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Formosa Plastics Corp., LA

Parent Companies:
Formosa Plastics Corp., USA
EPA Facility ID:
100000132812
Other ID:
70805FRMSPGULFS
Facility DUNS:
106238108
Parent Company DUNS:
39944004

Location:

Address:
End of GSU Road
Baton Rouge, LA 70805
County:
EAST BATON ROUGE
Lat / Long:
30.502, -91.186 (Get map)
Method:
GPS - Unspecified
Description:
Plant Entrance (General)
Horizonal accuracy:
8.7 m
Horizontal reference datum:
World Geodetic System of 1984
Source map scale:

Owner/Operator:

Name:
Formosa Plastics Corp., LA
Phone:
(225) 356-3341
Address:
PO Box 271
Baton Rouge, LA 70821 -0271
Foreign Address:

Person responsible for RMP implementation:

Name:
Paul Heurtevant
Title:
Plant Manager
Email:

Emergency contact:

Name:
Rusty Daigle
Title:
Safety Supervisor
Phone:
(225) 413-6764
24-hour phone:
(225) 356-8621
Ext or PIN:

Other contacts:

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

Safety:

Local Emergency Planning Committee:
East Baton Rouge LEPC
Full-Time Equivalent Employees:
232
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
1004-V2
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Feb. 19, 2015
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

VCM
RMP ID:
1000077068
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Chloroform [Methane, trichloro-]
67-66-3
53,000
No
Vinyl chloride [Ethene, chloro-]
75-01-4
19,000,000
No
Hydrogen chloride (anhydrous) [Hydrochloric acid]
7647-01-0
530,000
No
Propylene [1-Propene]
115-07-1
73,000
No
Chlorine
7782-50-5
620,000
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
PVC
RMP ID:
1000077069
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
1,600,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
Dec. 21, 2016
Type:
Resubmission
Reason:
Revised PHA / Hazard Review due to process change (40 CFR 68.190(b)(5))
Registered:
Yes
RMP ID:
1000061562

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 VCM)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Rural
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 VCM)
CBI claimed:
No
Percent weight:
79.0
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:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in VCM)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Rural
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 VCM)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Rural
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers

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 VCM)
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 VCM)
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

VCM, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000064825
Safety Review Date
Dec. 13, 2016, since latest RMP submission
PHA Update Date
Aug. 1, 2016, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • None
Process Controls
  • Vents
  • Relief Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Blast Walls
  • Deluge System
  • Neutralization
Monitoring Systems
  • Process Area
Changes since PHA
  • Reduced Inventory
  • Increased Inventory
  • Process Parameters
  • Process Controls
  • Process Detection
  • Mitigation Systems
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
Nov. 29, 2016, since latest RMP submission
Training Review Date
Nov. 3, 2016, since latest RMP submission
Maintenance Review Date
July 19, 2016, since latest RMP submission
Maintenance Inspection Date
Dec. 12, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 15, 2016
Management of Change Review Date
Nov. 29, 2016
Pre-startup Review Date
Dec. 15, 2016
Compliance Audit Date
Nov. 13, 2014
Compliance Audit Change Completion Date
Nov. 13, 2017
Incident Investigation Date
Sept. 27, 2016
Incident Invest. Change Completion Date
Dec. 15, 2016
Participation Plan Review Date
Sept. 28, 2005
Hot Work Review Date
Oct. 1, 2015
Contractor Safety Review Date
March 14, 2016, since latest RMP submission
Contractor Safety Eval. Date
Nov. 29, 2016, since latest RMP submission
PVC, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000064826
Safety Review Date
Nov. 4, 2016, since latest RMP submission
PHA Update Date
June 22, 2016, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • None
Process Controls
  • Vents
  • Relief Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Excess Flow Device
Mitigation Systems
  • Sprinkler System
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • Reduced Inventory
  • Process Parameters
  • Process Detection
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
April 27, 2016, since latest RMP submission
Training Review Date
Nov. 3, 2016, since latest RMP submission
Maintenance Review Date
July 19, 2016, since latest RMP submission
Maintenance Inspection Date
Dec. 14, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 8, 2016
Management of Change Review Date
Nov. 29, 2016
Pre-startup Review Date
Oct. 12, 2016
Compliance Audit Date
Nov. 13, 2014
Compliance Audit Change Completion Date
Nov. 13, 2017
Incident Investigation Date
Jan. 26, 2016
Incident Invest. Change Completion Date
Feb. 11, 2016
Participation Plan Review Date
Sept. 28, 2005
Hot Work Review Date
Oct. 1, 2015
Contractor Safety Review Date
March 14, 2016, since latest RMP submission
Contractor Safety Eval. Date
Nov. 29, 2016, 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:
Nov. 8, 2016
Local Response Agency:
Local Response Agency Phone:
(225) 389-2100
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

Facility Description:



Formosa Plastics, LA is a producer of basic industrial chemicals and materials. Chlorine, ethylene dichloride, anhydrous hydrogen chloride, and vinyl chloride are the major materials used and/or produced at the facility. The primary commodity produced at the facility is polyvinyl chloride resin. Polyvinyl chloride is used to manufacture food wrap, children's toys,medical devices, garden hoses, piping, vinyl siding, floor tiles, roofing shingles, electrical wiring insulation, furniture, clothing articles, automotive parts, etc. The facility is certified to ISO quality and environmental management standards and employs approximately 232 employees and approximately 89 full-time contractors.



The Baton Rouge plant includes two operating units which are covered under the Risk Management regulation. These are Polyvinyl Chloride (PVC) and Vinyl Chloride Monomer (VCM). A description of the covered processes is included in this summary.



RMP-Covered Materials:



The facility has five RMP-covered materials on site exceeding the RMP-specified regulatory threshold quantities. These materials are chlorine, anhydrous hydrogen chloride, vinyl chloride, propylene, and chloroform.



Chlorine is a greenish-yellow gas; it's heavier than air; it has the strong odor of household bleach; it is corrosive. Chlorine is used as a drinking water disinfectant; making household bleach; making plastics and other chemicals. Formosa uses this material in the manufacture of vinyl chloride.



Vinyl Chloride monomer is a colorless gas; it is heavier than air; it has a sweet odor; it is flammable. Formosa manufactures and uses this material in the production of polyvinyl chloride.



Anhydrous Hydrogen Chloride is a colorless gas; it is heavier than air; it has an irritating, pungent odor; it is corrosive. It is used in food processing and brewing operations, metal treatment for electroplating, rubber manufacture, metal ore extraction and reduction, leather manufacture,
plastic and resin production, etc. Formosa produces this material, maintained as a pressurized liquid, in the vinyl chloride manufacturing process.



Propylene is a colorless gas; it is heavier than air; it is flammable; it is virtually odorless. Propylene is used as a non-CFC refrigerant and in the manufacture of plastics, antifreezes, and food additives. Formosa uses this material as a refrigerant.



Chloroform is produced as a byproduct/impurity in the VCM manufacturing process.



Accidental Release Prevention Policy:



The facility's commitment to the safety of its employees, the community and the environment is exemplified by their EHS policy statement. The facility recognizes that it operates under privilege and acknowledges that protection and safety of the environment, community, and employees are integral to its continued success as an organization. As such, a holistic approach consisting of sound design, engineering and administrative measures is utilized in preventing accidental releases.



Accidental Release Prevention Programs and Measures:



In the prevention of accidental releases, the facility employs numerous engineering and administrative controls to ensure the chance of a hazardous material release is minimized. Engineering controls utilized include, but are not limited to, conservative process design safety factors, check valves that limit/prevent releases in the event of reverse excess flow, pressure and level alarms on primary storage vessels, redundant level detection for overfill protection, relief valves to prevent vessel overpressurization, insulated vessels to prevent solar overpressurization, shut-down systems, automatic/manual valves to isolate/limit releases, and redundant mechanical seals to prevent leaks.



Administrative controls utilized include certification to ISO quality and environmental management standards, Process Safety Management programs, Safety Permitting programs, Hot Work Procedures, Hazardous Energy Control pro
grams, regular equipment inspections and maintenance, Preventive Maintenance programs, Standard Operating and Troubleshooting procedures, training programs, standards for overfill protection, VOC emissions monitoring program, and more.



Emergency Response Policy:



It is the policy of the facility to prevent, minimize, control, and mitigate accidental releases. The facility recognizes that quick response to an incident is instrumental in assuring protection of the environment, community, and employees. To assist with this, the facility utilizes numerous engineering and administrative controls for early detection, communication, and response to incidents.



Emergency Response Programs and Measures:



The facility employs numerous engineering and administrative controls to ensure the chance of a hazardous material release is minimized. Engineering controls which aid in the identification and/or communication of such incidents including atmospheric leak detection systems, portable atmospheric detection equipment, facility alarm and siren systems, public address systems, two-way radios, phones, and computers.



Administrative controls include an Emergency Response plan, Spill Prevention plan, Emergency Notification procedures, and Emergency Shutdown procedures. An exercise testing the response plan and the communication procedures is conducted annually and a critique is held following the event.



The site has an emergency response team which consists of employees who have been trained in the areas of fire fighting, hazardous materials response, rescue, and injury treatment. Larger emergency response activities are coordinated under the Shift Safety Coordinator.



Emergency preplanning and response coordination with external agencies and responders is accomplished via membership and/or participation in organizations such as the Baton Rouge Area Mutual Aid Society and the North Baton Rouge Chemical Industry Task Force.



The facility is part of an emergency hotl
ine network, through which a system is in place to notify our immediate industrial neighbors and emergency response agencies with a single notification. Upon notification, the agencies can activate the community alert systems as necessary. The systems are tested on a regular basis.



Fixed fire suppression systems consisting of fire water pumps, fire hydrants and hydrant/monitor assemblies, water deluge systems, and foam blanket systems help protect the facility in the event of fire. Additionally, there are fire hose houses which contain fire hose, fire water nozzles, and various wrenches and adapters that provide mobile fire fighting capability. The site also has a fire truck and foam trailer which can be utilized by the emergency response team members. Additional fire water capacity can be accessed through a neighboring industry's fire water system if required.



For hazardous materials incidents, a supply of emergency equipment is kept on-hand, including protective clothing, fresh air systems, capping kits, absorbent pads, leak dams, etc. For incidents requiring external assistance, manpower is provided by the local fire department. The facility can also use the services of contract leak mitigation services as required.



Five Year Accident History:



The facility has had no releases in the last 5 years which require RMP reporting within the criteria specified by the Risk Management rule.



Planned Changes to Improve Safety:



The facility operates under a credo of continuous improvement and planned changes include such things as program enhancements, procedural evaluations, and other items as identified through various internal mechanisms, as warranted.



Facility RMP-Covered Process Unit Descriptions:



Vinyl Chloride Monomer (VCM) Unit Process Description



The VCM Unit produces VCM from 1,2-dichloroethane (EDC) and chlorine. EDC is fed to furnaces where it is converted to VCM and hydrochloric acid (HCI). A series of columns, heat exchangers, and vess
els, interconnected by piping and ancillary transfer equipment, are used to purify the VCM to required specifications for use as a produced feedstock. Several by-products, such as HCl and unreacted EDC, are recycled for reuse in the process, with a small portion of the HCL being diverted for sale as a commodity. Product VCM is stored for subsequent transfer to the PVC Unit or may otherwise be shipped. Feedstocks and finished products are stored in tanks. Raw materials may be received via barge, truck, and rail. Rail cars and tank trucks are used to deliver finished products to customers from the facility.



The VCM Unit also maintains necessary utilities equipment to aid in process operations, such as cooling towers and control and recovery devices. Incinerators at the FPC Baton Rouge Facility receive vent streams from reactors, columns, and tanks as well as vents from decontamination of equipment in the VCM Unit and other parts of the facility. As part of the incinerator systems, there are also hydrochloric acid (HCI) absorber towers and caustic scrubber columns used to recover and remove HCI and chlorine.



Polyvinyl Chloride (PVC) Unit Process Description



The PVC Unit produces PVC using suspension polymerization. The plant currently produces several grades of suspension PVC.



Polymerization occurs in batch reactors to convert the VCM charged in each batch to PVC in a water slurry. The unreacted VCM gas is recovered from the reactors for recycle. The PVC slurry is pumped to blowdown tanks, where additional unreacted VCM flashes overhead to be reclaimed by condensation. The blowdown tanks also serve as holding tanks for continuous feed of the slurry stripping columns Residual VCM is steam stripped from the PVC slurry in slurry stripping columns. Residual VCM is recovered from the equipment upstream of and including the slurry stripper. Condensed VCM is recycled to the process.

The stripped PVC slurry is then pumped through heat exchangers to dryer feed hol
ding tanks and centrifuges, where the slurry is dewatered and the PVC wet cake is produced. Water is pumped to the biotreatment plant. PVC wet cake is dried in either cyclone or fluidized bed dryers. Air vented from the cyclone dryers is passed through a water scrubber and PVC resin is screened by sieves and pneumatically conveyed to storage silos. Each silo vent is controlled with a bag or cartridge filter dust collector. Rail cars and trucks are used to deliver finished products to customers from the facility.



The PVC Unit also maintains necessary utilities equipment to aid in process operations, such as cooling towers and recovery devices.