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Addis Plant A

Parent Companies:
C-K Tech, Inc.
Shintech Louisiana, LLC
EPA Facility ID:
100000173509
Other ID:
LAR000056416
Facility DUNS:
0
Parent Company #1 DUNS:
0
Parent Company #2 DUNS:
65095390

Location:

Address:
9750 LA-1 South
Addis, LA 70710
County:
WEST BATON ROUGE
Lat / Long:
30.326, -91.261 (Get map)
Method:
Interpolation - Satellite
Description:
Center of Facility
Horizonal accuracy:
2 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
Shintech Louisiana, LLC
Phone:
(225) 685-1199
Address:
P.O. Box 358
Addis, LA 70710
Foreign Address:

Person responsible for RMP implementation:

Name:
Timothy Bergeron
Title:
Environmental Manager

Emergency contact:

Name:
Shintech Security
Title:
Security
Phone:
(225) 687-2105
24-hour phone:
(225) 687-2105
Ext or PIN:
5680

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:
60
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
2639-V7
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Jan. 17, 2013
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

PVC Plant
RMP ID:
1000066127
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
33,500,000
No
Chlorine
7782-50-5
3,750
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Providence
Address:
1201 Main Street
Baton Rouge, LA 70802
Foreign Address:

Phone:
(225) 766-7400

Latest RMP Submission:

Date:
Oct. 26, 2015
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000052458

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 PVC Plant)
CBI claimed:
No
Percent weight:
Physical state:
Gas
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:
  • Enclosures
not considered:
  • Dikes
  • 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 PVC Plant)
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:
  • Enclosures
not considered:
  • Dikes
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Sprinkler systems
  • Deluge systems
not considered:
  • 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 PVC Plant)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Blast walls

5. Flammables: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in PVC Plant)
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
  • Water curtain
  • Excess flow valve

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

PVC Plant, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000054992
Safety Review Date
March 31, 2014, since latest RMP submission
PHA Update Date
Sept. 27, 2012, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • None
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Aug. 10, 2015, since latest RMP submission
Training Review Date
June 20, 2015, since latest RMP submission
Maintenance Review Date
April 10, 2015, since latest RMP submission
Maintenance Inspection Date
Aug. 12, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Sept. 2, 2015
Management of Change Review Date
Sept. 15, 2014
Pre-startup Review Date
Sept. 2, 2015
Compliance Audit Date
Oct. 21, 2013
Compliance Audit Change Completion Date
Dec. 31, 2016
Incident Investigation Date
Aug. 22, 2015
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Dec. 3, 2013
Hot Work Review Date
Sept. 9, 2015
Contractor Safety Review Date
July 28, 2014, since latest RMP submission
Contractor Safety Eval. Date
Aug. 13, 2015, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
Aug. 24, 2015
Local Response Agency:
Local Response Agency Phone:
(225) 356-1577
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
No
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

SHINTECH LOUISIANA, LLC

ADDIS PLANT A



Risk Management Plan



LDEQ Facility ID No. 330



EXECUTIVE SUMMARY



Shintech is committed to operating in a manner that is safe for the plant workers, the public, and the environment. Shintech strives to protect and promote the health and safety of its employees, its neighbors, and others who may be affected by activities at the facility. Shintech also strives to limit adverse effects on the physical environment in which its activities are carried out. The facility has established systems to help ensure safe operation of the processes at this facility. One part of these systems is the risk management program which helps manage the risks at the facility and complies with the requirements of the EPA's Rule 40 CFR Part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). One of the requirements of the RMP rule is to submit an RMP describing the risk management program at the facility.



This document satisfies the RMP executive summary requirement of the RMP rule and provides the public with a description of the risk management program at Shintech.



ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES



Shintech's goal at its Program 3 stationary source is accidental release prevention while maintaining emergency response procedures to minimize consequences in the event of any such release. Shintech maintains a Process Safety Manual directing employees to process safety information in accordance with respective Occupational Safety and Health Administration (OSHA) process safety management and EPA chemical accident prevention provisions. Shintech also maintains an Emergency Procedures Manual providing necessary information and guidelines to utilize in the event of an emergency situation resulting in accidental release of a regulated substance. Shintech's objective is to train employees and contractors in emergency response procedures, and requires that emergency response act
ions are supported by proper consideration for safety, health, and welfare of employees, contractors, the surrounding community, and property.



ACCIDENTAL RELEASE PREVENTION PROGRAM



Shintech has developed a management system to oversee implementation of the RMP elements. Shintech assigns responsibility for implementing individual requirements of the program to identified persons exhibiting respective qualifications. Shintech's system includes:



*Compiling process safety information to support completing process hazard analyses.

*Issuing written operating procedures that provide instructions for safely conducting activities in the covered processes, and training employees involved in operating the processes.

*A mechanical integrity program.

*Management of change (MOC)procedures and pre-startup safety reviews.

*Compliance audits to evaluate compliance with provisions of the program.

*Incident investigation for incidents which resulted in, or could reasonably have resulted in, a release of a regulated substance.

*An established hot work permit program.

*Employee participation and training.

*Contractor pre-qualification, participation, and training.



Shintech's prevention steps include engineering and administrative controls. Shintech's engineering designs include overpressure protection for pressurized vessels including a closed vent capture and control system, as well as capture and control technology for atmospheric operations. Redundant equipment and instrumentation is installed where applicable. Shintech uses a Distributed Control System to control production in covered process units. Control buildings are engineered to be blast-resistant for protection of control systems and personnel. Administratively, Shintech engages in periodic inspection and maintenance practices consistent with industry standards, as well as OSHA and EPA regulatory provisions. Shintech's covered process units also include fire suppression, containment, and mitigation systems
.



EMPLOYEE PARTICIPATION



Employee participation is a goal at Shintech. Keeping employees informed and involved creates a team unity atmosphere. Employees participate on Process Hazards Analysis (PHA) teams and have access to all hazard and operability (HAZOP) information and recommendations. This information along with updated Operation Manuals are available in assigned locations throughout the facility. Operation manuals are developed, updated, and reviewed by Operations personnel and the Training Department. These Operation Manuals assist employees in refresher training and Operator Recertification Programs.



Safety meetings are held on a regular basis for Operations, Maintenance, Terminal, Administration, and Contract personnel. Topics chosen are relevant to respective personnel assigned duties, and general and specific information is provided as informational instruments to enhance employee participation in facility-wide safety performance.



PROCESS SAFETY INFORMATION



Shintech keeps a variety of technical documents that are used to help maintain safe process operations. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific departments within Shintech are assigned responsibility for maintaining up-to-date process safety information.



Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in safety data sheets. For specific process areas, Shintech has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in the operation manuals for each process unit. Shintech promotes maintaining process parameters within limits by using process controls and monitoring instruments, operating procedures, trained personnel, and protective instrument systems (e.g., automated shutdown systems).



Shint
ech also maintains 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 for evaluating proposed process and facility changes to enhance safety features in the process.



PROCESS HAZARD ANALYSIS



Shintech has a comprehensive PHA program to recognize and control hazards associated with the process. Within this program, the existing covered processes and potential future processes are systematically examined.



Shintech primarily uses the HAZOP analysis technique to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques available. The analyses are conducted using a team of personnel who exhibit operating, maintenance, and process engineering experience and expertise. This team identifies and evaluates hazards of the process as well as recommends accident prevention and/or mitigation measures when the team believes such measures are warranted.



Shintech periodically updates its PHAs of affected units. These periodic reviews will be conducted at least every five years and will be conducted at this frequency until the process is no longer operating.



OPERATING PROCEDURES



Shintech maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. Procedures are periodically reviewed and annually certified as current and accurate. Procedures are maintaine
d current by revising them as necessary to reflect changes made to the process. In addition, the Shintech operating procedures provide guidance on how to respond to events that result in exceeding safe operating limits for specific process or equipment parameters. The written operating procedures are readily available to operators in the process units and for other personnel to use as necessary to safely perform their job tasks.



TRAINING



To complement the written procedures for process operations, Shintech has implemented a training program for all employees involved in operating a process. New employees receive basic training in Shintech operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate (e.g., through tests, skills demonstration, etc.) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training on the operating procedures in order to maintain skills and knowledge at an acceptable level.



CONTRACTORS



Shintech uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, Shintech has procedures in place to provide 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 Shintech personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, (4) safe work practices, and (5) a work permit process (i.e., for hot work, confin
ed space, etc.) prior to their beginning work. In addition, Shintech evaluates contractor safety programs and performance during the selection of a contractor. Shintech personnel monitor contractor performance to evaluate the level at which contractors are fulfilling their safety obligations.



PRE-STARTUP SAFETY REVIEWS



Shintech conducts a pre-startup safety review for any new facility or facility modification that requires a change in the process safety information. This review provides that safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to corroborate that construction is in accordance with the design specifications and that all supporting systems are operationally ready. The review team uses checklists to verify all aspects of readiness. A review involves field verification of the construction and serves a quality assurance function.



MECHANICAL INTEGRITY



Shintech uses 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:



*Conducting training.

*Developing written procedures.

*Performing inspections and tests.

*Correcting identified deficiencies.

*Applying quality assurance measures.



In combination, these activities form a system that maintains the mechanical integrity of the process equipment. To help ensure that they can perform their job in a safe manner, maintenance personnel receive training on:



*An overview of the process.

*Safety and health hazards.

*Applicable maintenance procedures.

*Emergency response plans.

*Applicable safe work practices.



Written procedures are used in the order that work is performed in a consistent manner and provide a basis for training. Inspections and tests are completed to eva
luate equipment functioning as compared to that intended and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or a management of change 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. Shintech incorporates quality assurance measures into equipment purchases and repairs. This practice assesses suitability of new equipment for its intended use and establishes that proper materials and spare parts are used when repairs are made.



MANAGEMENT OF CHANGE



Shintech has a comprehensive system to manage process changes. 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 technology information, equipment information, and procedures are updated to incorporate these changes. In addition, operating and maintenance personnel are provided with any necessary training on the change.



INCIDENT INVESTIGATION



Shintech will investigate incidents that resulted in, or could have reasonably resulted in, a fire/explosion, toxic 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, which can include contractors, will document its findings, deve
lop recommendations to prevent a recurrence, and forward these results to Shintech's management for resolution. Corrective actions will be taken in response to the investigation team's findings, and recommendations will be tracked until they are complete. The final resolution of each finding or recommendation will be documented, and the investigation results will be reviewed with all employees (including contractors) who could be affected by the findings.



COMPLIANCE AUDITS



Shintech periodically conducts audits to confirm the procedures and practices required by the chemical accident prevention program are being implemented. Compliance audits are conducted at least every three years. The findings are forwarded to Shintech management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained.



HOT WORK PERMITS



The facility's hot work procedure requires that detailed permitting activities take place before, during, and after any job that has the potential to provide a source of ignition. The permit is followed through to completion of the work and those permits are maintained on site. The facility implements other work permits as necessary to assure safe work conditions are communicated to maintenance and contract personnel.



SAFE WORK PRACTICES



Shintech has safe work practices in place to sustain 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 process piping or equipment is opened, (4) a permit and procedure to control welding and other spark-producing activities, 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 foster that operations and maintenance activities are performed safely.



CHEMICAL-SPECIFIC PREVENTION STEPS



The processes at the facility have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized previously is applied to the facility. Collectively, these prevention program activities help prevent potential accident scenarios of releases of RMP regulated chemicals caused by equipment failures or human errors.



In addition to the accident prevention program activities, Shintech has many safety features to help prevent the accidental releases of regulated substances in the facility. These safety features help to prevent potential accident scenarios that could be caused by equipment failures and human error. These features include but are not limited to:



*Operating parameter monitors with alarms.

*Process relief systems.

*Isolation valves (manual or automated).



FIVE-YEAR ACCIDENT HISTORY



Shintech's five-year accident history is included in Section 6 of the RMP. None of the accidents resulted in known deaths, injuries, property damage, hospitalizations, evacuations, other medical treatments, sheltering-in-place, or environmental damage.



EMERGENCY RESPONSE PROGRAM INFORMATION



Shintech's emergency response program is set forth in its Emergency Procedures Manual. That manual is comprised of numerous relevant sections. Those sections deal with, but are not limited to:



*Employee participation.

*Incident command management.

*Response teams.

*Emergency evacuation procedures.

*Fire response.

*Toxic gas release.



The Emergency Procedures Manual states Shintech's management issued policy statement, which is briefly described in the Accidental Release Prevention and Emergency Response Policies section in this Executive Summary.



PLANNED CHANGES TO IMPROVE SAFETY



Shintech's me
chanisms to improve safety include written procedure review, process hazard analysis, management of change, incident reporting and investigation, near miss reporting and investigation, and employee safety meetings and suggestion processes. Also, Shintech's pre-startup safety review includes, among other things, 'show stoppers' that prohibit any startup until those items are closed. Shintech assigns respective tasks resulting from each of these mechanisms to responsible persons, and closure is approved only after all recommendations and action items are documented as complete.