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DuPont Pontchartrain Site

Parent Companies:
E.I. du Pont de Nemours & Co., Inc.
EPA Facility ID:
100000037266
Other ID:
70069DPNTPHIGHW
Facility DUNS:
37964814
Parent Company DUNS:
1315704

Location:

Address:
586 Highway 44
LaPlace, LA 70068
County:
ST. JOHN THE BAPTIST
Lat / Long:
30.057, -90.522 (Get map)
Method:
Interpolation - Photo
Description:
Storage Tank
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
E.I. du Pont de Nemours & Co., Inc.
Phone:
(985) 536-5217
Address:
586 Highway 44
LaPlace, LA 70068 -6912
Foreign Address:

Person responsible for RMP implementation:

Name:
Ivan D. Caldwell
Title:
Plant Manager

Emergency contact:

Name:
David S. Barrett
Title:
Emergency Response Leader
Phone:
(985) 536-5311
24-hour phone:
(504) 417-2782
Ext or PIN:

Other contacts:

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

Safety:

Local Emergency Planning Committee:
St. John The Baptist Parish LE
Full-Time Equivalent Employees:
148
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
2090-V6
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Aug. 30, 2011
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

PPDA Process
RMP ID:
1000051871
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
337,081
No
Public OCA Chemical
0
No
Ammonia Railcars
RMP ID:
1000051873
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
1,200,113
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Anthony J. Fugarino
Address:
586 Highway 44
LaPlace, LA 70068 -6912
Foreign Address:

Phone:
(985) 536-5438

Latest RMP Submission:

Date:
May 21, 2014
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000042103

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 Ammonia Railcars)
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

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 PPDA Process)
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:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Sprinkler systems
not considered:
  • 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

PPDA Process, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000043918
Safety Review Date
June 15, 2013, since latest RMP submission
PHA Update Date
Dec. 19, 2012, since latest RMP submission
PHA Techniques
  • What if/Checklist
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Equipment failure
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • Sprinkler System
Monitoring Systems
  • Process Area
Changes since PHA
  • Mitigation Systems
Training Type
  • None
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
Feb. 26, 2014, since latest RMP submission
Training Review Date
Oct. 10, 2013, since latest RMP submission
Maintenance Review Date
Oct. 14, 2013, since latest RMP submission
Maintenance Inspection Date
April 3, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
March 20, 2014
Management of Change Review Date
April 15, 2014
Pre-startup Review Date
Sept. 25, 2012
Compliance Audit Date
May 1, 2014
Compliance Audit Change Completion Date
Aug. 31, 2015
Incident Investigation Date
June 25, 2012
Incident Invest. Change Completion Date
Jan. 31, 2013
Participation Plan Review Date
Dec. 15, 2013
Hot Work Review Date
April 1, 2014
Contractor Safety Review Date
March 17, 2014, since latest RMP submission
Contractor Safety Eval. Date
May 4, 2014, since latest RMP submission
Ammonia Railcars, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000043920
Safety Review Date
June 15, 2013, since latest RMP submission
PHA Update Date
Dec. 19, 2012, since latest RMP submission
PHA Techniques
  • What if/Checklist
Hazards Identified
  • Toxic release
  • Fire
  • Hurricanes
Process Controls
  • Relief Valves
  • Rupture Disks
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 22, 2014, since latest RMP submission
Training Review Date
May 1, 2014, since latest RMP submission
Maintenance Review Date
July 11, 2012, since latest RMP submission
Maintenance Inspection Date
Jan. 25, 2011, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
July 23, 2013
Management of Change Review Date
April 15, 2014
Pre-startup Review Date
April 16, 2014
Compliance Audit Date
May 1, 2014
Compliance Audit Change Completion Date
Aug. 31, 2015
Incident Investigation Date
April 27, 2010
Incident Invest. Change Completion Date
July 30, 2010
Participation Plan Review Date
Dec. 15, 2013
Hot Work Review Date
April 1, 2014
Contractor Safety Review Date
March 17, 2014, since latest RMP submission
Contractor Safety Eval. Date
May 4, 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:
April 17, 2014
Local Response Agency:
Local Response Agency Phone:
(985) 652-2222
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

17113 LDEQ Facility ID Number



ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES



The DuPont Pontchartrain Site adheres to Corporate policies, which could be summarized as follows:

- All Safety and Environmental incidents are preventable.

- The Goal is Zero - Zero Incidents, Period - doing what it takes to be "Committed to Zero".

- All employees and contractors are responsible for their safety.



The Corporate policies are embodied in the numerous Safety, Health, and Environmental (SHE) and Engineering Standards, which apply globally. At the Pontchartrain Site, the policies are implemented through the Pontchartrain Site Process Management Manual (PMM). This manual is available to all employees through hard copies and also through on-line computer networks. In addition, the Pontchartrain Site Emergency Manual lays out the complete Emergency Response program for the site.



FACILITY DESCRIPTION



The DuPont Pontchartrain Site consists of 1132 acres, located in St John the Baptist Parish between the unincorporated areas of LaPlace and Reserve. About 200 acres of the property are used for manufacturing areas, 590 acres are leased for cattle grazing, 30 acres are leased for recreation, and the remainder is set aside for wildlife habitat and future manufacturing needs. A portion of the area used for manufacturing is occupied by DuPont Performance Polymers. The DuPont Performance Polymers facilities are considered to be a separate "stationary source" for the purposes of 40 CFR part 68.



In and prior to 2010, the DuPont Pontchartrain Site consisted of two manufacturing processes:



* Paraphenylene Diamine

* Isophorone Diamine



The Isophorone Diamine Unit was cleared of process material and shutdown on 10/7/2010. There are not any plans to start this unit again and the air permit was not re-newed, therefore as part of this RMP submittal the Isophorone Diamine Process has been removed from the RMP.



In the production of these product
s, anhydrous ammonia is the only regulated substance and is used as raw material.



On site storage of ammonia railcars is also treated as a separate process for the purposes of 40 CFR part 68.



GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC

PREVENTION STEPS



The DuPont Pontchartrain Site processes follow the requirements of DuPont Corporate SHE

Standard S21A, "Process Safety Management." This Standard includes and embraces the requirements

of 29 CFR 1910.119 and 40 CFR Part 68.



Our Safety Programs include:



Designing for Safety ...

- A documented process technology system covers hazards of materials, equipment design basis, and

process design basis.

- Extensive accident prevention and mitigation systems are strategically located.

- Applicable codes and standards are met or exceeded.

- Materials of construction are chosen to provide mechanical integrity.

- Quality Assurance ensures fabrication in accordance with design specifications and proper assembly.



Maintaining our Plant ...

- Maintenance personnel are trained and experienced.

- Contractors are trained and qualified.

- A work permit system controls hazards.



Operating Safety ...

- Operators are trained and job qualified.

- Technical resources are available and utilized as required.

- Operators follow approved procedures.



Auditing our Operations ...

- Routine safety inspections are conducted.

- Corporate, independent and governmental audits and reviews are conducted.

- Process Hazards Analyses are conducted.

- Safety critical equipment is set up on a periodic inspection frequency to ensure ongoing mechanical

integrity.

- Pre-startup safety reviews are conducted prior to starting up any new or modified equipment.

- Quality assurance of critical equipment ensures fabrication in accordance with design specifications.

- All incidents are investigated and actions taken to prevent recurrence.



SAFETY IS A JOB REQUIREMENT FOR ALL EMPLOYE
ES AND CONTRACTORS!



THE FIVE-YEAR ACCIDENT HISTORY



No deaths, injuries, or significant property damage on site, or known off-site deaths, injuries,

evacuations, sheltering in place, property damage, or environmental damage has resulted from a

release of Anhydrous Ammonia in the past five years.



EMERGENCY RESPONSE PROGRAM



The DuPont Pontchartrain Site is operated 24 hours per day, 7 days per week by four rotating shifts. Each shift has a well trained emergency response team lead by a qualified Emergency Director. Overall emergency planning and coordination between shifts is provided by an Emergency Coordinator who works a normal 5 day schedule. The Emergency Coordinator can be reached by telephone or pager 24 hours per day, 7 days per week if needed.



Plant personnel are trained and equipped to respond to plant emergencies including any releases of Anhydrous Ammonia. The program can be summarized as follows:



Training and Preparation ...

- Plant personnel receive emergency response training.

- Plant emergency responders are trained in assigned emergency roles.

- Emergency response plans are current.

- Plant participates in emergency drills.

- Critiques are held on drills and actual events.

- Plant is a member of the St John the Baptist Parish Local Emergency Planning Committee.



If a Major Release Occurs ...

- Emergency alarm is sounded.

- Plant Emergency Operating Center is activated.

- Plant Emergency Director and emergency squad respond.

- The Community Alert system is sounded.

- Community emergency responders are notified as appropriate.



PLANNED CHANGES TO IMPROVE SAFETY



* Continued focus on being "Committed to Zero" for injuries and incidents.



CORRECTION



Correction dated approximately 12/15/15 was just to update the Responsible Party for implementation of RMP and the maximum intended inventories which included some piping sources, etc. These updates did not effect any of the modeling inputs or outputs in any way
, therefore the modeling did not require to be updated.