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Flopam, Inc.

Parent Companies:
SNF Holding Company
EPA Facility ID:
100000213217
Other ID:
7076WFLPMN2679H
Facility DUNS:
214184
Parent Company DUNS:
878930965

Location:

Address:
26790 Hwy. 405
Plaquemine, LA 70764
County:
IBERVILLE
Lat / Long:
30.271, -91.145 (Get map)
Method:
Interpolation - Satellite
Description:
Plant Entrance (General)
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
Flopam Inc.
Phone:
(225) 687-2917
Address:
26790 Hwy. 405
Plaquemine, LA 70764
Foreign Address:

Person responsible for RMP implementation:

Name:
Tim Kane
Title:
EHS Manager

Emergency contact:

Name:
Gary Dismukes
Title:
Safety & Security Manager
Phone:
(225) 692-7245
24-hour phone:
(225) 692-7266
Ext or PIN:
2256927200

Other contacts:

Facility (or company) email:
Facility phone:
Facility (or company) URL:
snf.us

Safety:

Local Emergency Planning Committee:
Iberville Parish LEPC
Full-Time Equivalent Employees:
242
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
1280-00141-V5
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Aug. 14, 2013
Inspecting Agency:
EPA
Using Predictive Filing:
No

Processes:

Acrylamide Process
RMP ID:
1000077035
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Acrylonitrile [2-Propenenitrile]
107-13-1
6,900,000
No
Public OCA Chemical
0
No
ATBS Process
RMP ID:
1000077037
CBI claimed:
No
Program Level:
3
NAICS:
All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Chemical name
CAS#
Quantity (lbs.)
CBI
Acrylonitrile [2-Propenenitrile]
107-13-1
2,000,000
No
2-Methylpropene [1-Propene, 2-methyl-]
115-11-7
820,000
No
Oleum (Fuming Sulfuric acid) [Sulfuric acid, mixture with sulfur trioxide]
8014-95-7
1,125,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
GESI
Address:
810 Franklin Court Suite A
Marietta, GA 30067
Foreign Address:

Phone:
(770) 919-9552

Latest RMP Submission:

Date:
Jan. 16, 2017
Type:
Resubmission
Reason:
Regulated substance present above TQ in new (or previously not covered) process (40 CFR 68.190(b)(4))
Registered:
Yes
RMP ID:
1000061553

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 Acrylamide Process)
CBI claimed:
No
Percent weight:
99.6
Physical state:
Liquid
Model used:
Areal Locations of Hazardous Atmospheres (ALOHA)
Release duration (mins):
60.00
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 Acrylamide Process)
CBI claimed:
No
Percent weight:
99.6
Physical state:
Liquid
Model used:
Areal Locations of Hazardous Atmospheres (ALOHA)
Wind speed (meters per sec):
2.60
Stability class:
B
Topography:
Rural
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
Public OCA Chemical (in ATBS Process)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Liquid
Model used:
Areal Locations of Hazardous Atmospheres (ALOHA)
Wind speed (meters per sec):
2.60
Stability class:
B
Topography:
Rural
Passive mitigation
considered:
  • Containment pad and pit
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Emergency shutdown
  • Containment pad and pit
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers

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 ATBS Process)
CBI claimed:
No
Model used:
Areal Locations of Hazardous Atmospheres (ALOHA)
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 ATBS Process)
CBI claimed:
No
Model used:
Areal Locations of Hazardous Atmospheres (ALOHA)
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Excess flow valve

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

Acrylamide Process, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000064792
Safety Review Date
Feb. 23, 2016, since latest RMP submission
PHA Update Date
Feb. 23, 2016, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
  • Water Curtain
  • Enclosure
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
Oct. 11, 2016, since latest RMP submission
Training Review Date
Sept. 30, 2016, since latest RMP submission
Maintenance Review Date
Sept. 19, 2016, since latest RMP submission
Maintenance Inspection Date
March 2, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 25, 2016
Management of Change Review Date
Jan. 20, 2016
Pre-startup Review Date
June 17, 2015
Compliance Audit Date
June 25, 2015
Compliance Audit Change Completion Date
Nov. 30, 2016
Incident Investigation Date
Aug. 29, 2016
Incident Invest. Change Completion Date
March 31, 2017
Participation Plan Review Date
June 15, 2015
Hot Work Review Date
Aug. 24, 2015
Contractor Safety Review Date
Oct. 2, 2015, since latest RMP submission
Contractor Safety Eval. Date
July 26, 2016, since latest RMP submission
ATBS Process, All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Prevention Program ID:
1000064793
Safety Review Date
Jan. 9, 2017, since latest RMP submission
PHA Update Date
Jan. 9, 2017, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Fire Walls
  • Blast Walls
  • Deluge System
  • Water Curtain
  • Enclosure
  • Neutralization
Monitoring Systems
  • Process Area
Changes since PHA
  • Increased Inventory
  • Process Parameters
  • Process Controls
  • Process Detection
  • Mitigation Systems
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Oct. 11, 2016, since latest RMP submission
Training Review Date
Jan. 12, 2017, since latest RMP submission
Maintenance Review Date
Sept. 19, 2016, since latest RMP submission
Maintenance Inspection Date
March 2, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Oct. 10, 2016
Management of Change Review Date
Jan. 20, 2016
Pre-startup Review Date
Jan. 6, 2017
Compliance Audit Date
None
Compliance Audit Change Completion Date
None
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
June 15, 2015
Hot Work Review Date
Aug. 24, 2015
Contractor Safety Review Date
Oct. 2, 2015, since latest RMP submission
Contractor Safety Eval. Date
Dec. 12, 2016, 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:
Sept. 30, 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

General Executive Summary



SNF FLOPAM PLAQUEMINE FACILITY



1. Accidental Release Prevention and Emergency Response Policies



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



2. The Stationary Source and the Regulated Substances Handled



Our facility's primary activities encompass the manufacture of acrylamide, polyacrylamide, polyacrylamide emulsion, and ATBS. We have three regulated substances above the RMP threshold quantity present at our facility. The regulated toxic substances are acrylonitrile and oleum. The regulated flammable substance is isobutylene. Acrylonitrile is used as a feedstock in the manufacture of acrylamide. Acrylonitrile, oleum, and isobutylene are used to manufacture ATBS product. The maximum quantities of acrylonitrile, oleum, and isobutylene stored on-site are 8,900,000 pounds, 1,125,000 pounds, and 820,000 pounds, respectively.



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



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



Process Safety Information (PSI)



SNF Flopam Plaquemine maintains a detailed record of process safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes.



Process Hazard
Analysis (PHA)



Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled effectively. A HAZOP methodology is used to carry out these analyses. The studies are undertaken by a team of qualified personnel with expertise in engineering, process operations, and environmental, health and safety, and will be revalidated at a regular interval of five years. Findings related to the hazard analysis are addressed in a timely manner. Layer of Protection Analysis (LOPA) and the Event Tree method are also performed on critical nodes within the HAZOP. A parameter of total node failure was added to the HAZOPs nodes to ensure the worst case was correctly identified.



Operating Procedures



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



Training



SNF Flopam Plaquemine has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training will be provided at least every three years and more frequently at intervals determined by employee input.



Mechanical Integrity



SNF Flopam Plaquemine will carry out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others: pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Equipment defi
ciencies identified by the maintenance checks are corrected in a safe and timely manner.



Management of Change



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



Pre-startup Reviews



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



Incident Investigation



SNF Flopam Plaquemine promptly investigates incidents that have resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as corrective actions to prevent the release from reoccurring.



Employee Participation



We believe that process safety management and accident prevention is a team effort. Employees will participate in the elements of PSM and RMP. In the startup of this plant we included a high percentage of operations staff in the PHA process. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to information created as part of the facility's implementation of the RMP rule.



Contractors



On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the c
ontractor is carried out. SNF Flopam Plaquemine has a strict policy of informing the contractors of known potential hazards related to the contractor's work and the processes. Contractors are also informed of emergency response duties in the event of a release or incident.



4. Five-year Accident History



The SNF Flopam Plaquemine Plant has had no RMP incidents in the past five years. There are no incidents to report.



5. Emergency Response Plan



SNF Flopam Plaquemine has a written emergency response plan to deal with accidental releases of hazardous materials. The plan addresses aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public.

The plan is promptly updated to reflect pertinent changes taking place within our processes that would require a modified emergency response. Emergency responders are trained or drilled on a quarterly basis.



Iberville Parish Office of Emergency Preparedness is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified.