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Shintech Plaquemine Plant

Parent Companies:
Shintech Louisiana, LLC
C-K Tech, Inc.
EPA Facility ID:
100000202899
Other ID:
LAD 08141918
Facility DUNS:
0
Parent Company #1 DUNS:
65095390
Parent Company #2 DUNS:
0

Location:

Address:
26270 Highway 405
Plaquemine, LA 70764
County:
IBERVILLE
Lat / Long:
30.273, -91.173 (Get map)
Method:
Interpolation - Other
Description:
Plant Entrance (General)
Horizonal accuracy:
25 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
Email:

Emergency contact:

Name:
Timothy Bergeron
Title:
Environmental Manager
Phone:
(225) 687-2105
24-hour phone:
(225) 687-2105
Ext or PIN:
5620

Other contacts:

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

Safety:

Local Emergency Planning Committee:
Iberville Parish LEPC
Full-Time Equivalent Employees:
296
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
1280-00118-V6AA
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Inspecting Agency:
Never had one
Using Predictive Filing:
No

Processes:

VCM 1, Storage, HAPF 1
RMP ID:
1000083818
CBI claimed:
No
Program Level:
3
NAICS:
Plastics Material and Resin Manufacturing (325211)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ethylene [Ethene]
74-85-1
2,765
No
Hydrogen chloride (anhydrous) [Hydrochloric acid]
7647-01-0
200,458
No
Vinyl chloride [Ethene, chloro-]
75-01-4
8,505,590
No
Propylene [1-Propene]
115-07-1
147,701
No
Chloroform [Methane, trichloro-]
67-66-3
231,971
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
C/A Manufacturing
RMP ID:
1000083819
CBI claimed:
No
Program Level:
3
NAICS:
Plastics Material and Resin Manufacturing (325211)
Chemical name
CAS#
Quantity (lbs.)
CBI
Chlorine
7782-50-5
4,622
No
Public OCA Chemical
0
No
Tank Farm and Loading
RMP ID:
1000083820
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
83,401
No
Public OCA Chemical
0
No
Polyvinyl Chloride (PVC)
RMP ID:
1000083821
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
8,505,590
No
Public OCA Chemical
0
No
VCM 2, Storage, HAPF 2
RMP ID:
1000083822
CBI claimed:
No
Program Level:
3
NAICS:
Plastics Material and Resin Manufacturing (325211)
Chemical name
CAS#
Quantity (lbs.)
CBI
Chloroform [Methane, trichloro-]
67-66-3
231,971
No
Vinyl chloride [Ethene, chloro-]
75-01-4
8,505,590
No
Hydrogen chloride (anhydrous) [Hydrochloric acid]
7647-01-0
200,458
No
Propylene [1-Propene]
115-07-1
147,701
No
Ethylene [Ethene]
74-85-1
2,765
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
C/A 2
RMP ID:
1000083823
CBI claimed:
No
Program Level:
3
NAICS:
Plastics Material and Resin Manufacturing (325211)
Chemical name
CAS#
Quantity (lbs.)
CBI
Chlorine
7782-50-5
4,622
No
Public OCA Chemical
0
No

RMP Preparer:

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

Phone:
(225) 766-7440

Latest RMP Submission:

Date:
Nov. 29, 2017
Type:
Resubmission
Reason:
Voluntary update (not described by any of the above reasons)
Registered:
Yes
RMP ID:
1000066801

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

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

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

Public OCA Chemical (in VCM 2, Storage, HAPF 2)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
141.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Rural
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Public OCA Chemical (in VCM 2, Storage, HAPF 2)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Rural
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Public OCA Chemical (in C/A 2)
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:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps

3. Toxics: Alternative release

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

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

Public OCA Chemical (in VCM 1, Storage, HAPF 1)
CBI claimed:
No
Percent weight:
100.0
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:
  • Deluge systems
not considered:
  • Sprinkler systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in VCM 1, Storage, HAPF 1)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Rural
Passive mitigation
considered:
  • Dikes
not considered:
  • 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 C/A Manufacturing)
CBI claimed:
No
Percent weight:
100.0
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:
  • Scrubbers
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
Public OCA Chemical (in VCM 2, Storage, HAPF 2)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Rural
Passive mitigation
considered:
  • Dikes
not considered:
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in VCM 2, Storage, HAPF 2)
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:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in C/A 2)
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:
  • None
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 2, Storage, HAPF 2)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Blast walls
Public OCA Chemical (in VCM 2, Storage, HAPF 2)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Blast walls
Public OCA Chemical (in VCM 2, Storage, HAPF 2)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Blast walls

5. Flammables: Alternative release

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

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

Public OCA Chemical (in VCM 1, Storage, HAPF 1)
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
Public OCA Chemical (in VCM 1, Storage, HAPF 1)
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
Public OCA Chemical (in VCM 1, Storage, HAPF 1)
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
Public OCA Chemical (in Polyvinyl Chloride (PVC))
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
Public OCA Chemical (in VCM 2, Storage, HAPF 2)
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
Public OCA Chemical (in VCM 2, Storage, HAPF 2)
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
Public OCA Chemical (in VCM 2, Storage, HAPF 2)
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

April 13, 2016 at 17:15
ID:
1000051957
NAICS:
Plastics Material and Resin Manufacturing (325211)
Duration:
5 minutes
Chemicals involved:
  • Chlorine
Release events:
Gas release
Weather conditions at time of event
Wind speed:
11.0 miles/h SSE
Temperature:
81.00 ℉
Atmospheric stability:
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:
1
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:
  • Equipment failure
Off-site responders notified:
No, not notified
Changes introduced as a result of the accident:
  • Improved/upgraded equipment

7. Prevention: Program level 3

VCM 1, Storage, HAPF 1, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000070656
Safety Review Date
Aug. 1, 2013, since latest RMP submission
PHA Update Date
Aug. 22, 2012, 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
  • None
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Increased Inventory
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Dec. 1, 2013, since latest RMP submission
Training Review Date
April 25, 2013, since latest RMP submission
Maintenance Review Date
May 1, 2014, since latest RMP submission
Maintenance Inspection Date
July 1, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Jan. 16, 2014
Management of Change Review Date
Dec. 2, 2013
Pre-startup Review Date
Jan. 17, 2014
Compliance Audit Date
March 29, 2012
Compliance Audit Change Completion Date
Dec. 31, 2013
Incident Investigation Date
July 11, 2014
Incident Invest. Change Completion Date
July 11, 2014
Participation Plan Review Date
Nov. 28, 2012
Hot Work Review Date
Dec. 16, 2013
Contractor Safety Review Date
Dec. 4, 2012, since latest RMP submission
Contractor Safety Eval. Date
Aug. 27, 2013, since latest RMP submission
C/A Manufacturing, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000070657
Safety Review Date
May 16, 2012, since latest RMP submission
PHA Update Date
May 16, 2012, 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
  • None
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Dec. 30, 2013, since latest RMP submission
Training Review Date
Oct. 15, 2013, since latest RMP submission
Maintenance Review Date
Jan. 14, 2014, since latest RMP submission
Maintenance Inspection Date
Dec. 30, 2013, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 19, 2013
Management of Change Review Date
Dec. 1, 2012
Pre-startup Review Date
Aug. 1, 2013
Compliance Audit Date
Aug. 11, 2012
Compliance Audit Change Completion Date
Dec. 31, 2013
Incident Investigation Date
June 18, 2013
Incident Invest. Change Completion Date
Jan. 22, 2014
Participation Plan Review Date
Nov. 28, 2012
Hot Work Review Date
Aug. 29, 2012
Contractor Safety Review Date
Nov. 28, 2012, since latest RMP submission
Contractor Safety Eval. Date
Aug. 27, 2013, since latest RMP submission
Tank Farm and Loading, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000070658
Safety Review Date
Feb. 17, 2016, since latest RMP submission
PHA Update Date
Jan. 20, 2014, 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
  • None
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • None Recommended
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Nov. 15, 2015, since latest RMP submission
Training Review Date
March 15, 2015, since latest RMP submission
Maintenance Review Date
June 18, 2015, since latest RMP submission
Maintenance Inspection Date
April 22, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
None
Management of Change Review Date
Dec. 1, 2012
Pre-startup Review Date
Dec. 1, 2012
Compliance Audit Date
Aug. 11, 2012
Compliance Audit Change Completion Date
Dec. 31, 2013
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Nov. 28, 2012
Hot Work Review Date
Aug. 29, 2012
Contractor Safety Review Date
Nov. 28, 2012, since latest RMP submission
Contractor Safety Eval. Date
Aug. 27, 2013, since latest RMP submission
Polyvinyl Chloride (PVC), Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000070659
Safety Review Date
June 25, 2012, since latest RMP submission
PHA Update Date
June 25, 2012, 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
  • None
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 2, 2014, since latest RMP submission
Training Review Date
June 24, 2013, since latest RMP submission
Maintenance Review Date
Jan. 2, 2014, since latest RMP submission
Maintenance Inspection Date
Nov. 13, 2013, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Oct. 22, 2013
Management of Change Review Date
Dec. 1, 2012
Pre-startup Review Date
Dec. 23, 2013
Compliance Audit Date
Aug. 11, 2012
Compliance Audit Change Completion Date
Dec. 31, 2013
Incident Investigation Date
Oct. 13, 2013
Incident Invest. Change Completion Date
Oct. 30, 2013
Participation Plan Review Date
Nov. 28, 2012
Hot Work Review Date
Aug. 29, 2012
Contractor Safety Review Date
Nov. 28, 2012, since latest RMP submission
Contractor Safety Eval. Date
Aug. 27, 2013, since latest RMP submission
VCM 2, Storage, HAPF 2, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000070660
Safety Review Date
Jan. 28, 2013, since latest RMP submission
PHA Update Date
Oct. 1, 2013, 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
  • None
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • None Recommended
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 25, 2013, since latest RMP submission
Training Review Date
Oct. 8, 2012, since latest RMP submission
Maintenance Review Date
May 1, 2014, since latest RMP submission
Maintenance Inspection Date
July 10, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Jan. 15, 2014
Management of Change Review Date
Dec. 2, 2013
Pre-startup Review Date
Jan. 8, 2014
Compliance Audit Date
Aug. 11, 2012
Compliance Audit Change Completion Date
Dec. 31, 2013
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Nov. 28, 2012
Hot Work Review Date
Dec. 16, 2013
Contractor Safety Review Date
Dec. 4, 2013, since latest RMP submission
Contractor Safety Eval. Date
Aug. 27, 2013, since latest RMP submission
C/A 2, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000070661
Safety Review Date
Dec. 21, 2012, since latest RMP submission
PHA Update Date
May 6, 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
  • None
Mitigation Systems
  • Dikes
  • Deluge System
  • Neutralization
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Dec. 30, 2013, since latest RMP submission
Training Review Date
Dec. 15, 2013, since latest RMP submission
Maintenance Review Date
Jan. 14, 2014, since latest RMP submission
Maintenance Inspection Date
Oct. 15, 2013, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Jan. 16, 2014
Management of Change Review Date
Dec. 1, 2012
Pre-startup Review Date
Jan. 8, 2014
Compliance Audit Date
Aug. 11, 2012
Compliance Audit Change Completion Date
Dec. 31, 2013
Incident Investigation Date
Oct. 28, 2013
Incident Invest. Change Completion Date
Dec. 28, 2013
Participation Plan Review Date
Nov. 30, 2013
Hot Work Review Date
Aug. 29, 2012
Contractor Safety Review Date
Nov. 28, 2012, since latest RMP submission
Contractor Safety Eval. Date
Aug. 27, 2013, 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. 29, 2016
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

EXECUTIVE SUMMARY



1.0 APPLICABILITY



The Risk Management Program, required under Section 112 of the 1990 Clean Air Act Amendments, was promulgated on June 20, 1996. The requirements, codified in 40 CFR 68, Subparts A-H, require any facility that has more than a threshold quantity of a regulated substance in a process to comply with the requirements of the Risk Management Program and submit a Risk Management Plan (RMP).



Regulated flammable and toxic substances and their corresponding threshold quantities (TQ) (under 40 CFR 68, Subpart C and Tables 1 through 4 of 68.130) are identified for the purpose of determining applicability. The threshold determination for mixtures of flammable substances is in accordance with 40 CFR 68.115(b)(2). In cases where the listed substance is greater than one percent by weight of the mixture (for a flammable), the entire weight of the mixture is considered in the threshold determination, unless it can be demonstrated that the mixture itself does not have a National Fire Protection Associations (NFPA) flammable hazard rating of 4. Where toxic substances are found in greater than one percent by weight of a mixture, only the weight of the toxic substance is considered in threshold determination. Table 1 lists the regulated substances and the greatest amount held in a single vessel or pipe onsite in a covered process at the Shintech Louisiana, LLC Shintech Plaquemine Plant Complex (Shintech). The Complex currently incorporates the following facilities: Shintech Plaquemine Plant 1 (SPP-1), Shintech Plaquemine Plant 2 (SPP-2), Hydrochloric Acid Production Furnace 1 (HAPF-1), and Hydrochloric Acid Production Furnace 2 (HAPF-2). Shintech is currently in the process of constructing a Hydrochloric Acid Production Furnace 3 (HAPF-3) and a Plaquemine Ethylene Plant 1 (PEP-1).



Table 1

Regulated RMP Chemical

Type

CAS Number

RMP TQ (in lbs)

Total Quantity Capable of Being Present in a Process (in lbs)

Location of Process

Chlorine


Toxic

7782-50-5

2,500

4622

C/A unit

Chloroform

Toxic

67-66-3

20,000

231,971

VCM unit

Ethylene

Flammable

74-85-1

10,000

2,765

VCM unit

Hydrogen Chloride

Toxic

7647-01-0

5,000

200,458

VCM unit

Propylene

Flammable

115-07-1

10,000

147,701

VCM unit

Vinyl Chloride

Flammable

75-01-4

10,000

8,505,590

VCM unit



1.1

Determination of Program Applicability



Each covered process regulated under the Risk Management Program is assigned as either Program 1, 2, or 3 and must meet the applicable requirements of the assigned program. Program 1 processes are those that meet the following; those that do not comply are assigned Program 2 or 3:

1) Have not had an accidental release in the past 5 years

2) The distance to a toxic or flammable endpoint is less than the distance to any public receptor; and

3) Emergency response has been coordinated with local emergency response organizations



The Shintech Plaquemine Plant Complex is assigned Program 3 because it does not meet the criteria stated in number 2 and is subject to OSHA's PSM standard under federal or state OSHA programs which imposes OSHA's PSM standard as the prevention program as well as additional hazard assessment, management, and emergency response requirements.



1.2 General Requirements for a Program 3 Facility:



According to CFR 68.12 General Requirements, the owner or operator of a facility eligible for program 3 shall:

(A) Submit a single RMP, to include a registration that reflects all covered processes (CFR 68.150-68.185)

(B) Develop and implement a management system (CFR 68.15)

(C) Conduct a hazard assessment (CFR 68.20-68.42)

(D) Implement the prevention requirements (CFR 68.65-68.87)

(E) Develop and implement an emergency response program (CFR 68.90-68.95)

(F) Submit as part of the RMP the data on prevention program elements for Program 3 processes (CFR 68.175)



2.0 EXECUTIVE SUMMARY:



The owner/operator shall provide in an executive summary of the R
MP: The accidental release prevention and emergency response policies at the facility; the stationary source and regulated substances handled; the general accidental release prevention program and chemical-specific prevention steps; the five year accident history; the emergency response program; and planned changes to improve safety.



Shintech currently owns and operates the Shintech Plaquemine Plant Complex located near Plaquemine, Louisiana. The facility is designed as a vertically integrated polyvinyl chloride (PVC) manufacturing facility that also produces intermediate products, including chlorine (and caustic soda as a byproduct), ethylene dichloride, vinyl chloride monomer, and hydrochloric acid.This facility has been designed in a manner that minimizes the potential for accidental releases. Shintech is committed to operating this facility in a manner that is safe for the plant workers, the public, and the environment. Shintech has many years of experience and an excellent environmental and safety track record in the production of polyvinyl chloride. 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, and to limit adverse effects on the physical environment in which its activities are carried out. Shintech has established systems to help ensure safe operation of the processes at this facility. One part of these systems is a risk management program (RMP) that helps manage the risks at the facility and that complies with the requirements of the Environmental Protection Agency's (EPA's) rule 40 CFR part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule), and the Louisiana Department of Environmental Quality (LDEQ) regulation (LAC 33:III.Chapter 59). One of the requirements of the RMP rule is to submit a risk management plan (RMP) describing the risk management program at the facility. An initial RMP for the facility was
submitted to EPA via the RMP Submit Program in June 2008. According to LAC 33:III.Chapter.59, the registration shall also be submitted to the LDEQ within 60 days of the stationary source becoming subject to this regulation. Shintech registered with LDEQ in June 2008. If anything changes within the registration, it will be submitted to LDEQ within 60 days of the change. Likewise, Shintech will update its RMP via RMP Submit and submit the changes to the EPA within 6 months of the change.



This document is intended to satisfy the RMP executive summary requirement of the RMP rule and to provide the public with a description of the risk management program at the facility.



2.1 Accidental Release Prevention and Emergency Response Policies



Shintech is committed to minimizing potential risks to the general public, to the facility employees, and to the environment. A fundamental part of this commitment is the prevention of accidental releases of hazardous substances in and around the facility. The facility utilizes engineering controls, inspection programs, and detailed procedures as a means to prevent accidental releases. In the event of a release, the facility has well-trained emergency response teams to contain, mitigate, monitor, and stop the release. The facility has fully staffed and trained emergency response teams for fire fighting and emergency rescue. In addition to handling the release, the facility is also participating in established communication systems to alert the community in the event of a significant release. Through the coordination with the local emergency planning commission (LEPC), the facility has the ability to provide emergency notification to the local community through cable override systems, radio broadcasts, and/or through an automated telephone notification system.





2.1.1 Develop and Implement a Management System (CFR 68.15)



The owner/operator shall develop a management system to oversee the implementation of risk management pro
gram elements and assign a qualified person or position that has the overall responsibility for the development, implementation, and integration of the program. The names and positions of these individuals shall be documented and the lines of authority shall be defined through an organizational chart or equivalent document.



The Shintech Environmental Manager is responsible for the development and implementation of the risk management program for the facility. However, the specific responsibilities for certain aspects of that program will be delegated to other personnel who will report either directly or through other management personnel to the Environmental Manager. Similarly, responsibility for the RMP offsite consequence analysis and five year accident history has been delegated to the Environmental Supervisor. The Safety/Security Supervisor is responsible for Emergency Response and Safety and Data Sheets (SDS) and Process Safety Information. Furthermore, it is the facility's policy that safe operation is part of everyone's job; therefore, many other site personnel will also be involved in RMP activities on an ongoing basis.



2.2 Facility Regulated Substances



See Table 1 for list of regulated RMP substances that are above threshold in a process at the facility.



2.3 Accidental Release Prevention Program



Because the facility is also subject to the Occupational Safety and Health Administration (OSHA) process safety management (PSM) standard, and because the OSHA PSM requirements are very similar to the EPA RMP requirements, this summary addresses each of the OSHA PSM elements. The PSM program at this facility has been extended by the facility, where necessary, to satisfy EPA's Program Level 3 accident prevention program requirements.



2.3.1 Employee Participation



The owner/operator shall create a written plan of action regarding the implementation of employee participation required by the Program 3 Prevention Program.



The owner/operator shall c
onsult with employees and their representatives on the conduct and development of process hazards analyses and on the development of other elements of process safety management.



The owner/operator shall provide to employees and their representatives access to process hazard analyses and to all other information.



As employee participation is required by both PSM and RMP, Shintech will encourage employees to participate in all facets of process safety management and accident prevention. Specific ways that employees can be involved in the accident prevention program will be documented in an employee participation plan that will be maintained at the facility and will address each accident prevention program element.



2.3.2 Process Safety Information



The owner/operator shall complete a compilation of written process safety information before conducting any process hazard analysis. This is to enable the owner/operator and employees to identify and understand the hazards posed by those processes involving regulated substances. It shall include hazards of the regulated substances used or produced(toxicity information, permissible exposure limits, physical /reactivity/and corrosive data, thermal and chemical stability data, hazardous effects of inadvertent mixing of different materials that could foreseeably occur), information pertaining to the technology of the process (block flow diagram, process chemistry, maximum intended inventory, safe upper and lower limits for temperature/ pressures/flows/etc, evaluation of consequences and deviations), and information pertaining to the equipment in the process(materials of construction, piping and instrument diagrams, electrical classification, relief system design and design basis, ventilation system design, design codes and standards employed, material and energy balances for processes built after June 21, 1999, safety systems). The owner/operator shall document that equipment complies with recognized and generally acc
epted good engineering practices and if it is designed with practices that are no longer in use, determine and document that the equipment is designed, maintained, inspected, tested and operating in a safe manner.



The facility will keep a variety of technical documents used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. These documents will also need to be gathered for the Process Hazard Analysis. Specific departments within the facility are assigned responsibility for maintaining and updating process safety information.



Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in safety data sheets (SDSs). This information is supplemented by documents that specifically address known concerns and hazards. In addition, the facility has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in the operation manuals. Shintech will ensure that the process is maintained within these limits by using process controls and monitoring instruments, operating procedures, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems).



Shintech will also maintain numerous 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 ensure that safety features in the process are not compromised.



2.3.3 Process Hazard Analysis



The owner/operato
r shall perform an initial process hazard analysis that is appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process. The owner/operator shall determine and document the priority order for conducting process hazard analyses based on a rationale which includes such considerations as extent of the process hazards, number of potentially affected employees, age of the process, and operating history of the process. Those completed to comply with PSM (29 CFR 1910.199(e)) are acceptable as initial process hazards analyses, yet they shall be updated and revalidated based on their completion date.



The owner/operator shall use one or more of the following methods to determine and evaluate the hazards of the process being analyzed:

i. What-If;

ii. Checklist;

iii. What-If/Checklist;

iv. Hazard and Operability Study (HAZOP);

v. Failure Mode and Effects Analysis (FMEA);

vi. Fault Tree Analysis; or

vii. An appropriate equivalent method.



The process hazard analysis shall address:

i. The hazards of the process;

ii. Identification of any previous incident which had a likely potential for catastrophic consequences;

iii. Engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of releases;

iv. Consequences of failure of engineering and administrative controls;

v. Stationary source sitting;

vi. Human factors;

vii. A qualitative evaluation of a range of the possible safety and health effects of failure of controls



The process hazard analysis shall be performed by a team with expertise in engineering and process operations (one member must have knowledge and experience to the specific process and one must be knowledgeable in the process methodology).



The owner/operator shall establish as system to promptly address the team's findings and recommendations; assure that the rec
ommendations are resolved in a timely manner and the resolutions are documented; document what actions are to be taken and complete them as soon as possible; develop a written schedule of when these actions are to be completed; communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations/actions.



At least every five years after the completion of the initial analysis, the process hazard analysis shall be updated and revalidated by a team (complying with (d) of this section). Updated and revalidated process hazard analyses completed to comply with PSM (29 CFR 1910.119(e)) are acceptable.



The owner/operator shall retain process hazard analyses and updates or revalidations for each process, as well as the documented resolution for the life of the process.



The facility has a comprehensive process hazard analysis (PHA) program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, the covered process is systematically examined to identify hazards to ensure that adequate controls are in place to manage those hazards.



The facility primarily uses the What If, HAZOP, and Fault Mode and Effects Analysis techniques to perform these evaluations. These analyses are conducted using a team of people who have operating, maintenance, experience, and engineering 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 necessary.



To help ensure that the process controls and/or process hazards do not deviate significantly from the original design safety features, the facility will periodically update and revalidate its process hazard analyses. These periodic reviews are conducted at least every five years and will be conducted at this frequency until the process is no longer operating. The resu
lts and recommendations from these updates are documented and retained.



2.3.4 Operating Procedures



The owner/operator shall develop and implement written operating procedures that provide clear instructions for safety conducting activities involved in each covered process consistent with the process safety information and shall address at least the following elements:

i. Steps for each operating phase: initial startup, normal operations, temporary operations, emergency shutdown(include assignment of responsible operators), emergency operations, normal shutdown, and startup following a turnaround or after an emergency shutdown;

ii. Operating limits: consequences of deviation and how to correct/avoid deviation

iii. Safety and health considerations: Properties and hazards of chemicals used, precautions necessary to prevent exposure, control measures to be taken if physical contact or airborne exposure, quality control for raw materials and control of hazardous chemical inventory levels, and any special/unique hazards.

iv. Safety systems and their functions.

Operating procedures shall be readily accessible to employees.



Operating procedures shall be reviewed as necessary and shall be updated according to any change. The owner/operator shall certify annually that they are current and accurate.



The owner/operator shall develop and implement safe work practices applicable to all employees to provide for the control of hazards during operations.



The facility 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 maintained current by revising them as necessary to reflect changes made to the process. In addition, the facility's
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 and for other personnel to use as necessary to safely perform their job tasks.



2.3.5 Training



Initial training: Each employee shall be trained in an overview of the process and in the operating procedures prior to becoming involved in the process. Training shall empha safety and health hazards, emergency operations, and safe work practices applicable to job tasks.

Refresher training: Each involved employee shall have refresher training at least every three years or more frequently as determined by the operator/owner.

Documentation: The owner/operator shall ascertain that each employee involved has received and understood the training and keep a record which contains the identities of employees, dates of training, and the means used to verify that the employee understands the training.



To complement the written procedures for process operations, the facility has implemented a training program for all employees involved in operating a process. All operations employees receive basic training in the facility operations. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. As required per 40 CFR 68.54, this refresher training is conducted every three years or more often if determined to be necessary. Operators are given the opportunity to take part in more frequent refresher training if desired. This training is documented for each operator, including the means used to verify that the operator understood the training.



2.3.6 Contractors



The owner/operator shall obtain and evaluate information regarding the safety performance and programs of contractors performing maintenance or repair, turnaround, major renovat
ion, or specialty work on or adjacent to a covered process. The owner/operator shall inform the contract owner/operator of the known potential fire, explosion or toxic release hazards and shall explain the Emergency Response Plan. The owner/operator shall implement safe work practices and periodically evaluate the performance of the contractor in fulfilling the following responsibilities:

i. All employees are trained in the work practices necessary to safely perform his/her job.

ii. All employees are to know potential accidents and the applicable provisions of the emergency action plan.

iii. Training is understood and documented in a record with employee identities, dates of training, and the means used.

iv. Each employee follows the safety rules, including the safe work practices.

v. The contract employee advises the owner/operator of any unique hazards presented by their work or any hazards found.



The facility uses contractors to supplement its work force throughout the year as needed. Because some contractors work on or near process equipment, the facility has procedures in place to ensure that contractors perform their work in a safe manner, possess the appropriate knowledge and skills needed, are trained of the hazards in the workplace, and are aware of the procedures to take in the event of an emergency. 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 prior to their beginning work. In addition, Shintech evaluates contractor safety programs and performance during the selection of a contractor. Shintech management personnel periodically monitor contractor performance to insure that contractors are fulfilling their safety obligations.



2.3.7 Pre-Startup Safety Reviews



The owner/operator shall perform a pre-startup safety review for new stationary sources and for modified stationa
ry sources when the modification is significant enough to require a change in the process safety information.



The pre-startup safety review shall confirm that prior to the introduction of regulated substances to a process: construction and equipment is in accordance with design specifications; safety, operating, maintenance, and emergency procedures are in place and are adequate; process hazard analyses have been performed on new stationary sources and any recommendations have been resolved and implemented; modified stationary sources meet the requirements contained in management of change; and training of each involved employee has been completed.



Shintech personnel conduct a pre-startup safety review for any new facility or facility modification that requires a change in the process safety information (not required for replacement in kind). The purpose of the review is to ensure that safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. A review involves field verification of the construction and serves a quality assurance function.



2.3.8 Mechanical Integrity



The following shall apply to: pressure vessels and storage tanks; piping systems; relief and vent systems and devices; emergency shutdown systems; controls; and pumps.



Written Procedures: The owner/operator shall establish and implement written procedures to maintain the ongoing integrity of process equipment.



Training for process maintenance activities: The owner/operator shall train each employee involved in maintaining the on-going integrity of process equipment in an overview of that process and its hazards and in the procedures applicable to the employee's job tasks to assure that the employee can perform the job tasks in a safe m
anner.



Inspection and testing:

i. Inspections and tests shall be performed on process equipment and shall follow recognized and generally accepted good engineering practices. Inspections shall also be performed to assure the equipment is installed properly.

ii. The frequency shall be consistent with applicable manufacturers' recommendations and good engineering practices, or more frequently if necessary.

iii. The owner/operator shall document each inspection and test that has been performed on process equipment. The documentation shall identify the date of the inspection or test, the name of person who performed it, the serial number of equipment, and a description of the inspection and results.



Equipment deficiencies: The owner/operator shall correct deficiencies in equipment that are outside acceptable limits before further use or in a safe and timely manner.



Quality assurance: The owner/operator shall assure that equipment is suitable for the process application for which it will be used. The owner/operator shall assure that maintenance materials, spare parts and equipment are suitable for the process application for which they will be used.



Shintech personnel has well-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. Additionally, Shintech has developed and maintains a mechanical integrity list of these items that are critical to the safety of the process. Furthermore, the basic aspects of Shintech's mechanical integrity program include (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process equipment.



Shintech maintenance personnel receive training on (1) an overview o
f the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their job in a safe manner. Written procedures help ensure that work is performed in a consistent manner and provide a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits. 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. The facility incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made.



2.3.9 Safe Work Practices



The facility has safe work practices in place to help ensure 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 help ensure that operations and maintenance activities are performed safely.



2.3.10 Management of change:



The owner/operator shall establish and implement written procedures to manage changes to proc
ess chemicals, technology, equipment, and procedures; and, changes to stationary sources that affect a covered process.



The following considerations shall be addressed prior to any change:

i. The technical basis for the proposed change;

ii. Impact of change on safety and health;

iii. Modifications to operating procedures;

iv. Necessary time period for the change; and,

v. Authorization requirements for the proposed change.



All affected employees shall be informed of, and trained in, the change prior to start-up of the process or affected part of the process.



The facility has a comprehensive system to manage changes to processes. 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, and equipment information, as well as procedures are updated to incorporate these changes. In addition, operating and maintenance personnel are provided with any necessary training on the change.



2.3.11 Incident investigation:



The owner/operator shall investigate each incident which resulted in, or could have resulted in, a catastrophic release of a regulated substance.



An incident investigation shall be initiated as promptly as possible, but no later than 48 hours following the incident.



An incident investigation team shall be established and consist of at least one knowledgeable person in the process involved.



A report shall be prepared, including at least: the date of incident, date investigation began, description of incident, factors leading to incident, and recommendations.



The owner/operator shall establish as system to promp
tly address and resolve the incident report findings and recommendations. Resolutions and corrective actions shall be documented.



The report shall be reviewed with all affected personnel whose job tasks are relevant to the incident findings including contract employees where applicable.



Incident reports shall be retained for five years.



Shintech personnel will promptly investigate all incidents that result in, or reasonably could result in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation will be to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. Incident investigation reports will be retained for at least five years so that the reports can be reviewed during future PHAs and PHA revalidations.



2.3.12 Compliance audits:



The owner or operator shall certify that they have evaluated compliance with the provisions of this subpart at least every three years to verify that procedures and practices developed under this subpart are adequate and are being followed.



The compliance audit shall be conducted by at least one person knowledgeable in the process.



A report of the findings of the audit shall be developed.



The owner or operator shall promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected.



The owner or operator shall retain the two (2) most recent compliance audit reports.



To help ensure that the accident prevention program is functioning properly, the facility will periodically conduct audits to confirm the procedures and practices required by the accident prevention program are being implemented. Compliance audits will be conducted at least every three years. The final resolution of each finding will be documented, and recent audit reports will be retained.



2.3.13 Chemical-Specific Prevent
ion Steps



The process at the facility has 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.



2.3.14 Additional Safety Features



In addition to the accident prevention program activities, the facility has many safety features to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of a release. The following types of safety features are used in various processes:



* Release detection

* Area ambient air monitoring system.

* Automated control systems

* Process relief valves to prevent overpressure damage to equipment;

* Scrubbers to neutralize chemical releases;

* Manual and automatic valves to permit isolation of vessels;

* Automated shutdown systems for specific process parameters (e.g., high level, high temperature);

* Dikes to contain liquid releases;

* Release mitigation systems (water spray systems);

* Fire suppression and extinguishing systems; and

* Trained emergency response personnel.



2.3.15 Hot Work Permit:



The owner/operator shall issue a hot work permit for hot work operations conducted on or near a covered process.



The permit shall document that the fire prevention and protection requirements in 29 CFR 1910.252(a) have been implemented prior to beginning the hot work operations; it shall indicate the dates authorized for hot work; and identify the object on which hot work is to be performed. The permit shall be kept on file until completion of the hot work operations.



Shintech complies with the requirements of hot work operations and obtains the necessary hot work permit per each hot work event.



2.4 Five Year Accident History:



The owner/operator must include the five-year accident history in the RMP
. The history must include all accidental releases from covered processes that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. For each accidental release, the following shall be reported: date, time, approximate duration; chemicals released; estimated quantity released in pounds or percentage concentration by weight of the release regulated toxic substance in the liquid mixture; 5 or 6 digit NAICS code corresponding to the process; type of release event; weather conditions (if known); offsite impacts; on-site impacts; initiating event and contributing factors; whether offsite responders were notified; and operational or process changes that resulted from investigation of the release. The level of accuracy can be estimated to two significant figures.



The facility does not have any accidental releases from covered processes that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage within the previous five years.



2.5 Emergency Response Program



The owner/operator shall develop and implement an emergency response program for the purpose of protecting public health and the environment. Such program shall include:

1) An emergency response plan, to be maintained at the stationary source and contain:

i. Procedures for informing the public and local agencies about accidental releases

ii. Documentation of proper first-aid and emergency medical treatment necessary to treat accidental human exposures; and

iii. Procedures and measures for emergency response after an accidental release.

2) Procedures for the use of emergency response equipment and for its inspection, testing, and maintenance

3) Training for all employees in relevant procedures; and

4) Procedures to review and update, as approp
riate, the emergency response plan to reflect changes at the stationary source and ensure that employees are informed of changes.



A written plan that complies with other Federal contingency plan regulations or is consistent with the approach in the National Response Team's Integrated Contingency Plan Guidance and that, among other matters, includes the elements listed above, shall satisfy the requirements of this section if the owner or operator also complies with the paragraph below.



The emergency response plan shall be coordinated with the community emergency response plan developed under 42 U.S.C. 11003. Upon request of the local emergency planning committee or emergency response officials, the owner or operator shall promptly provide to the local emergency response officials information necessary for developing and implementing the community emergency response plan.



The facility maintains a written Emergency Response Plan (ERP), which aims to protect employees, public health, and the environment. The purpose of the ERP is to minimize potential adverse impacts on the facility and surrounding areas in the event of an emergency situation. The plan consists of procedures for responding to such emergencies as fires, explosions, hazardous gas or liquid releases, natural disasters, and terrorist threats. The plan addresses all aspects of emergency response including coordination with mutual aid organizations, timely notification of authorities, maintenance of proper documentation, and guidelines for compliance with applicable government regulations. Furthermore, the facility has procedures that address proper use, maintenance, inspection, and testing of emergency response equipment. Based on job description, employees receive safety and process control training to instruct them in proper emergency response procedures. The overall ERP for the facility is coordinated with the Iberville Parish LEPC.



In order to keep the plan up to date, the emergency response
procedures are reviewed annually. Necessary revisions are made and distributed to the plan holders by the safety department. Affected personnel are trained in regards to the changes in the ERP.



2.6 Planned Changes to Improve Safety



The facility constantly strives to improve the safety of its operations through periodic safety reviews, the incident investigation program, and a program soliciting safety suggestions from the workers.



SHINTECH LOUISIANA, LLC