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Eco Services Operations, Corp

Parent Companies:
EPA Facility ID:
100000227523
Other ID:
Facility DUNS:
0

Location:

Address:
1301 Airline Hwy
Baton Rouge, LA 70807
County:
EAST BATON ROUGE
Lat / Long:
30.509, -91.188 (Get map)
Method:
Interpolation - Photo
Description:
Plant Entrance (General)
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Eco Services Operations Corp
Phone:
(844) 812-1812
Address:
2002 Timberloch Place
Suite 300
The Woodlands, TX 77380
Foreign Address:

Person responsible for RMP implementation:

Name:
Daniel Tate
Title:
Plant Manager

Emergency contact:

Name:
Robert Musselman
Title:
Emergency Response Coordinator
Phone:
(225) 359-3715
24-hour phone:
(225) 241-3121
Ext or PIN:

Other contacts:

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

Safety:

Local Emergency Planning Committee:
East Baton Rouge Parish LEPC
Full-Time Equivalent Employees:
120
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
0840-00033-06
OSHA Star/Merit Ranking
Yes
Last Safety Inspection Date:
Nov. 7, 2014
Inspecting Agency:
EPA
Using Predictive Filing:
Yes

Processes:

Logistics
RMP ID:
1000061462
CBI claimed:
No
Program Level:
3
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Chemical name
CAS#
Quantity (lbs.)
CBI
Oleum (Fuming Sulfuric acid) [Sulfuric acid, mixture with sulfur trioxide]
8014-95-7
12,040,000
No
Public OCA Chemical
0
No
Unit 2 Acid Plant
RMP ID:
1000061463
CBI claimed:
No
Program Level:
3
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Chemical name
CAS#
Quantity (lbs.)
CBI
Oleum (Fuming Sulfuric acid) [Sulfuric acid, mixture with sulfur trioxide]
8014-95-7
205,820
No
Public OCA Chemical
0
No
Hazardous Waste Treatment
RMP ID:
1000061464
CBI claimed:
No
Program Level:
3
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
100,000
No
Ethyl ether [Ethane, 1,1'-oxybis-]
60-29-7
50,000
No
Isopentane [Butane, 2-methyl-]
78-78-4
30,000
No
Flammable Mixture
00-11-11
225,000
No
Ethyl mercaptan [Ethanethiol]
75-08-1
25,000
No
Propionitrile [Propanenitrile]
107-12-0
500,000
No
Carbon disulfide
75-15-0
230,000
No
Epichlorohydrin [Oxirane, (chloromethyl)-]
106-89-8
30,000
No
Methyl mercaptan [Methanethiol]
74-93-1
25,000
No
Toluene diisocyanate (unspecified isomer) [Benzene, 1,3-diisocyanatomethyl-]
26471-62-5
80,000
No
Vinyl acetate monomer [Acetic acid ethenyl ester]
108-05-4
230,000
No
Allyl alcohol [2-Propen-1-ol]
107-18-6
90,000
No
Acetaldehyde
75-07-0
37,500
No
Acrylonitrile [2-Propenenitrile]
107-13-1
50,000
No
Hydrogen sulfide
7783-06-4
14,000
No
Isopropylamine [2-Propanamine]
75-31-0
175,000
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
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
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
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
July 29, 2016
Type:
Resubmission
Reason:
Voluntary update (not described by any of the above reasons)
Registered:
Yes
RMP ID:
1000049027

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 Hazardous Waste Treatment)
CBI claimed:
No
Percent weight:
97.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
6060.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • Dikes
not considered:
  • 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 Unit 2 Acid Plant)
CBI claimed:
No
Percent weight:
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
  • Sumps
not considered:
  • Enclosures
  • Berms
  • Drains
Active mitigation
considered:
  • Deluge systems
  • Neutralization
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Water curtain
  • Excess flow valve
  • Flares
  • Scrubbers
Public OCA Chemical (in Hazardous Waste Treatment)
CBI claimed:
No
Percent weight:
97.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
  • Sumps
not considered:
  • Enclosures
  • Berms
  • Drains
Active mitigation
considered:
  • Deluge systems
  • Flares
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Scrubbers
Public OCA Chemical (in Hazardous Waste Treatment)
CBI claimed:
No
Percent weight:
85.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
  • Sumps
not considered:
  • Enclosures
  • Berms
  • Drains
Active mitigation
considered:
  • Deluge systems
  • Flares
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Scrubbers
Public OCA Chemical (in Hazardous Waste Treatment)
CBI claimed:
No
Percent weight:
60.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
  • Sumps
not considered:
  • Enclosures
  • Berms
  • Drains
Active mitigation
considered:
  • Deluge systems
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
Public OCA Chemical (in Hazardous Waste Treatment)
CBI claimed:
No
Percent weight:
10.0
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
  • Sumps
not considered:
  • Enclosures
  • Berms
  • Drains
Active mitigation
considered:
  • Deluge systems
  • Flares
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Scrubbers
Public OCA Chemical (in Hazardous Waste Treatment)
CBI claimed:
No
Percent weight:
40.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
  • Sumps
not considered:
  • Enclosures
  • Berms
  • Drains
Active mitigation
considered:
  • Deluge systems
  • Flares
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Scrubbers
Public OCA Chemical (in Hazardous Waste Treatment)
CBI claimed:
No
Percent weight:
95.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
  • Sumps
not considered:
  • Enclosures
  • Berms
  • Drains
Active mitigation
considered:
  • Deluge systems
  • Flares
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Scrubbers
Public OCA Chemical (in Hazardous Waste Treatment)
CBI claimed:
No
Percent weight:
90.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
  • Sumps
not considered:
  • Enclosures
  • Berms
  • Drains
Active mitigation
considered:
  • Deluge systems
  • Flares
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Scrubbers
Public OCA Chemical (in Hazardous Waste Treatment)
CBI claimed:
No
Percent weight:
40.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
  • Sumps
not considered:
  • Enclosures
  • Berms
  • Drains
Active mitigation
considered:
  • Deluge systems
  • Flares
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Scrubbers
Public OCA Chemical (in Hazardous Waste Treatment)
CBI claimed:
No
Percent weight:
6.0
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
  • Sumps
not considered:
  • Enclosures
  • Berms
  • Drains
Active mitigation
considered:
  • Deluge systems
  • Flares
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • 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 Hazardous Waste Treatment)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • dikes
not considered:
  • Blast walls

5. Flammables: Alternative release

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

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

Public OCA Chemical (in Hazardous Waste Treatment)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • Dikes
not considered:
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Water curtain
  • Excess flow valve

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

Logistics, Other Basic Inorganic Chemical Manufacturing (32518)
Prevention Program ID:
1000051109
Safety Review Date
Aug. 15, 2014, since latest RMP submission
PHA Update Date
Feb. 4, 2013, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Runaway reaction
  • Overpressurization
  • Corrosion
  • Overfilling
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Purge System
Mitigation Systems
  • Dikes
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
Oct. 31, 2014, since latest RMP submission
Training Review Date
June 9, 2014, since latest RMP submission
Maintenance Review Date
Aug. 19, 2009, since latest RMP submission
Maintenance Inspection Date
Sept. 6, 2013, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Oct. 31, 2014
Management of Change Review Date
Jan. 6, 2014
Pre-startup Review Date
Oct. 31, 2014
Compliance Audit Date
Sept. 25, 2012
Compliance Audit Change Completion Date
Dec. 15, 2014
Incident Investigation Date
March 12, 2013
Incident Invest. Change Completion Date
Sept. 19, 2013
Participation Plan Review Date
July 9, 2014
Hot Work Review Date
April 1, 2013
Contractor Safety Review Date
Nov. 15, 2014, since latest RMP submission
Contractor Safety Eval. Date
Nov. 15, 2014, since latest RMP submission
Unit 2 Acid Plant, Other Basic Inorganic Chemical Manufacturing (32518)
Prevention Program ID:
1000051110
Safety Review Date
Aug. 15, 2014, since latest RMP submission
PHA Update Date
July 17, 2012, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Runaway reaction
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Purge System
Mitigation Systems
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
Nov. 21, 2014, since latest RMP submission
Training Review Date
June 9, 2014, since latest RMP submission
Maintenance Review Date
Aug. 19, 2009, since latest RMP submission
Maintenance Inspection Date
Nov. 21, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Nov. 4, 2014
Management of Change Review Date
Jan. 6, 2014
Pre-startup Review Date
Nov. 22, 2014
Compliance Audit Date
Sept. 25, 2012
Compliance Audit Change Completion Date
Dec. 15, 2014
Incident Investigation Date
Jan. 13, 2012
Incident Invest. Change Completion Date
Feb. 14, 2013
Participation Plan Review Date
July 9, 2014
Hot Work Review Date
April 1, 2013
Contractor Safety Review Date
Nov. 15, 2014, since latest RMP submission
Contractor Safety Eval. Date
Nov. 15, 2014, since latest RMP submission
Hazardous Waste Treatment, Other Basic Inorganic Chemical Manufacturing (32518)
Prevention Program ID:
1000051111
Safety Review Date
Nov. 19, 2014, since latest RMP submission
PHA Update Date
June 18, 2014, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
Sept. 3, 2014, since latest RMP submission
Training Review Date
June 9, 2014, since latest RMP submission
Maintenance Review Date
Aug. 19, 2009, since latest RMP submission
Maintenance Inspection Date
June 12, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Oct. 23, 2014
Management of Change Review Date
Jan. 6, 2014
Pre-startup Review Date
Oct. 23, 2014
Compliance Audit Date
Sept. 25, 2012
Compliance Audit Change Completion Date
Dec. 15, 2014
Incident Investigation Date
Oct. 15, 2014
Incident Invest. Change Completion Date
Nov. 21, 2014
Participation Plan Review Date
July 9, 2014
Hot Work Review Date
April 1, 2013
Contractor Safety Review Date
Nov. 15, 2014, since latest RMP submission
Contractor Safety Eval. Date
Nov. 15, 2014, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
Jan. 27, 2015
Local Response Agency:
Local Response Agency Phone:
(225) 389-2055
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

General Executive Summary for the Risk Management Plan at the ECO Services Operations Baton Rouge Plant

LDEQ facility ID # 1314



Date of report: 11/25/2014.



1. Our Accidental Release Prevention and Emergency Response Policies



The ECO Services Baton Rouge, LA Facility (Baton Rouge 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, hazard analysis, installation, operating procedures, mechanical integrity, management of change, incident investigation 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. The Baton Rouge site has also established an Emergency Response Team, consisting of plant personnel, that is well trained and prepared to respond to emergency situations.





2. Our Facility and the Regulated Substances handled



The Baton Rouge facility produces Sulfuric Acid including Oleum. Our facility's manufacturing activities encompass Sulfuric Acid Regeneration from Spent Acid, Oleum Production and Hazardous Waste Treatment Operations. The RMP-covered processes at our facility together handle the various regulated substances identified in this plan.





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



The Baton Rouge facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR 68 of the EPA RMP regulations. The following sections briefly describe the elements of the release prevention program that is in place at our facility.



Process Safety Information



The Baton Rouge Facility maintains detailed records of safety information that describes the properties and hazards of the chemicals used in our manufacturing units, the process technology employed, safe oper
ating parameters and safety instrumented systems, and equipment specifications and design basis associated with all processes.



Process Hazard Analysis



Our facility conducts comprehensive analytical studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodologies used to carry out these analyses are What-If and HazOp, incorporating Layers-of-Protection Analysis (LOPA). The studies are undertaken by a cross-functional team of qualified personnel with expertise in engineering, process operations and equipment maintenance, and are revalidated at a periodic interval of five years. Any recommendations related to the hazard analysis are addressed in a timely manner.





Operating Procedures



For the purposes of safely conducting activities within our covered processes, the Baton Rouge Facility maintains 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 periodically reviewed and is readily accessible to operators involved in the processes.



Training



The Baton Rouge Facility has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every three years and more frequently as needed.



Mechanical Integrity



The Baton Rouge Facility carries out documented maintenance inspections on process equipment to ensure proper operations. Process equipment examined by these inspections includes, among others, pressure vessels, storage tanks, heat exchangers, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Process equipment that are in contact with the hazardous RMP-listed chemicals receive priority for inspections
. Maintenance functions are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance inspections are corrected in a safe and timely manner.



Management of Change



Written procedures are in place at the Baton Rouge Facility to manage changes in process chemicals, technology, equipment and procedures. Proposed changes are implemented after they have been justified and reviewed for potential hazards that are addressed prior to implementing the change. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of the change and why it is necessary, and offered training to understand and work with the modification.



Pre-startup Safety Reviews



Pre-start up safety reviews related to new processes and to significant modifications in established processes are conducted as a regular practice at the Baton Rouge Facility. The extent of review is based on the complexity of the modification. These reviews are conducted by a cross-functional team to confirm that construction, equipment, instrumentation, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation.



Compliance Audits



The Baton Rouge Facility conducts audits on a regular basis to determine whether the provisions set out under the RMP regulations are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are prioritized and undertaken in a safe and timely manner.



Incident Investigation



The Baton Rouge Facility promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated chemical. These investigations are undertaken by cross-functional teams to identify t
he root cause(s) leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years.



Employee Participation



The Baton Rouge Facility truly believes that process safety management and accident prevention is a team effort. The site has a written program as well as an employee-driven HS&E team leading the effort to attain 100% employee participation in HS&E improvement efforts. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP regulations, including information resulting from process hazard analyses in particular.



Contractors



On occasion, our facility hires contractors to perform specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety record of the contractor is conducted. Only those contractors who satisfy the site's selection criteria are approved for being hired. The Baton Rouge Facility has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated chemical occur.





4. Our Five-year Accident History



The Baton Rouge Facility has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent accidental release prevention program and policies, there has been no reportable accidental release of regulated chemicals from our covered processes during this period. Our record reflects our safety culture and commitment to preventing accidental releases.





5. Our Emergency Response Program



The Baton Rouge Facility has a written emergency response plan to deal with accidental releases of haz
ardous chemicals. The plan includes all aspects of emergency response including incident command system of response management, adequate first aid and medical treatment, shelter-in-place and evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas and critique of the response. The site has established an Emergency Response team consisting of plant personnel well trained and prepared to respond to emergency situations.



To ensure proper functioning, our emergency response equipment is regularly inspected, tested and serviced. Site-wide emergency preparedness drills are conducted periodically and response critiqued for improvement opportunities. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response.



East Baton Rouge Parish LEPC is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified.





6. Planned Changes to Improve Safety



The Baton Rouge facility is committed to maintaining and operating our manufacturing units in a safe and environmentally responsible manner. Our site is committed to achieving HS&E excellence through continuous improvement of our HS&E processes. Ongoing changes to improve safety include Implementation of Total Productive Maintenance (TPM), wider implementation of Safety Instrumented Systems (SIS), enhanced employee awareness of safety through improved training and education, and creating an accountability culture for safety performance.