 20, 2011
Management of Change Review Date
Dec. 11, 2013
Pre-startup Review Date
Dec. 11, 2013
Compliance Audit Date
Oct. 19, 2012
Compliance Audit Change Completion Date
May 1, 2013
Incident Investigation Date
Aug. 22, 2013
Incident Invest. Change Completion Date
Dec. 9, 2013
Participation Plan Review Date
Nov. 12, 2013
Hot Work Review Date
March 18, 2014
Contractor Safety Review Date
Oct. 27, 2009, since latest RMP submission
Contractor Safety Eval. Date
April 30, 2013, since latest RMP submission
Chemical Grade Propylene, Other Chemical and Allied Products Merchant Wholesalers (42469)
Prevention Program ID:
1000042634
Safety Review Date
Feb. 7, 2014, since latest RMP submission
PHA Update Date
Oct. 4, 2011, since latest RMP submission
PHA Techniques
  • What if
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
  • Overfilling
  • Equipment failure
  • Cooling loss
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Fire Walls
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Nov. 7, 2013, since latest RMP submission
Training Review Date
Feb. 26, 2014, since latest RMP submission
Maintenance Review Date
May 15, 2013, since latest RMP submission
Maintenance Inspection Date
Aug. 31, 2011, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Oct. 24, 2011
Management of Change Review Date
Dec. 11, 2013
Pre-startup Review Date
Dec. 11, 2013
Compliance Audit Date
Oct. 19, 2012
Compliance Audit Change Completion Date
May 1, 2013
Incident Investigation Date
Aug. 22, 2013
Incident Invest. Change Completion Date
Dec. 9, 2013
Participation Plan Review Date
Nov. 12, 2013
Hot Work Review Date
March 18, 2014
Contractor Safety Review Date
Oct. 27, 2009, since latest RMP submission
Contractor Safety Eval. Date
April 30, 2013, since latest RMP submission
Isobutylene, Other Chemical and Allied Products Merchant Wholesalers (42469)
Prevention Program ID:
1000042635
Safety Review Date
Feb. 7, 2014, since latest RMP submission
PHA Update Date
Oct. 4, 2011, since latest RMP submission
PHA Techniques
  • What if
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Equipment failure
  • Cooling loss
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Backup Pump
  • Grounding Equipment
  • Purge System
Mitigation Systems
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Nov. 7, 2013, since latest RMP submission
Training Review Date
Feb. 26, 2014, since latest RMP submission
Maintenance Review Date
May 15, 2013, since latest RMP submission
Maintenance Inspection Date
May 20, 2009, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
None
Management of Change Review Date
Dec. 11, 2013
Pre-startup Review Date
Dec. 11, 2013
Compliance Audit Date
Oct. 19, 2012
Compliance Audit Change Completion Date
May 1, 2013
Incident Investigation Date
Aug. 22, 2013
Incident Invest. Change Completion Date
Dec. 9, 2013
Participation Plan Review Date
Nov. 12, 2013
Hot Work Review Date
March 18, 2014
Contractor Safety Review Date
Oct. 27, 2009, since latest RMP submission
Contractor Safety Eval. Date
April 30, 2013, 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:
March 12, 2013
Local Response Agency:
Local Response Agency Phone:
(225) 346-1577
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
No
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

INTERCONTINENTAL TERMINALS COMPANY

ANCHORAGE CHEMICAL TERMINAL

EXECUTIVE SUMMARY



19556 LDEQ FACILITY ID NUMBER





ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES

Intercontinental Terminals Company's Anchorage Chemical Terminal (ACT), located in Port Allen, LA, modified its safety programs in 1991 by adopting a concept of structured safety management systems entitled, "Operations Integrity Management Systems (OIMS)." The Anchorage Chemical Terminal utilizes these management systems to assure proper design, operation, maintenance, inspection, work permits, change management, and emergency response in a proactive effort to minimize risk to the public, environment, and the plant.



DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES

The Anchorage Chemical Terminal employs 20 associates who live and work in the Baton Rouge, LA area. In business at the same location since 1977, the company is a quality bulk storage/distribution facility for LPG-like chemicals. Butadiene is shipped to companies around the United States, who in turn use the chemical to produce products such as tires, automotive parts, roofing materials, wire and cable coating, etc. Propylene, which is shipped to companies in Texas, is a key ingredient used to produce plastic and rubber products.



ACT is a storage and shipping/receiving facility. The chemicals typically stored or handled onsite on a day to day basis exceeding ARP threshold quantities include 1,3-Butadiene, Crude Butadiene, Chemical Grade Propylene, and Dilute Propylene. ACT occasionally handles the following chemicals onsite that exceed ARP threshold quantities: Isobutylene (2-Methylpropene); 1,3-Butadiene (Stabilized); ST-04 Bottoms; Mixed Butylenes; and Crude Isoprene (aka Dilute Isoprene or Isoprene Concentrate). Crude Butadiene, Dilute Propylene, 1,3- Butadiene (Stabilized), ST-04 Bottoms, Mixed Butylenes, and Crude Isoprene are flammable mixtures. Crude Butadiene contains four regulated subst
ances (1,3-Butadiene, Butane, Butylene, and 2-Methylpropene); Dilute Propylene contains three regulated substances (Butane, Propane, and Propylene); 1,3-Butadiene (Stabilized) contains four regulated substances (1,3-Butadiene, 2-butene, 1-butene, and Butane); ST-04 Bottoms contains two regulated substances (1,3-Butadiene and Propylene); Mixed Butylenes contains six regulated substances (Butane, 1-Butane, 2-Butane-cis, Isobutane, Isobutylene, and 2-Butene (E)); and Crude Isoprene contains three regulated substances (Isoprene, 1,3-Pentadiene and n-Pentane). Chemicals are received via ship, barge, tank car, tank truck or pipeline and transferred to commerce via ship, barge, tank car, tank truck or pipeline.



1,3-Butadiene, Crude Butadiene, Dilute Propylene, and Chemical Grade Propylene are stored in excess of threshold quantities and are therefore subject to the ARP Program. Isobutylene in quantities exceeding the threshold is occasionally off-loaded directly from ships to tank cars. 1,3-Butadiene (Stabilized); ST-04 Bottoms; Mixed Butylenes; and Crude Isoprene in quantities exceeding the threshold may be occasionally unloaded from tank cars into the Crude Butadiene storage unit (Sphere 697) and transferred out via pipeline as a Crude Butadiene mixture.



GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS

The following is a summary of the general Accident Prevention Program in place at the Anchorage Chemical Terminal. EPA's Program 3 prevention requirements were implemented because some processes at the plant meet Program 3 criteria and are also subject to the OSHA Process Safety Management (PSM) standard. In addition, Intercontinental Terminals Company has implemented Operations Integrity Management Systems (OIMS) at the Anchorage Chemical Terminal that includes the aspects of EPA's prevention program and this summary describes OIMS. Further, OIMS has been attested as equivalent to ISO 14001 as a valid management system to oversee the implementation of the ri
sk management activities.



EMPLOYEE PARTICIPATION

Intercontinental Terminals Company encourages associates to participate in all facets of process safety management and accident prevention. Examples of associate participation ranges from updating and compiling operating and maintenance procedures to participating as a member of a Process Hazard Analysis (PHA) team. Associates have access to all information generated from HAZOPs and Site Risk Assessments. In addition, the plant has a number of initiatives underway that address process safety and associate safety issues via the ACT Safety Committee which is comprised of site personnel and selected contractors.



PROCESS SAFETY INFORMATION

The Anchorage Chemical Terminal keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. The ACT Terminal Manager is responsible for maintaining up-to-date process safety information. A table summarizing the reference documents and their location is readily available as part of the OIMS documentation to help associates locate any necessary process safety information.



Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in Material Safety Data Sheets (MSDS). This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For specific process areas, the plant has identified operating envelopes, i.e., documented safety related limits for specific process parameters such as temperature, level, and compositions. The plant ensures that the process is maintained within these limits using computerized process controls and monitoring instruments, highly trained pe
rsonnel, and protective instrument systems (i.e., automated shutdown systems, alarm systems).

The plant also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, electrical rating of equipment, etc. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as form evaluating proposed process and facility changes to ensure that safety features in the process are not compromised.



PROCESS HAZARD ANALYSIS

The Anchorage Chemical Terminal has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.



The Anchorage Chemical Terminal primarily uses the Knowledge Based Hazard and Operability (HAZOP) study that is an adaptation by ExxonMobil Research and Engineering and ExxonMobil Chemical Americas of widely used industry methodologies to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The analyses are conducted using a team of people who have operating experience and engineering expertise on the process to be evaluated. This PHA team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary.



The PHA team findings are forwarded to local management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk evaluation done by the PHA team. This evaluation helps ensure that potential accident
scenarios assigned greater risk receive attention first. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. The resolution of each finding is documented and retained.



To ensure that the process controls and/or process hazards do not deviate significantly from the original design safety features, the Anchorage Chemical Terminal periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every five years for the life of the process. The results and findings from these updates are documented and retained. The team findings are forwarded to management for consideration and resolution of the findings is documented and retained.



OPERATING PROCEDURES AND SAFE WORK PRACTICES

The Anchorage Chemical Terminal maintains written procedures that address various modes of process operations, such as (1) startup, (2) shutdown, (3) normal, and (4) emergency operations. These procedures can be used as a reference by experienced operators and provide a consistent basis for training of new operators. The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change process.

The plant has identified operating envelopes, i.e., documented safety related limits for specific process parameters such as temperature, level, and compositions. This information, along with written operating procedures, is readily available to operators and for other personnel to use as necessary to safely perform their job tasks.

The Anchorage Chemical Terminal has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel; (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance; (3) a procedure for safe removal of hazardous materials before proces
s piping or equipment is opened; (4) a permit and procedure to control spark producing activities (i.e., hot work); and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to ensure that operations and maintenance activities are performed safely.



TRAINING

To complement the written procedures for process operations, the Anchorage Chemical Terminal has implemented a comprehensive training program for all associates involved in operating a process. New associates receive basic training in plant operations. After successfully completing this training, a new operator is paired with an experienced operator to learn process specific duties and tasks. After employees demonstrate (i.e., through tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operations personnel periodically receive refresher training to ensure that their skills and knowledge are maintained at an acceptable level. All of this training is documented for each operator.



CONTRACTORS

The Anchorage Chemical Terminal uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the plant has procedures in place to ensure that contractors (1) perform their work in a safe manner; (2) have the appropriate knowledge and skills; (3) are aware of the hazards in their workplace; (4) understand what they should do in the event of an emergency; (5) understand and follow site safety rules; and (6) inform plant personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) safety orientation; (2) information about safety and heath hazards; (3) emergency response plan requirements; and (4) saf
e work practices prior to their beginning work. In addition, the Anchorage Chemical Terminal evaluates contractor safety programs and performance during the selection of a contractor. Plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations.



MECHANICAL INTEGRITY

The Anchorage Chemical Terminal has well established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training; (2) developing written procedures; (3) performing inspections and tests; (4) correcting identified deficiencies; and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process equipment.

Maintenance personnel receive training on (1) an overview of the process; (2) safety and health hazards; (3) applicable maintenance procedures; (4) emergency response plans; and (5) applicable safe work practices to help ensure that they can perform their job in a safe manner. Written procedures help ensure that work is preformed in a consistent manner and provide a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits (i.e., adequate wall thickness for pressure vessels). If a deficiency is identified, associates will correct the deficiency before placing the equipment back into service (if possible) or a MOC team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment.

Another integral part of the Mechanical Integrity Program is quality assurance. The Anchorage Chemical Terminal incorporates quality assurance measures into equipment purchases and repairs. This helps ensure t
hat new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made.



HOT WORK

The Anchorage Chemical Terminal has a Work Permit System in place to protect personnel, site facilities, and the surrounding community. The purpose of the Work Permit System is to ensure that jobs are planned, equipment is prepared, personnel are informed to hazards and procedures, precautions are taken, and work is executed in a manner to protect safety, health, and the environment. The Work Permit System covers hot work and other categories of work such as opening equipment, excavation, lifting, and confined spaces.



MANAGEMENT OF CHANGE

The Anchorage Chemical Terminal has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training before the change is implemented.



INCIDENT INVESTIGATION

The Anchorage Chemical Terminal promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, gas release, major property damage, environmental loss or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident.

The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to plant m
anagement for resolution. Corrective actions are taken in response to the investigation team's findings and recommendations are tracked until they are complete. The resolution of each finding or recommendation is documented and the investigation results are reviewed with all associates (including contractors) who could be affected by the findings. Incident investigation reports are retained for at least five years so that the reports can be reviewed during future PHAs and PHA revalidations.



COMPLIANCE AUDITS

To help ensure that Safety, Health and Environmental (SHE) management systems are functioning properly, the Anchorage Chemical Terminal periodically conducts audits to determine whether the procedures and practices required by the OIMS are being implemented. Compliance audits are conducted semi-annually and external SHE audits are conducted at least every three years. The audit team develops findings that are forwarded to management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The resolution of each finding is documented, and the most recent audit reports are retained.



CHEMICAL SPECIFIC PREVENTION STEPS

The processes at the Anchorage Chemical Terminal have hazards that must be managed to ensure continued safe operation. Prevention activities in place at ACT help prevent potential accident scenarios that could be caused by (1) equipment failures and (2) human errors. In addition to the prevention activities, the plant has safety features on many units to help, (1) quickly detect a release, (2) contain/control a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in various processes:

Release Detection

1. Hydrocarbon detectors with alarms

Release Containment/Control

1. Process relief valves that discharge to a flare to capture and incinerate episodic releases

2. Valves to permit isolation of the process (manu
al or automated)

3. Automated shutdown systems for specific process parameters (i.e., high level, high temperature)

4. Curbing or diking to contain liquid releases

5. Redundant equipment and instrumentation (i.e., backup firewater pump)

6. Atmospheric relief devices

Release Mitigation

1. Fire suppression and extinguishing systems

2. Deluge system for specific equipment

3. Trained emergency response personnel

4. Personal protective equipment (i.e., protective clothing, self-contained breathing apparatus)

5. Blast resistant buildings to help protect control systems and personnel



FIVE YEAR ACCIDENT HISTORY

ACT has had one accidental released during the last five years, which meets the criteria for an accidental release per 40 CFR 68.42. On August 12, 2013, 1,3- Butadiene was released to the atmosphere from the vacuum breaker on Tank 1670 due to a blockage in the remote sensing tubing which prevented the necessary pressure to keep the vacuum breaker closed. The release started at approximately 1400 hours and ended at 1720 hours. The release event lasted approximately 200 minutes. It is estimated that 8,466 pounds of 1,3 Butadiene was released based on the tank inventory net loss calculation.



EMERGENCY RESPONSE PROGRAM INFORMATION

The Anchorage Chemical Terminal maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including proper first-aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post incident cleanup and decontamination requirements. In addition, the plant has procedures that
address maintenance, inspection, and testing of emergency response equipment, as well as instruction that address the use of emergency response equipment. Associates receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is updated when necessary based on modifications made to plant processes or facilities. The emergency response program changes are administered through the MOC process, which includes informing and/or training affected personnel in the changes.

The overall emergency response program for the Anchorage Chemical Terminal is coordinated with the West Baton Rouge Parish Local Emergency Planing Committee (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives.

The plant has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (i.e., Port Allen Fire Department and ExxonMobil Baton Rouge Chemical Plant Emergency Response Team). This provides a means of notifying the public of an incident as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, the plant conducts periodic emergency drills that involve the local response agencies.