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INEOS Oxide

Parent Companies:
INEOS Oxide, a Division of Americas, LLC
EPA Facility ID:
100000176551
Other ID:
LA000044180
Facility DUNS:
0
Parent Company DUNS:
0

Location:

Address:
21255A Hwy 1
Plaquemine, LA 70765
County:
IBERVILLE
Lat / Long:
30.316, -91.241 (Get map)
Method:
Classical Surveying Techniques
Description:
Water Release Pipe
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
INEOS Oxide
Phone:
(225) 242-3000
Address:
21255A Hwy 1 South, P. O. Box 718
Dow Block 55
Plaquemine, LA 70765 -0718
Foreign Address:

Person responsible for RMP implementation:

Name:
Kevin McGovern
Title:
Site Manager

Emergency contact:

Name:
Kevin McGovern
Title:
Site Manager
Phone:
(225) 242-3027
24-hour phone:
(713) 553-6534
Ext or PIN:

Other contacts:

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

Safety:

Local Emergency Planning Committee:
Iberville Parish LEPC
Full-Time Equivalent Employees:
40
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
2599-V4
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
April 29, 2005
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Organic Chemical Manufact
RMP ID:
1000074570
CBI claimed:
No
Program Level:
3
NAICS:
Other Basic Organic Chemical Manufacturing (32519)
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
500,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
Aug. 31, 2016
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000059699

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 Organic Chemical Manufact)
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:
Urban
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 Organic Chemical Manufact)
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:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Sprinkler systems
  • Deluge systems
  • Emergency shutdown
not considered:
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers

4. Flammables: Worst-case

None

5. Flammables: Alternative release

None

6. Five-year accident history

July 20, 2011 at 01:47
ID:
1000045918
NAICS:
Other Basic Organic Chemical Manufacturing (32519)
Duration:
55 minutes
Chemicals involved:
  • Ammonia (conc 20% or greater)
Release events:
Gas release
Weather conditions at time of event
Wind speed:
5.0 miles/h NW
Temperature:
95.00 ℉
Atmospheric stability:
E
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
0
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$0
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Overpressurization
  • Upset condition
  • process start-up
Off-site responders notified:
No, not notified
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Revised operating procedures
  • New mitigation systems

7. Prevention: Program level 3

Organic Chemical Manufact, Other Basic Organic Chemical Manufacturing (32519)
Prevention Program ID:
1000062675
Safety Review Date
Dec. 15, 2015, since latest RMP submission
PHA Update Date
Oct. 26, 2015, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • None
Process Controls
  • None
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • None Recommended
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Sept. 29, 2014, since latest RMP submission
Training Review Date
Sept. 29, 2014, since latest RMP submission
Maintenance Review Date
Feb. 1, 2016, since latest RMP submission
Maintenance Inspection Date
April 1, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 14, 2009
Management of Change Review Date
April 14, 2009
Pre-startup Review Date
May 10, 2014
Compliance Audit Date
April 27, 2016
Compliance Audit Change Completion Date
None
Incident Investigation Date
July 29, 2016
Incident Invest. Change Completion Date
Dec. 31, 2016
Participation Plan Review Date
Jan. 27, 2016
Hot Work Review Date
July 2, 2013
Contractor Safety Review Date
Aug. 1, 2016, since latest RMP submission
Contractor Safety Eval. Date
Dec. 14, 2010, 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:
Oct. 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:
No
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

Risk Management Program Executive Summary

INEOS Oxide, a Division of INEOS Americas, LLC

Plaquemine, Louisiana Operations



RMP Facility ID Number - 100000176551

LDEQ Facility ID Number - 89259



1. Accidental Release Prevention and Emergency Response Policies

The Ineos L.L.C. -Plaquemine, Louisiana Operations (Ineos) is strongly committed to employee, public and environmental safety. As an integral part of this commitment, Ineos has developed and implemented a comprehensive accidental release prevention program that covers such areas as design, installation, operating procedures, maintenance, emergency response and employee training associated with the processes at its Plaquemine, Louisiana facility. This program complies with all of the requirements of 40 CFR Part 68, "Chemical Accident Prevention Provisions" and with Chapter 59 of LAC 33:III, "Chemical Accident Prevention and Minimization of Consequences".



It is Ineos' policy to always operate the manufacturing processes in a safe manner and according to the established procedures and good engineering and management practices. As part of this policy, Ineos has established the appropriate management and administrative controls for the prevention of accidental releases of regulated substances. In the unlikely event that such a release may occur, trained emergency response personnel are available on site to take the necessary and appropriate corrective action to control and mitigate the effects of the release.



Ineos has also established lines of communication with the Iberville Parish Emergency Planning Committee (LEPC), in the event that an accidental chemical release may have beyond-the-fenceline effects and that additional emergency response expertise may be deemed necessary.



Figure 1 presents an organization chart that shows the Ineos staff and supervisory positions responsible for the implementation of the various parts of the RMP program, in compliance with 40 CFR 68.15



2. Stationary
Sources and Regulated Substances Handled



In February 2001, Ineos and the Dow Chemical Company (Dow) finalized agreements whereby Ineos, as an independent business entity, operates the existing production units at the Dow Plaquemine facilities known as Block 55. Specifically, Ineos owns and operates the ethanolamines unit and operates the glycol ethers and polyethylene glycol units for Dow. The 3 production units that now comprise the Ineos facility manufacture approximately 18 different ethylene oxide and propylene oxide derivatives used in a wide variety of consumer products such as antifreeze, shampoo ingredients, automotive fluids, cosmetics, and water purification chemicals.



Ineos uses a few organic chemicals as raw materials, including ethylene and propylene oxides, methanol, n-Butanol and ethylene glycol. Inorganic chemicals used in the process include phosphoric acid, potassium hydroxide and ammonia, among others. Although chlorine is not used in the manufacturing processes, it is used on site for cooling water treatment.



None of the products and byproducts manufactured at the Ineos facility is regulated under the risk management program (RMP) established by Section 112(r) of the Clean Air Act (CAA). The only RMP-regulated substances present at Ineos above the RMP threshold quantities are Chlorine and Ammonia (anhydrous). Ethylene oxide [Oxirane] and Propylene oxide [Oxirane, methyl-] are both used as raw materials in the Ineos processes, but they are received by pipeline from nearby Dow facilities on a continuous basis and as needed in the chemical manufacturing processes. Consequently, there are no storage facilities for these two chemicals within the Ineos Block 55 perimeter.



Maximum inventories and threshold quantities for the RMP-regulated substances at the Ineos facility in Plaquemine, Louisiana are shown on the table below.





Table 1

112(r) Regulated Chemicals Present at the Ineos-Plaquemine Facility

and their Threshold Q
uantities



RMP Regulated Substance

Inventory Quantity (lbs)

(24-hr. Max.)

RMP Threshold, lb

Ammonia (Anhydrous)

500,000

10,000

Ethylene oxide

2,500 (*)

10,000

Propylene oxide

3,000 (*)

10,000



(*) Ethylene Oxide and Propylene Oxide are received into the Ineos facility via pipeline from the Dow facility next door, on demand depending on the process needs. No storage of these chemicals over the RMP threshold quantities takes place within the Ineos perimeter. The amounts shown are the volumes of the existing in-line surge drums.





Anhydrous Ammonia. Ammonia is received on the Ineos plant site primarily by pipeline and four times a year by railroad tank cars. It is stored under pressure in a spherical tank, DS-205. From this tank, it is pumped into the process. DS-205 has a gross storage capacity of approximately 750,000 lbs. of ammonia, but the necessary administrative controls (written operating procedures and level controls and alarms) are in place to limit the maximum amount of ammonia in the tank to 500,000 lbs. DS-205 has no refrigeration, therefore the material is kept under pressure and, according to operating personnel, the storage temperature is usually between 75 deg F. and 85 degs F. The vapor pressure of anhydrous ammonia in this temperature range is between 140 and 180 psia.



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



Ineos has taken all the necessary steps to comply with the accidental release prevention requirements set out by the USEPA under 40 CFR Part 68. The following sections briefly describe the elements of the release prevention program that is in place at the Ineos facility.



Health and safety procedures are being reviewed and revised as needed by Ineos. The last review/revision of the theses procedures was in December 2015.



Process Safety Information



The Ineos facility maintains detailed records of safety information that describes the chemical hazards, ope
rating parameters and equipment designs associated with all processes, including those that involve the regulated chemicals, ammonia and chlorine. Documentation kept on site provides information regarding the chemical properties and chemical hazards associated with the regulated chemicals. These documents include, but are not limited to:



* Copies of current Material Safety Data Sheets (MSDS's),

* Equipment specifications and manufacturer's design data,

* Complete sets of construction drawings and specifications

* A copy of the plant's Emergency Response Plan

* Copies of Shop Drawings and assembly and maintenance instructions for all major components

* Copies of the Operator's daily log sheets, showing material inventories and a record of the shipments of chemicals delivered on site.



The above records are updated as applicable and necessary.





Process Hazard Analysis (PHA)



Comprehensive studies were conducted by Dow to ensure that hazards associated with all processes are identified and controlled efficiently. These studies included the process units that now comprise the Ineos facility. The methodologies used to carry out these analyses include What If/Checklist (combined), HAZOP, the Dow Fire and Explosion Index, the Dow Chemical Exposure Index, and Reactive Chemicals/Process Hazards Analysis (PHA). It is Dow's practice that these studies be undertaken periodically by a team of qualified personnel with expertise in engineering and process operations and that any findings related to the hazard analysis are addressed in a timely manner. Ineos management is committed to continue these practices. The most recent PHA/update on the process systems was performed by INEOS's technical staff on 10/26/2015.



Operating Procedures



For the purposes of safely conducting activities within the manufacturing processes, Ineos maintains complete and up to date written standard operating procedures (SOP's) for each process. These procedures address various
modes of operation such as initial startup, normal operations, temporary operations, emergency operations, emergency shutdown, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. The SOP's also discuss potential deviations from the standard operating conditions, how to prevent such deviations and the corrective steps to take if and when they do occur. Operating information and process parameters are readily accessible to operators involved in the processes and the SOP's are reviewed and updated periodically and if required when any process changes are implemented (see also Management of Change section below). The SOP's for the Ineos facilities are reviewed based on procedure user policy which falls into two review periods. Level-3 SOP's are considered critical and are reviewed annually and level 1-2 are reviewed every three years.



All SOP's are kept electronically on the plant's electronic document management system. This allows for the control of all copies by the document manager and prevents unauthorized changes in the documents. They are readily accessible 24 hours/day and located on computers in the control room. Copies may be printed for use, and are labeled as "uncontrolled" copies.





Training



Ineos has a comprehensive training program in place to ensure that employees who are operating the manufacturing processes are competent in the operating procedures associated with these processes and that they understand the potential hazards associated with the chemicals and substances involved in said processes. It is Ineos policy that all new employees receive the necessary initial training according to their intended position and responsibilities and that periodic refresher training sessions are provided as needed.



Maintenance and Mechanical Integrity



The Ineos facility has established a well-documented preventive maintenance (PM) program to en
sure proper operations of all equipment. It includes periodic checks to verify that all equipment is always in good operating condition. Process equipment examined by these periodic checks includes among others: pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, pumps and process control systems and components.



Any equipment deficiencies identified by the PM checks are corrected in a safe and timely manner. PM activities and routine maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed.



Management of Change (MOC)



Written procedures are in place at Ineos to manage and document changes in process chemicals and raw materials, technology, equipment and/or operating procedures. The most recent review/revision of MOC procedures was completed on 04/14/09 triggered by an internal PSM audit. Process operators, maintenance personnel or any other employee whose job tasks and responsibilities are affected by a modification in process conditions are promptly made aware of and provided the necessary training so that they understand the modification(s), the reason(s) for it (them) and how their job responsibilities will be affected as a result.



Ineos' MOC procedures were implemented under OSHA's Process Safety Management (PSM) requirements, thereby they are compliant with RMP requirements as well. These procedures require, among other things, that process safety considerations be evaluated anytime that a process change is considered, to determine whether a process hazard analysis (PHA) is warranted and to evaluate any potential on-site and off-site impacts.



Pre-startup Safety Reviews



Procedures are in place at Ineos to perform Pre-start up safety reviews related to new processes and to modifications in existing processes. The most recent review was performed by INEOS on 3/18/2010
(DS-205). The purpose of these reviews is not only to confirm that the new or modified equipment and systems have been constructed and installed with all the necessary safety features, but also to establish that the operating and maintenance procedures are fully adequate and that they include all of the necessary information for safe startup, before the system is actually placed into operation.



Internal Compliance Audits



Similarly, Ineos will conduct audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. There was a PSM compliance audit conducted by 3rd party on 4/27/2016. This also covered all RMP compliance requirments.



Ineos will continue to conduct these audits at least once every 3 years and any corrective actions required as a result of the audits will be addressed in a safe and prompt manner.



Incident Investigation



Ineos incident investigation procedures were established in compliance with OSHA's PSM requirements. Ineos has adopted these procedures and will promptly investigate any incident that results in, or could reasonably result in, a catastrophic release of a regulated substance. These investigations will be undertaken to identify the situation, conditions and contributing factors leading to the incident as well as to identify any corrective actions to prevent the incident from reoccurring. The objectives of such investigations are:



* to establish the facts relating to the incident,

* to determine the factors causing or contributing, directly or indirectly, to the incident and

* to define what corrective actions, if any, are necessary to prevent such incidents from occurring in the future.



The incident investigation team will include members of the staff who are familiar with the process involved in the incident and shall also include personnel from the operations, maintenance and management departments.



The investigating team will submit its findings and recommenda
tions to plant management for resolution. Corrective actions taken in response to the investigation report will be tracked until completed. 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 said findings. Incident investigation reports will be kept on file for a minimum of 5 years so that they can be reviewed during future process hazard reviews.



The incident investigation reports will include, among other information, the date and time of the incident, actual or estimated duration of the release, actual or estimated amount of the regulated substance that was released, a description of the incident, factors causing and/or contributing to the incident, and any conclusions and recommendations arrived at by the investigating team.



Employee Participation



Ineos truly believes that process safety management and accident prevention is a team effort. Ineos' employee participation program is a program developed in compliance with OSHA's PSM requirements, which by definition also complies with the requirements of the RMP program. PHA procedures call for the active participation of Ineos employees; the findings and recommendations resulting from PHA reviews are made available to all employees and are discussed with all employees who work in the affected areas.



Further, quartly meeting are held where company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, all Ineos employees have access to the information developed and created as part of the facility's implementation of the RMP rule, including information resulting from PHA reviews.



Contractors



From time to time and as the need arises, Ineos will hire contractors to conduct specialized maintenance, repairs, construction and various other activities. An integral part of the c
ontractor selection procedure is a thorough evaluation of each candidate's safety performance. After such a contract has been awarded but before the actual work commences, all of the contractor's employees who will be performing work inside the plant must undergo, as a condition of the contract, a mandatory safety orientation. As part of this orientation, Ineos will inform the contractors of known potential hazards related to the contractor's work and the processes involved. Contractors are also informed of all the procedures for emergency response, should an accidental release of a regulated substance occur. Contractors are also required to inform Ineos of any hazards they may introduce at the site.



4. Five-year Accident History

Ineos operations has not experience, within the last 5 years, any accidental releases of regulated substances that were reportable under 40 CFR 68.42(a) (i. e. that resulted in deaths, injuries or significant onsite property damage or known offsite deaths, injuries, evacuations, shelter in place, property damage or environmental damage). However, there have been releases reportable under rules other than Part 68 and these have been subject to internal investigation and evaluation.



Ineos has adopted and adheres to strict accident prevention policies, therefore Ineos will maintain an excellent accident record in the future.





5. Emergency Response Program

The Ineos facility has developed and implemented an emergency response program that includes procedures to respond to emergencies involving toxic materials.



The Plan addresses all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. Medical and emergency response support is coordinated with the Dow Plaquemine operations.



Some of the major topics addressed in the Plan include, but are not limited to,
the following:

* Description of the uses of ammonia within the plant

* Physical Properties of ammonia

* Safety measures that must be taken before working in the ammonia storage area

* Description of monitoring, warning and alarm systems in the ammonia storage area

* Description of safety features provided at the ammonia storage sphere area.

* Personnel responsibilities during a ammonia emergency, including local and evacuation alarms.

* List of emergency call numbers to be contacted (local agencies and public)

* Procedures to inform the media and the public about accidental releases of regulated substances

* Emergencies requiring public action

* Proper first-aid and emergency medical treatments for accidental human exposures to ammonia

* Closure of emergency condition

* Plant evacuation procedures and checklist



Ineos holds refresher training on the Plan annually.



To ensure proper functioning, Ineos emergency response equipment is regularly inspected and serviced. In addition, the Plan will be promptly updated, when and as necessary, to reflect any changes taking place within the processes that would require a modified emergency response.



Ineos will coordinate its emergency plan with the Iberville Parish Emergency Planning Committee (LEPC). The Ineos emergency response team also works closely with Dow's and personnel from the two plants are qualified to provide mutual emergency assistance when and as necessary. Lines of communication have been clearly established between the two plants with respect to sharing emergency and chemical hazard information.





6. Planned Changes to Improve Safety

There are no planned changes to improve safety at this time as a result of our implementing the accidental release prevention program.