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Axiall Corporation - Plaquemine Facility

Parent Companies:
EPA Facility ID:
100000140714
Other ID:
00765GRGGLHIGHW
Facility DUNS:
120957840

Location:

Address:
26100 Highway 405
Plaquemine, LA 70764
County:
IBERVILLE
Lat / Long:
30.255, -91.189 (Get map)
Method:
Interpolation - Photo
Description:
Facility Centroid
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Axiall Corporation
Phone:
(225) 685-2500
Address:
P.O. Box 629
Plaquemine, LA 70765
Foreign Address:

Person responsible for RMP implementation:

Name:
Doug Knittig
Title:
General Manager

Emergency contact:

Name:
Mark Devall
Title:
Sr. Specialist, HSE
Phone:
(225) 685-2646
24-hour phone:
(225) 685-2500
Ext or PIN:
2642

Other contacts:

Facility (or company) email:
Facility phone:
(225) 685-2500
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Iberville Parish Office of Eme
Full-Time Equivalent Employees:
464
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
881-VO
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Nov. 19, 2014
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Water Treatment
RMP ID:
1000061047
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
20,000
No
Public OCA Chemical
0
No
Chlorine
RMP ID:
1000061048
CBI claimed:
No
Program Level:
3
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Chemical name
CAS#
Quantity (lbs.)
CBI
Chlorine
7782-50-5
16,500,000
No
Public OCA Chemical
0
No
VCM
RMP ID:
1000061049
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Vinyl chloride [Ethene, chloro-]
75-01-4
35,000,000
No
Public OCA Chemical
0
No
PVC
RMP ID:
1000061050
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
666,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Mark Devall
Address:
26100 Highway 405
Plaquemine, LA 70675
Foreign Address:

Phone:
(225) 685-2646

Latest RMP Submission:

Date:
Feb. 23, 2015
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000048698

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 Chlorine)
CBI claimed:
No
Percent weight:
100.0
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 Water Treatment)
CBI claimed:
No
Percent weight:
100.0
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:
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in Chlorine)
CBI claimed:
No
Percent weight:
Physical state:
Gas
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:
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown

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:
  • dikes, dikes
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

Water Treatment, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000050760
Safety Review Date
Feb. 3, 2015, since latest RMP submission
PHA Update Date
June 30, 2014, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Fire
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
Process Controls
  • None
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Observation
Procedure Review Date
Feb. 3, 2015, since latest RMP submission
Training Review Date
Dec. 29, 2009, since latest RMP submission
Maintenance Review Date
Jan. 27, 2015, since latest RMP submission
Maintenance Inspection Date
Dec. 15, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 15, 2009
Management of Change Review Date
April 9, 2013
Pre-startup Review Date
Dec. 21, 2009
Compliance Audit Date
Sept. 23, 2013
Compliance Audit Change Completion Date
Sept. 23, 2015
Incident Investigation Date
Oct. 3, 2014
Incident Invest. Change Completion Date
Sept. 28, 2015
Participation Plan Review Date
Feb. 28, 2013
Hot Work Review Date
Oct. 25, 2010
Contractor Safety Review Date
May 27, 2014, since latest RMP submission
Contractor Safety Eval. Date
Aug. 15, 2014, since latest RMP submission
Chlorine, Other Basic Inorganic Chemical Manufacturing (32518)
Prevention Program ID:
1000050757
Safety Review Date
Feb. 3, 2015, since latest RMP submission
PHA Update Date
Sept. 1, 2015, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • Perimeter Monitors
Changes since PHA
  • Process Controls
Training Type
  • None
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 14, 2015, since latest RMP submission
Training Review Date
Dec. 29, 2009, since latest RMP submission
Maintenance Review Date
Jan. 27, 2015, since latest RMP submission
Maintenance Inspection Date
Oct. 22, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Sept. 29, 2014
Management of Change Review Date
April 9, 2013
Pre-startup Review Date
Oct. 6, 2014
Compliance Audit Date
Sept. 23, 2013
Compliance Audit Change Completion Date
Sept. 23, 2015
Incident Investigation Date
June 24, 2014
Incident Invest. Change Completion Date
July 17, 2014
Participation Plan Review Date
Feb. 28, 2013
Hot Work Review Date
Oct. 25, 2010
Contractor Safety Review Date
May 27, 2014, since latest RMP submission
Contractor Safety Eval. Date
Aug. 15, 2014, since latest RMP submission
VCM, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000050758
Safety Review Date
Feb. 11, 2015, since latest RMP submission
PHA Update Date
Sept. 26, 2011, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
  • Neutralization
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 29, 2015, since latest RMP submission
Training Review Date
Dec. 29, 2009, since latest RMP submission
Maintenance Review Date
Jan. 27, 2015, since latest RMP submission
Maintenance Inspection Date
Feb. 9, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Feb. 9, 2015
Management of Change Review Date
April 9, 2013
Pre-startup Review Date
Feb. 11, 2015
Compliance Audit Date
Sept. 23, 2013
Compliance Audit Change Completion Date
Sept. 23, 2015
Incident Investigation Date
Dec. 23, 2014
Incident Invest. Change Completion Date
Jan. 21, 2015
Participation Plan Review Date
Feb. 28, 2013
Hot Work Review Date
Oct. 25, 2010
Contractor Safety Review Date
May 27, 2014, since latest RMP submission
Contractor Safety Eval. Date
Aug. 15, 2014, since latest RMP submission
PVC, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000050759
Safety Review Date
Feb. 11, 2015, since latest RMP submission
PHA Update Date
Sept. 26, 2011, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • None
Mitigation Systems
  • Sprinkler System
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
Feb. 4, 2015, since latest RMP submission
Training Review Date
Dec. 29, 2009, since latest RMP submission
Maintenance Review Date
Jan. 27, 2015, since latest RMP submission
Maintenance Inspection Date
Jan. 14, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
March 27, 2014
Management of Change Review Date
April 9, 2013
Pre-startup Review Date
May 15, 2014
Compliance Audit Date
Sept. 23, 2013
Compliance Audit Change Completion Date
Sept. 23, 2015
Incident Investigation Date
Sept. 21, 2014
Incident Invest. Change Completion Date
Jan. 13, 2015
Participation Plan Review Date
Feb. 28, 2013
Hot Work Review Date
Oct. 25, 2010
Contractor Safety Review Date
May 27, 2014, since latest RMP submission
Contractor Safety Eval. Date
Aug. 15, 2014, 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:
Jan. 14, 2015
Local Response Agency:
Local Response Agency Phone:
(225) 687-5140
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

General Executive Summary for Chemical Manufacturing Facilities

2694 - LDEQ Facility ID Number

Axiall CORPORATION, PLAQUEMINE FACILITY



1. Accidental Release Prevention and Emergency Response Policies



Axiall Corporation, Plaquemine Facility is strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances and to protect people, property and the environment.



2. The Stationary Source and the Regulated Substances Handled



Our facility's primary activities encompass the manufacture Electrochemicals and Polyvinyl Chloride (PVC) Resins. We have three regulated substances above the RMP threshold quantity present at our facility. These substances are Chlorine, Vinyl chloride monomer and anhydrous ammonia. Chlorine is used in the manufacture of vinyl chloride monomer. Vinyl chloride is used for feedstock in the manufacture of PVC resin. Anhydrous Ammonia is used in bio feed for water treatment.



3. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps



Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The following sections briefly describe the elements of the accidental release prevention and process safety managements programs that are in place at our facility.



Process Safety Information (PSI)



Axiall Corporation maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes.



Process Hazard Analysis (PHA)



Our facility conducts comprehensive studies to ensure that
hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is "HAZOP" and/or"What If". The site utilizes a Layers of Protection Analysis (LOPA)methodology in the most recent Hazard Studies. The studies are undertaken by a team of qualified personnel which may include expertise in engineering, process operations, maintenance and environmental, health and safety. Findings related to the hazard analysis are entered in our electronic tracking system.



Operating Procedures



For the purposes of safely conducting activities within our covered processes, we maintain written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to workers involved in the processes.



Training



Axiall Corporation has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every three years and more frequently at intervals determined by the complexity of the process and employee input.



Mechanical Integrity



Axiall Corporation carries out documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.



Management of Change




Written procedures are in place to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and trained to deal with the modification prior to working with the modified process. In addition operating procedures and associated PSI are updated as required.



Pre-startup Reviews



Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Axiall Corporation. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation.



Incident Investigation



Axiall Corporation promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. All incidents are inputted electronically on our electronic tracking system. These incidents are shared and provide a tool for "lessons learned" throughout the corporation. We use the Apollo Root Cause methodology to investigate all incidents that meet the company's set criteria.



Employee Participation



We believe that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. Axiall developed a Safety Involvement team (SIT) and a Unit Safety Involvement Team (USIT) to increase employee involvement. Both teams provide value in Employee Participation. They focus on updating safety procedures, plant inspections, unit and plant safety issues and they are a voice to Management concerning plant safety issues. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulti
ng from process hazard analyses in particular. Axiall has been recognized by the Chemical Manufacturers' Association for having Employee Involvement Programs that are "Examples of Excellence in the Chemical Industry."



Contractors



On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Axiall Corporation, Plaquemine Facility has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur.



4.Five-year Accident History



Axiall Corporation has had an excellent record of preventing accidental releases; during the 5 years prior to the Feb 2015 submission, there have not been accidents in our site that meet the RMP criteria as defined in ?68.42.



5. Emergency Response Plan



Axiall Corporation has a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public.



To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. Emergency responders are trained or drilled on a quarterly basis.

Our emergency plan has been coordinated with and verified by Iberville LEPC.



6. Planned Changes to Improve Safety



Axiall has incorporated the use of Layers of Protection Analysis (LOPA) in our existing Process Hazard Analysis Program (PHA). This analysis helps to confirm existing safeguards and helps ide
ntify areas for potentially improving or adding additional safeguards. LOPA will be incorporated on new projects requiring hazard analysis and it is being incorporated in upcoming PHA revalidations.