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Kemira Chemicals, Inc.- Shreveport Plant

Parent Companies:
Kemira Chemicals, Inc.
EPA Facility ID:
100000137808
Other ID:
Facility DUNS:
0
Parent Company DUNS:
33870585

Location:

Address:
5677 North Industry Road
Shreveport, LA 71107
County:
CADDO
Lat / Long:
32.553, -93.854 (Get map)
Method:
Interpolation - Map
Description:
Other
Horizonal accuracy:
1 m
Horizontal reference datum:
North American Datum of 1927
Source map scale:
9899

Owner/Operator:

Name:
Kemira Chemicals, Inc.
Phone:
(770) 436-1542
Address:
245 Townpark Drive, Suite 200
Kennesaw, GA 30144
Foreign Address:

Person responsible for RMP implementation:

Name:
R. V. Hinton
Title:
Director HS&E

Emergency contact:

Name:
R. v. Hinton
Title:
Director HS&E
Phone:
(678) 819-4517
24-hour phone:
(678) 776-6041
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(770) 436-1542
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Full-Time Equivalent Employees:
5
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. 14, 2001
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Epichlorohydrin Process
RMP ID:
46658
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Epichlorohydrin [Oxirane, (chloromethyl)-]
106-89-8
58,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
June 16, 2004
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
No
RMP ID:
32268

Deregistration:

Date:
Effective Date:
Reason:
Source terminated operations
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 Epichlorohydrin Process)
CBI claimed:
No
Percent weight:
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • Dikes
not considered:
  • 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 Epichlorohydrin Process)
CBI claimed:
No
Percent weight:
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
1.50
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Deluge systems
not considered:
  • Sprinkler systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown

4. Flammables: Worst-case

None

5. Flammables: Alternative release

None

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

Epichlorohydrin Process, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
26666
Safety Review Date
May 10, 2000, since latest RMP submission
PHA Update Date
May 10, 2000, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Polymerization
  • Overpressurization
  • Overfilling
  • Equipment failure
  • Cooling loss
Process Controls
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Grounding Equipment
  • Rupture Disks
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • Reduced Inventory
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
Procedure Review Date
Sept. 11, 2002, since latest RMP submission
Training Review Date
Feb. 12, 2003, since latest RMP submission
Maintenance Review Date
June 14, 2004, since latest RMP submission
Maintenance Inspection Date
Dec. 15, 2002, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Sept. 28, 1999
Management of Change Review Date
June 4, 2004
Pre-startup Review Date
Nov. 15, 1988
Compliance Audit Date
Sept. 30, 2003
Compliance Audit Change Completion Date
Dec. 31, 2003
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Nov. 27, 2000
Hot Work Review Date
May 15, 2003
Contractor Safety Review Date
March 24, 2003, since latest RMP submission
Contractor Safety Eval. Date
Feb. 7, 2003, 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:
Feb. 24, 2003
Local Response Agency:
Local Response Agency Phone:
(318) 675-2144
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

24912 LDEQ Facility ID Number

ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE
POLICIES

The Kemira Chemicals, Inc - Shreveport Plant has a long-
standing commitment to worker and public safety and to the
protection of the environment. We are committed to
operating and maintaining all of our processes in a safe and
responsible manner, as demonstrated by the resources we
invest to prevent accidents. As a member of the American
Chemistry Council (ACC), we adhere to the principles of
Responsible Care and are working towards RC 14001
certification. In addition to ensuring that our employees
have the best possible training in the operation of our
processes, we demand that safety be the first priority in
the design, installation, operation and maintenance of our
processes. We have implemented maintenance and inspection
programs that ensure site integrity. Our policy is to
implement reasonable controls to prevent foreseeable
releases of regulated substances. Examples of controls to
prevent releases include (1) installation of pressure relief
valves to prevent rupture of vessels due to
overpressurization, (2) routine visual inspection and
thickness checks to ensure vessels and piping are in good
condition, (3) using materials of construction that are
compatible with the process chemistry, (4) vessel pressure
and temperature are continuously monitored and (5) use of
carbon scrubbers to remove small amounts of emissions.

Mitigation measures that have been included in our design
include installation of isolation valves, fire suppression
systems in areas where flammable chemicals are present and
fire fighting equipment in all process areas, a fully
implemented emergency response plan, appropriate PPE and an
alarm system for early notification of a release. Since
this is a small site, our employees have only been trained
to handle fires in the incipient stages and small spills.
We would rely on the local fire department and hazmat team
for major spills requiring sui
t-up.

The Shreveport Plant has also conducted a Security
Vulnerability Analysis. The site is completely fenced and
the gate kept closed except for controlled entry.

STATIONARY SOURCE AND REGULATED SUBSTANCES

The Kemira Chemicals, Inc. - Shreveport Plant is primarily
involved in manufacturing polymers for the paper industry.
As a part of the manufacturing process, we use one substance
that is covered by the Risk Management Program (RMP) rule,
40 CFR 68. This process is subject to Program Level 3. The
plant itself is located on 5.32 acres in an Industrial Park
with few neighbors. The plant also uses a combination of
good design practices, an accidental release prevention
program, and an emergency response program to ensure the
safety of our employees, the public and the environment. We
are committed to operating our facility in a safe and
responsible manner.


KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS

EPA's RMP rule (40 CFR 68) requires that companies provide
information about two types of offsite consequence analysis
scenarios: worst-case scenarios and alternative release
scenarios. There are strict requirements for choosing and
modeling worst-case release scenarios; as a result, these
scenarios are often exceedingly conservative and represent a
situation that is unlikely to occur. The purpose of the
alternative release scenarios is to provide emergency
planners with more information about the chemicals we handle
and their relative hazards. The alternative release
scenarios are more realistic than the worst case scenarios
and could possibly occur.

GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-
SPECIFIC PREVENTION STEPS

We take a systematic, proactive approach to preventing
accidental releases of hazardous chemicals. Our management
system addresses each of the key features of a successful
prevention program, as described below:

PROCESS SAFETY INFORMATION

The Kemira Chemicals, Inc. - Shreveport Plant maintains a
variety of technical
documents that describe the chemicals
and processes at the facility. These documents are kept up
to date and are available to all employees and address
important process parameters such as (1) operating limits
for the equipment, (2) design basis and configuration of the
equipment, and (3) physical properties and hazards of the
chemicals used in our processes.

Chemical information is usually documented in Material
Safety Data Sheets (MSDSs). MSDSs contain information
concerning both the physical properties and the hazards
associated with each chemical. This information typically
includes (1) toxicity information, (2) physical data, (3)
reactivity and corrosivity data, (4) thermal and chemical
stability data and (5) hazards of mixing substances
together. MSDSs are available to all employees as well as
the emergency responders in our community. MSDSs for all
Shreveport chemicals are maintained on site.

Important process parameters are also documented and
maintained. Engineering design documents may include (1)
operating limits, (2) block flow or simplified process flow
diagrams, (3) process chemistry, (4) maximum intended
inventories, (5) design basis and configuration, (6) piping
and instrumentation diagrams and (7) other information that
is important for understanding the design intent, operating
limits and hazards of each process.

PROCESS HAZARD ANALYSES

The Kemira Chemicals, Inc. - Shreveport Plant has a
comprehensive program for ensuring that the hazards
associated with our processes are identified and controlled.
Each process is examined in detail to ensure that all
hazards are identified and that appropriate controls are in
place to manage those hazards.

A Hazard and Operability Analysis (HAZOP) is typically used
for our Process Hazard Analysis (PHA). A team comprising
personnel with engineering, operations, environmental and
maintenance experience systematically examines each hazard
in each section of the process and identifies potential
causes
and a range of possible consequences. The team then
compares the hazard to the existing set of prevention and
mitigation measures designed to contain that hazard, making
further recommendations when deemed necessary. These
recommendations are resolved by management and tracked until
they are implemented.

We update and revalidate each Process Hazard Analysis every
five years or whenever a significant or reportable change
occurs. The results and findings from these revalidation
studies are documented and retained, and recommendations are
tracked by management until completed.

OPERATING PROCEDURES

Our engineers, operators and supervisors work together to
develop and maintain operating procedures that ensure the
safe operation of our facility. These procedures cover all
modes of operation, such as (1) unit startup, (2) normal
operations, (3) temporary operations, (4) emergency
shutdown, (5) normal shutdown and (6) initial startup of a
new or improved process. Operating procedures are used as a
reference by experienced employees and provide a consistent
basis for training new employees. In addition to describing
the steps for safely conducting operations, the procedures
also contain valuable information about safe upper and lower
limits, consequences of deviations and applicable safety and
health information. Operating procedures are annually
certified as accurate to ensure that they are updated
following process changes.

The Shreveport Plant also operates using a batchsheet
system. Batchsheets are the detailed operating procedures
for making a batch of product. The batchsheets include
process deviation codes describing the actions to take under
various conditions (e.g., high temperature, high pressure,
loss of cooling, etc) that may be encountered while
manufacturing batches using hazardous chemicals.

TRAINING

The Kemira Chemicals, Inc. - Shreveport Plant trains workers
to safely and effectively perform their tasks. Employees
who are new to a
process are given basic training that
includes (1) a general overview of the process, (2) the
properties of the substances used in the process and their
associated hazards and (3) a detailed review of the
operating procedures for that process. Once they have
demonstrated their understanding of this initial training,
they are paired with an experienced operator to learn their
specific job functions and tasks. After they demonstrate
their competence in performing these tasks, they are allowed
to work independently.

Through oral reviews, written tests and on-the-job
demonstration, we ensure that our employees understand the
training given to them. The frequency of refresher training
is decided, in part, by our employees, but is performed at
least every three years. All training given to an employee
is documented along with the means used to verify that the
training is understood.

MECHANICAL INTEGRITY

The Shreveport Plant maintains the mechanical integrity of
the equipment to prevent failures that could endanger
workers, the public or the environment. Our inspection and
testing program helps identify equipment damage or
deterioration before the equipment fails. When a deficiency
is found, maintenance personnel will correct the problem and
try to identify the root cause so that future problems are
avoided. Our quality assurance system ensures that new or
replacement equipment meets the strict design standards
required for service in our facility. The mechanical
integrity system includes (1) inspection and testing
procedures, (2) replacement equipment specifications, (3)
procedures for safe work practices, (4) maintenance
personnel training and (5) required documentation.

MANAGEMENT OF CHANGE (MOC)

We review any changes to our processes to determine if new
hazards are introduced or existing prevention measures are
threatened. Except for replacements-in-kind (e.g.,
replacing a valve with an identical valve), all changes are
subjected to a hazard ana
lysis to ensure that (1) new
hazards are not inadvertently introduced into the system,
(2) safety consequences resulting from the change are
addressed, (3) operators in the process are notified of the
change and made aware of possible repercussions and (4) all
training material, process safety information and operating
procedures are updated. The MOC system applies to changes
in the chemicals used, process equipment, technology,
procedures and other facility changes.

PRE-STARTUP REVIEW

Whenever a change occurs that requires updating the process
safety information, the Shreveport Plant performs a pre-
start-up safety review. This review ensures that safety
features, procedures, personnel and the equipment are
prepared for service before the process is restarted. A pre-
startup safety review will generally include field
verification of new construction and also serves a quality
assurance function by verifying that accident prevention
measures are implemented correctly. Generally, a pre-
startup review will ensure that (1) construction and
equipment are consistent with design standards, (2) adequate
operating, safety and maintenance procedures are in place,
(3) training for all affected employees is complete and (4)
a Process Hazard Analysis (PHA) has been performed, if
necessary.

INCIDENT INVESTIGATION

The Kemira Chemicals, Inc. - Shreveport Plant trains its
employees to promptly investigate each incident that
resulted in, or could have resulted in, serious injury to
employees, the public or the environment. Incident
investigations are designed to determine the facts, identify
root causes and provide recommendations for ensuring that
the incident does not recur. Corrective actions resulting
from an incident investigation are tracked until they are
resolved.

Incident investigations are conducted in accordance with..

EMPLOYEE PARTICIPATION

The Shreveport Plant encourages employees to be involved in
every aspect of process safety management an
d incident
investigation. Employees are routinely asked to participate
in process hazard analyses, incident investigations,
management of change hazard analyses and all other aspects
of the prevention program. Employees have access to all
information developed as part of the prevention program and
are specifically informed of any changes that occur in their
process areas. The various ways employees are involved in
the prevention program are documented in a written plan.

SAFE WORK PRACTICES

The Kemira Chemicals, Inc.- Shreveport Plant has established
safe work practices that ensure the safety of our employees.
Examples of these procedures include (1) a hot work permit
that is designed to control spark or flame-producing
activities, (2) a permit and procedure to control confined
space entry, and (3) a lockout/tagout procedure for
isolating energy sources during maintenance. These
procedures and permits ensure that operations and
maintenance activities are performed safely.

CONTRACTORS

The Shreveport Plant uses contractors for various activities
such as maintenance and construction. All contractors are
evaluated to ensure that they are well trained and are able
to perform their job function in a safe manner. A
contractor's safety record and performance are reviewed as
part of the selection process.

Once a contractor is selected, the plant provides training
and procedures to ensure that contractor employees (1)
perform their work in a safe manner, (2) are aware of the
hazards associated with the area in which they will be
working, (3) understand the emergency response procedures
and (4) report any hazards they find during their work. Our
personnel periodically monitor contractor activities to
ensure they are performing their work in a safe manner.

COMPLIANCE AUDITS

A compliance audit is performed periodically to help ensure
that the prevention program activities at our facility are
adequate and that safety issues are addressed effectively.
A
udits are performed by a team that is knowledgeable in our
processes, but is independent of our facility to ensure a
thorough and complete evaluation. The audit team
systematically evaluates each aspect of the prevention
program, ensuring both compliance with the RMP rule and
effective hazard prevention. The results of the audits are
documented and recommendations are tracked until they are
resolved. Compliance audits are conducted at least every
three years.

CHEMICAL-SPECIFIC PREVENTION STEPS

The prevention program described previously ensures the safe
operation of our facility by providing our employees with a
system they can use to safely perform their job functions.
This management system helps prevent hazards associated with
equipment failures and human error. In addition to the
prevention program, the Shreveport Plant has safety features
built into the design of the facility that help to ensure
safe process operation for our employees, the public and the
environment. These features may contain or control a
release, detect a release or reduce the consequences of a
release. They may also prevent a release by providing
strict design standards for process equipment. The
following types of safety features are used in various
processes in our facility:

Release Detection

1 Procedures that require a Shreveport Plant employee be
present during loading and unloading operations

Release Containment and Control

2 Valves to permit isolation of the process
3 Automated shutdown systems for some process parameters
(e.g., high level, high pressure)
4 Manual shutdown systems located in the control room
5 Diked areas designed to contain a release
6 Pressure relief valves and rupture disks that discharge
safely to the atmosphere

Release Mitigation

1 Fire suppression equipment
2 Trained emergency response personnel
3 Personal Protective Equipment (e.g., protective
clothing, self-contained breathing appa
ratus)
4 Spill clean-up equipment

FIVE YEAR ACCIDENT HISTORY

Our five-year accident history shows that the Kemira
Chemicals, Inc.- Shreveport Plant has had no qualifying
accidental releases of epichlorohydrin.

EMERGENCY RESPONSE PROGRAM

The Shreveport Plant relies on our community emergency
responders (the fire department ) to mitigate releases from
our facility and to notify the community. However, we
maintain procedures that address many of the other aspects
of an emergency response, such as proper first-aid and other
medical procedures and the use of personal protective
equipment.

The Shreveport Plant's emergency response procedures are
coordinated with local emergency responders. The local
responders are trained in the hazards of the substances at
the plant and communications channels are kept open 24-hours
per day. This coordination and communication ensure that
the public is quickly notified, if necessary, and that
action is promptly taken to minimize the consequences of a
release.

PLANNED CHANGES TO IMPROVE SAFETY

The Kemira Chemicals, Inc.- Shreveport Plant continuously
strives to improve the safety of our processes. Suggestions
for improving safety are regularly addressed through process
hazard analyses, management of change procedures, incident
investigations and employee suggestions.
24912 LDEQ Facility ID Number



ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE

POLICIES



The Kemira Chemicals, Inc - Shreveport Plant has a long-

standing commitment to worker and public safety and to the

protection of the environment. We are committed to

operating and maintaining all of our processes in a safe and

responsible manner, as demonstrated by the resources we

invest to prevent accidents. As a member of the American

Chemistry Council (ACC), we adhere to the principles of

Responsible Care and are working towards RC 14001

certification. In addition to ensuring that our employees

have the best possible training in the operation of
our

processes, we demand that safety be the first priority in

the design, installation, operation and maintenance of our

processes. We have implemented maintenance and inspection

programs that ensure site integrity. Our policy is to

implement reasonable controls to prevent foreseeable

releases of regulated substances. Examples of controls to

prevent releases include (1) installation of pressure relief

valves to prevent rupture of vessels due to

overpressurization, (2) routine visual inspection and

thickness checks to ensure vessels and piping are in good

condition, (3) using materials of construction that are

compatible with the process chemistry, (4) vessel pressure

and temperature are continuously monitored and (5) use of

carbon scrubbers to remove small amounts of emissions.



Mitigation measures that have been included in our design

include installation of isolation valves, fire suppression

systems in areas where flammable chemicals are present and

fire fighting equipment in all process areas, a fully

implemented emergency response plan, appropriate PPE and an

alarm system for early notification of a release. Since

this is a small site, our employees have only been trained

to handle fires in the incipient stages and small spills.

We would rely on the local fire department and hazmat team

for major spills requiring suit-up.



The Shreveport Plant has also conducted a Security

Vulnerability Analysis. The site is completely fenced and

the gate kept closed except for controlled entry.



STATIONARY SOURCE AND REGULATED SUBSTANCES



The Kemira Chemicals, Inc. - Shreveport Plant is primarily

involved in manufacturing polymers for the paper industry.

As a part of the manufacturing process, we use one substance

that is covered by the Risk Management Program (RMP) rule,

40 CFR 68. This process is subject to Program Level 3. The

plant itself is located on 5.32 acres in an Industrial Park

with few neighbors. The plant also uses a c
ombination of

good design practices, an accidental release prevention

program, and an emergency response program to ensure the

safety of our employees, the public and the environment. We

are committed to operating our facility in a safe and

responsible manner.





KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS



EPA's RMP rule (40 CFR 68) requires that companies provide

information about two types of offsite consequence analysis

scenarios: worst-case scenarios and alternative release

scenarios. There are strict requirements for choosing and

modeling worst-case release scenarios; as a result, these

scenarios are often exceedingly conservative and represent a

situation that is unlikely to occur. The purpose of the

alternative release scenarios is to provide emergency

planners with more information about the chemicals we handle

and their relative hazards. The alternative release

scenarios are more realistic than the worst case scenarios

and could possibly occur.



GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-

SPECIFIC PREVENTION STEPS



We take a systematic, proactive approach to preventing

accidental releases of hazardous chemicals. Our management

system addresses each of the key features of a successful

prevention program, as described below:



PROCESS SAFETY INFORMATION



The Kemira Chemicals, Inc. - Shreveport Plant maintains a

variety of technical documents that describe the chemicals

and processes at the facility. These documents are kept up

to date and are available to all employees and address

important process parameters such as (1) operating limits

for the equipment, (2) design basis and configuration of the

equipment, and (3) physical properties and hazards of the

chemicals used in our processes.



Chemical information is usually documented in Material

Safety Data Sheets (MSDSs). MSDSs contain information

concerning both the physical properties and the hazards

associated with each chemical. This inf
ormation typically

includes (1) toxicity information, (2) physical data, (3)

reactivity and corrosivity data, (4) thermal and chemical

stability data and (5) hazards of mixing substances

together. MSDSs are available to all employees as well as

the emergency responders in our community. MSDSs for all

Shreveport chemicals are maintained on site.



Important process parameters are also documented and

maintained. Engineering design documents may include (1)

operating limits, (2) block flow or simplified process flow

diagrams, (3) process chemistry, (4) maximum intended

inventories, (5) design basis and configuration, (6) piping

and instrumentation diagrams and (7) other information that

is important for understanding the design intent, operating

limits and hazards of each process.



PROCESS HAZARD ANALYSES



The Kemira Chemicals, Inc. - Shreveport Plant has a

comprehensive program for ensuring that the hazards

associated with our processes are identified and controlled.

Each process is examined in detail to ensure that all

hazards are identified and that appropriate controls are in

place to manage those hazards.



A Hazard and Operability Analysis (HAZOP) is typically used

for our Process Hazard Analysis (PHA). A team comprising

personnel with engineering, operations, environmental and

maintenance experience systematically examines each hazard

in each section of the process and identifies potential

causes and a range of possible consequences. The team then

compares the hazard to the existing set of prevention and

mitigation measures designed to contain that hazard, making

further recommendations when deemed necessary. These

recommendations are resolved by management and tracked until

they are implemented.



We update and revalidate each Process Hazard Analysis every

five years or whenever a significant or reportable change

occurs. The results and findings from these revalidation

studies are documented and retained, and re
commendations are

tracked by management until completed.



OPERATING PROCEDURES



Our engineers, operators and supervisors work together to

develop and maintain operating procedures that ensure the

safe operation of our facility. These procedures cover all

modes of operation, such as (1) unit startup, (2) normal

operations, (3) temporary operations, (4) emergency

shutdown, (5) normal shutdown and (6) initial startup of a

new or improved process. Operating procedures are used as a

reference by experienced employees and provide a consistent

basis for training new employees. In addition to describing

the steps for safely conducting operations, the procedures

also contain valuable information about safe upper and lower

limits, consequences of deviations and applicable safety and

health information. Operating procedures are annually

certified as accurate to ensure that they are updated

following process changes.



The Shreveport Plant also operates using a batchsheet

system. Batchsheets are the detailed operating procedures

for making a batch of product. The batchsheets include

process deviation codes describing the actions to take under

various conditions (e.g., high temperature, high pressure,

loss of cooling, etc) that may be encountered while

manufacturing batches using hazardous chemicals.



TRAINING



The Kemira Chemicals, Inc. - Shreveport Plant trains workers

to safely and effectively perform their tasks. Employees

who are new to a process are given basic training that

includes (1) a general overview of the process, (2) the

properties of the substances used in the process and their

associated hazards and (3) a detailed review of the

operating procedures for that process. Once they have

demonstrated their understanding of this initial training,

they are paired with an experienced operator to learn their

specific job functions and tasks. After they demonstrate

their competence in performing these tasks, they ar
e allowed

to work independently.



Through oral reviews, written tests and on-the-job

demonstration, we ensure that our employees understand the

training given to them. The frequency of refresher training

is decided, in part, by our employees, but is performed at

least every three years. All training given to an employee

is documented along with the means used to verify that the

training is understood.



MECHANICAL INTEGRITY



The Shreveport Plant maintains the mechanical integrity of

the equipment to prevent failures that could endanger

workers, the public or the environment. Our inspection and

testing program helps identify equipment damage or

deterioration before the equipment fails. When a deficiency

is found, maintenance personnel will correct the problem and

try to identify the root cause so that future problems are

avoided. Our quality assurance system ensures that new or

replacement equipment meets the strict design standards

required for service in our facility. The mechanical

integrity system includes (1) inspection and testing

procedures, (2) replacement equipment specifications, (3)

procedures for safe work practices, (4) maintenance

personnel training and (5) required documentation.



MANAGEMENT OF CHANGE (MOC)



We review any changes to our processes to determine if new

hazards are introduced or existing prevention measures are

threatened. Except for replacements-in-kind (e.g.,

replacing a valve with an identical valve), all changes are

subjected to a hazard analysis to ensure that (1) new

hazards are not inadvertently introduced into the system,

(2) safety consequences resulting from the change are

addressed, (3) operators in the process are notified of the

change and made aware of possible repercussions and (4) all

training material, process safety information and operating

procedures are updated. The MOC system applies to changes

in the chemicals used, process equipment, technology,

procedures a
nd other facility changes.



PRE-STARTUP REVIEW



Whenever a change occurs that requires updating the process

safety information, the Shreveport Plant performs a pre-

start-up safety review. This review ensures that safety

features, procedures, personnel and the equipment are

prepared for service before the process is restarted. A pre-

startup safety review will generally include field

verification of new construction and also serves a quality

assurance function by verifying that accident prevention

measures are implemented correctly. Generally, a pre-

startup review will ensure that (1) construction and

equipment are consistent with design standards, (2) adequate

operating, safety and maintenance procedures are in place,

(3) training for all affected employees is complete and (4)

a Process Hazard Analysis (PHA) has been performed, if

necessary.



INCIDENT INVESTIGATION



The Kemira Chemicals, Inc. - Shreveport Plant trains its

employees to promptly investigate each incident that

resulted in, or could have resulted in, serious injury to

employees, the public or the environment. Incident

investigations are designed to determine the facts, identify

root causes and provide recommendations for ensuring that

the incident does not recur. Corrective actions resulting

from an incident investigation are tracked until they are

resolved.



Incident investigations are conducted in accordance with..



EMPLOYEE PARTICIPATION



The Shreveport Plant encourages employees to be involved in

every aspect of process safety management and incident

investigation. Employees are routinely asked to participate

in process hazard analyses, incident investigations,

management of change hazard analyses and all other aspects

of the prevention program. Employees have access to all

information developed as part of the prevention program and

are specifically informed of any changes that occur in their

process areas. The various ways employe
es are involved in

the prevention program are documented in a written plan.



SAFE WORK PRACTICES



The Kemira Chemicals, Inc.- Shreveport Plant has established

safe work practices that ensure the safety of our employees.

Examples of these procedures include (1) a hot work permit

that is designed to control spark or flame-producing

activities, (2) a permit and procedure to control confined

space entry, and (3) a lockout/tagout procedure for

isolating energy sources during maintenance. These

procedures and permits ensure that operations and

maintenance activities are performed safely.



CONTRACTORS



The Shreveport Plant uses contractors for various activities

such as maintenance and construction. All contractors are

evaluated to ensure that they are well trained and are able

to perform their job function in a safe manner. A

contractor's safety record and performance are reviewed as

part of the selection process.



Once a contractor is selected, the plant provides training

and procedures to ensure that contractor employees (1)

perform their work in a safe manner, (2) are aware of the

hazards associated with the area in which they will be

working, (3) understand the emergency response procedures

and (4) report any hazards they find during their work. Our

personnel periodically monitor contractor activities to

ensure they are performing their work in a safe manner.



COMPLIANCE AUDITS



A compliance audit is performed periodically to help ensure

that the prevention program activities at our facility are

adequate and that safety issues are addressed effectively.

Audits are performed by a team that is knowledgeable in our

processes, but is independent of our facility to ensure a

thorough and complete evaluation. The audit team

systematically evaluates each aspect of the prevention

program, ensuring both compliance with the RMP rule and

effective hazard prevention. The results of the audits are

documented and recom
mendations are tracked until they are

resolved. Compliance audits are conducted at least every

three years.



CHEMICAL-SPECIFIC PREVENTION STEPS



The prevention program described previously ensures the safe

operation of our facility by providing our employees with a

system they can use to safely perform their job functions.

This management system helps prevent hazards associated with

equipment failures and human error. In addition to the

prevention program, the Shreveport Plant has safety features

built into the design of the facility that help to ensure

safe process operation for our employees, the public and the

environment. These features may contain or control a

release, detect a release or reduce the consequences of a

release. They may also prevent a release by providing

strict design standards for process equipment. The

following types of safety features are used in various

processes in our facility:



Release Detection



1 Procedures that require a Shreveport Plant employee be

present during loading and unloading operations



Release Containment and Control



2 Valves to permit isolation of the process

3 Automated shutdown systems for some process parameters

(e.g., high level, high pressure)

4 Manual shutdown systems located in the control room

5 Diked areas designed to contain a release

6 Pressure relief valves and rupture disks that discharge

safely to the atmosphere



Release Mitigation



1 Fire suppression equipment

2 Trained emergency response personnel

3 Personal Protective Equipment (e.g., protective

clothing, self-contained breathing apparatus)

4 Spill clean-up equipment



FIVE YEAR ACCIDENT HISTORY



Our five-year accident history shows that the Kemira

Chemicals, Inc.- Shreveport Plant has had no qualifying

accidental releases of epichlorohydrin.



EMERGENCY RESPONSE PROGRAM



The Shreveport Plant relies on our community emergency

resp
onders (the fire department ) to mitigate releases from

our facility and to notify the community. However, we

maintain procedures that address many of the other aspects

of an emergency response, such as proper first-aid and other

medical procedures and the use of personal protective

equipment.



The Shreveport Plant's emergency response procedures are

coordinated with local emergency responders. The local

responders are trained in the hazards of the substances at

the plant and communications channels are kept open 24-hours

per day. This coordination and communication ensure that

the public is quickly notified, if necessary, and that

action is promptly taken to minimize the consequences of a

release.



PLANNED CHANGES TO IMPROVE SAFETY



The Kemira Chemicals, Inc.- Shreveport Plant continuously

strives to improve the safety of our processes. Suggestions

for improving safety are regularly addressed through process

hazard analyses, management of change procedures, incident

investigations and employee suggestions.