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Hexion Luling Facility

Parent Companies:
Hexion Inc.
Hexion LLC
EPA Facility ID:
100000231448
Other ID:
1001218
Facility DUNS:
0
Parent Company #1 DUNS:
166495924
Parent Company #2 DUNS:
0

Location:

Address:
12513 Queenie Rd.
Luling,, LA 70070
County:
ST. CHARLES
Lat / Long:
29.923, -90.349 (Get map)
Method:
Interpolation - Other
Description:
Center of Facility
Horizonal accuracy:
15 m
Horizontal reference datum:
World Geodetic System of 1984
Source map scale:

Owner/Operator:

Name:
Hexion Inc.
Phone:
(225) 744-2000
Address:
P.O. Box 232
Geismar, LA 70734
Foreign Address:

Person responsible for RMP implementation:

Name:
Ricky Dickmyer
Title:
Site Leader

Emergency contact:

Name:
Ricky Dickmyer
Title:
Site Leader
Phone:
(225) 744-2021
24-hour phone:
(225) 290-5691
Ext or PIN:

Other contacts:

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

Safety:

Local Emergency Planning Committee:
St. Charles Parish LEPC
Full-Time Equivalent Employees:
10
Covered by OSHA PSM:
No
EPCRA section 302:
No
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Inspecting Agency:
New Facility. No inspection has been done
Using Predictive Filing:
No

Processes:

Formaldehyde Solutions
RMP ID:
1000068188
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Formaldehyde (solution)
50-00-0
6,000,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Bruce Raff with CK Associates, LLC
Address:
17170 Perkins Road
Baton Rouge, LA 70810
Foreign Address:

Phone:
(225) 755-1000

Latest RMP Submission:

Date:
Feb. 3, 2016
Type:
First-time submission
Reason:
Registered:
Yes
RMP ID:
1000054418

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 Formaldehyde Solutions)
CBI claimed:
No
Percent weight:
52.0
Physical state:
Liquid
Model used:
EPA's OCA Guidance Reference Tables or Equations
Release duration (mins):
10.00
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 Formaldehyde Solutions)
CBI claimed:
No
Percent weight:
52.0
Physical state:
Liquid
Model used:
EPA's OCA Guidance Reference Tables or Equations
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:
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown

4. Flammables: Worst-case

None

5. Flammables: Alternative release

None

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

Formaldehyde Solutions, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000057135
Safety Review Date
Jan. 27, 2016, since latest RMP submission
PHA Update Date
Dec. 18, 2015, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
  • FTA
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Overfilling
  • Contamination
  • Floods
  • Hurricanes
Process Controls
  • None
Mitigation Systems
  • Sprinkler System
  • Dikes
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
Procedure Review Date
Jan. 5, 2016, since latest RMP submission
Training Review Date
Jan. 18, 2016, since latest RMP submission
Maintenance Review Date
Jan. 4, 2016, since latest RMP submission
Maintenance Inspection Date
Jan. 18, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Jan. 18, 2016
Management of Change Review Date
Dec. 4, 2015
Pre-startup Review Date
Jan. 18, 2016
Compliance Audit Date
None
Compliance Audit Change Completion Date
None
Incident Investigation Date
Jan. 5, 2016
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Feb. 20, 2014
Hot Work Review Date
May 29, 2015
Contractor Safety Review Date
April 30, 2015, since latest RMP submission
Contractor Safety Eval. Date
None, 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. 3, 2016
Local Response Agency:
Local Response Agency Phone:
(985) 783-5050
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
No
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

February 2016 - Initial submittal for new facility.





1. Accidental release prevention and emergency response policies



As stated in our Corporate Health, Safety, and Environmental Policy and Principles, the facility is committed to health, safety, and environmental excellence. To accomplish this we integrate health, safety, and environmental planning into all business activities. This includes complying with applicable laws, responsibly managing risks, and working collaboratively with others in addressing health, safety, and environmental issues.



In the Corporate Safety Manual, the Safety Policy Statement clearly states that safety will not be compromised to achieve any other operational or business objective. This manual defines requirements and guidelines developed to prevent injuries and accidental releases.



Included in the Safety Manual are Emergency Response Policies that state that safety is the top priority in all emergency response situations. This policy refers to the plant Emergency Response Plan for specific procedures for handling releases of hazardous materials.



2. Stationary source and regulated substances handled



This plant makes formaldehyde solutions. The site includes a formaldehyde manufacturing facility.



The regulated substances used in the plant and the maximum quantity stored is formaldehyde.



3. Accidental release prevention program and chemical-specific prevention steps



This plant has a comprehensive process safety management program that is in compliance with the EPA Accidental Release Prevention Rule, the OSHA Process Safety Management Standard, and all applicable state codes and regulations. A safety management system is in place to assure on-going compliance. This management system includes the Safety Manual, a list of site safety responsibilities, a file system to maintain records of compliance, and a monthly Safety Committee meeting, where a management control checksheet is used to verify that tasks were comple
ted on schedule. The Site Leader has overall responsibility for this program.



Designated personnel are assigned to maintain and improve the safety of their units. Their duties include keeping operating procedures up-to-date, training operators so they can safely carry out these procedures, assuring that the plant is run safely on a daily basis, and when necessary, investigating incidents in their unit. All employees participate in the safety program to improve safety and plant operation.



Designated personnel maintain an Operating Guide that includes process safety information, operating procedures, and a training certification program. Operators use the Operating Guide as a training tool and for reference. By applying the information it contains their actions will prevent accidental releases.



Process hazard analyses were conducted to identify hazards and recommend safeguards that will prevent an accidental release. As a result of initial process hazard reviews, a significant investment was made in process control systems. Recommendations resulting from the process hazard analyses are entered into an action items database to track the items to completion.



A Management of Change (MOC) system is used to assure that changes to plant equipment, procedures, or processed do not cause accidents. For equipment, procedure, and process changes, a MOC initiates a safety review. This review may include a process hazard analysis. Changes to product formulations initiate a review by technical and plant personnel.



A preventive maintenance program maintains the mechanical integrity of process equipment. A computer database is used to manage the preventive maintenance schedule and other corrective or improvement repairs necessary to maintain the ongoing integrity and reliability of the facility equipment. Each month scheduled equipment inspections, tests, or servicing are performed. The schedule is based on plant experience to reduce the likelihood of an accidental rel
ease caused by equipment failure.



The requirements in the Safety Manual include safe work practices which prevent accidental releases. One important section describes safety measures for welding or other "hot" work, which includes a permit system to reduce the risk of fire. The Safety Manual also includes requirements for locking out equipment for maintenance. These procedures reduce the likelihood that a valving error will lead to a release.



Contractors, who periodically perform work in the plant, are given safety orientations to brief them on plant hazards and safety practices. Contractor safety programs and performance are evaluated prior to their selection for jobs that impact process safety.



Incidents that cause or could have caused a release are investigated and recommendations are made to prevent recurrence. These recommendations may lead to improvements in equipment, procedures, operating conditions, or training.



Internal Corporate Health, Safety and Environmental Audits are conducted periodically to maintain compliance with local, state and federal regulations. Regional Safety and Environmental professionals periodically review the health, safety, and environmental programs. Addressing recommendations from these audits and reviews keeps the Facility's Safety and Environmental programs effective.



4. Five-year accident history



Since this is a new facility, there have been no reportable incidents of a regulated substance from our processes.



5. Emergency response program



The plant Emergency Response Plan describes procedures for actual and threatened releases, including coordination with fire department responders. An emergency response drill is conducted annually to test the Emergency Response Plan and reinforce training that plant responders receive.



6. Planned changes to improve safety



No significant changes are planned.