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St. Charles Operations

Parent Companies:
Union Carbide Corporation
The DOW Chemical Company
EPA Facility ID:
100000094211
Other ID:
70057NNCRBHWY31
Facility DUNS:
801038019
Parent Company #1 DUNS:
1289008
Parent Company #2 DUNS:
5005483

Location:

Address:
La. Highways 18 and 3142
Hahnville, LA 70057
County:
ST. CHARLES
Lat / Long:
29.983, -90.444 (Get map)
Method:
Interpolation - Photo
Description:
Center of Facility
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
2400

Owner/Operator:

Name:
Union Carbide Corporation
Phone:
(985) 783-4387
Address:
La. Highways 18 and 3142
355 Hwy 3142
Hahnville, LA 70057
Foreign Address:

Person responsible for RMP implementation:

Name:
Title:
Responsible Care Leader
Email:

Emergency contact:

Name:
Matthew Schaar
Title:
Emergency Service & Security Leader
Phone:
(985) 783-5296
24-hour phone:
(985) 783-4387
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:
983
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
multi permits
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
April 28, 2010
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Site Logistics
RMP ID:
1000068663
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Vinyl methyl ether [Ethene, methoxy-]
107-25-5
3,500,000
No
Ammonia (anhydrous)
7664-41-7
400,000
No
Ethylene oxide [Oxirane]
75-21-8
20,000,000
No
Ethylenediamine [1,2-Ethanediamine]
107-15-3
7,400,000
No
Propane
74-98-6
1,400,000
No
Propylene [1-Propene]
115-07-1
7,900,000
No
1,3-Butadiene
106-99-0
9,970,000
No
Methyl mercaptan [Methanethiol]
74-93-1
8,500,000
No
Acetaldehyde
75-07-0
160,000
No
1-Pentene
109-67-1
2,300,000
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
Hydrocarbons
RMP ID:
1000068664
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Propane
74-98-6
350,000
No
Propylene [1-Propene]
115-07-1
1,500,000
No
1,3-Butadiene
106-99-0
130,000
No
1-Butene
106-98-9
13,000
No
Methane
74-82-8
100,000
No
Ethane
74-84-0
370,000
No
Ethylene [Ethene]
74-85-1
870,000
No
2-Methylpropene [1-Propene, 2-methyl-]
115-11-7
13,000
No
2-Butene
107-01-7
10,000
No
Butene
25167-67-3
32,000
No
1-Pentene
109-67-1
14,000
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
Ethyleneamines
RMP ID:
1000068665
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
250,000
No
Ethylenediamine [1,2-Ethanediamine]
107-15-3
670,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Oxide 1
RMP ID:
1000068666
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ethylene oxide [Oxirane]
75-21-8
160,000
No
Ethylene [Ethene]
74-85-1
54,000
No
Methane
74-82-8
50,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Polyethylene
RMP ID:
1000068667
CBI claimed:
No
Program Level:
3
NAICS:
Plastics Material and Resin Manufacturing (325211)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ethylene [Ethene]
74-85-1
54,000
No
1-Butene
106-98-9
920,000
No
Isopentane [Butane, 2-methyl-]
78-78-4
1,500,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
SPU
RMP ID:
1000068668
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Methyl mercaptan [Methanethiol]
74-93-1
1,800,000
No
Vinyl methyl ether [Ethene, methoxy-]
107-25-5
54,000
No
Acrolein [2-Propenal]
107-02-8
620,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Acrylics
RMP ID:
1000068669
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Acetaldehyde
75-07-0
420,000
No
Acrolein [2-Propenal]
107-02-8
660,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
EOA
RMP ID:
1000068670
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
140,000
No
Public OCA Chemical
0
No
EXP
RMP ID:
1000068671
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ethylene oxide [Oxirane]
75-21-8
20,000
No
Public OCA Chemical
0
No
Butanol
RMP ID:
1000068672
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Propylene [1-Propene]
115-07-1
75,000
No
Public OCA Chemical
0
No
MGE
RMP ID:
1000068673
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ethylene oxide [Oxirane]
75-21-8
10,400
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
Dec. 31, 2015
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:
1000054862

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 SPU)
CBI claimed:
No
Percent weight:
98.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
26.20
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 Site Logistics)
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 SPU)
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:
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in SPU)
CBI claimed:
No
Percent weight:
98.0
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:
  • None
not considered:
  • Dikes
  • 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 EOA)
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:
  • 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 EXP)
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

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 Site Logistics)
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 Site Logistics)
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:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Excess flow valve

6. Five-year accident history

June 25, 2015 at 07:50
ID:
1000042265
NAICS:
Petrochemical Manufacturing (32511)
Duration:
20 minutes
Chemicals involved:
  • Ethylenediamine [1,2-Ethanediamine]
  • Ammonia (anhydrous)
Release events:
Gas release
Liquid spills/evaporation
Weather conditions at time of event
Wind speed:
4.0 miles/h NE
Temperature:
82.00 ℉
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:
3
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:
85
Property damage:
$0
Environmental damage:
  • Water contamination
  • Soil Contamination
  • Emissions through the flare exceeded the max hourly rate but no RQ was exceeded.
Initiating event:
Human Error
Contributing factors:
  • Improper procedure
  • Process design failure
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Revised operating procedures
  • New process controls
  • Changed process
Sept. 14, 2014 at 23:40
ID:
1000042264
NAICS:
Petrochemical Manufacturing (32511)
Duration:
56 minutes
Chemicals involved:
  • Ethylenediamine [1,2-Ethanediamine]
Release events:
Liquid spills/evaporation
Weather conditions at time of event
Wind speed:
4.0 miles/h NW
Temperature:
82.00 ℉
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:
15
Property damage:
$0
Environmental damage:
Initiating event:
Human Error
Contributing factors:
  • Maintenance activity/inactivity
Off-site responders notified:
Notified Only
Changes introduced as a result of the accident:
  • Communication was provided to the site to reinforce safety standards

7. Prevention: Program level 3

Site Logistics, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000057329
Safety Review Date
June 1, 2015, since latest RMP submission
PHA Update Date
July 14, 2015, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
  • Water Curtain
  • Enclosure
Monitoring Systems
  • Process Area
Changes since PHA
  • Increased Inventory
  • Process Parameters
  • Process Controls
  • Process Detection
  • Mitigation Systems
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
June 1, 2015, since latest RMP submission
Training Review Date
Sept. 11, 2014, since latest RMP submission
Maintenance Review Date
June 20, 2014, since latest RMP submission
Maintenance Inspection Date
Nov. 30, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
June 20, 2015
Management of Change Review Date
May 11, 2015
Pre-startup Review Date
June 20, 2015
Compliance Audit Date
June 1, 2015
Compliance Audit Change Completion Date
Dec. 31, 2015
Incident Investigation Date
Sept. 19, 2015
Incident Invest. Change Completion Date
March 31, 2016
Participation Plan Review Date
Nov. 5, 2015
Hot Work Review Date
Nov. 17, 2015
Contractor Safety Review Date
July 13, 2014, since latest RMP submission
Contractor Safety Eval. Date
Nov. 11, 2015, since latest RMP submission
Hydrocarbons, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000057330
Safety Review Date
Feb. 18, 2013, since latest RMP submission
PHA Update Date
Jan. 7, 2015, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Overfilling
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Dec. 16, 2014, since latest RMP submission
Training Review Date
Aug. 15, 2013, since latest RMP submission
Maintenance Review Date
Aug. 17, 2015, since latest RMP submission
Maintenance Inspection Date
April 20, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 24, 2015
Management of Change Review Date
May 11, 2015
Pre-startup Review Date
April 24, 2015
Compliance Audit Date
Feb. 18, 2013
Compliance Audit Change Completion Date
Dec. 31, 2016
Incident Investigation Date
May 16, 2015
Incident Invest. Change Completion Date
June 30, 2017
Participation Plan Review Date
May 19, 2010
Hot Work Review Date
Nov. 26, 2009
Contractor Safety Review Date
March 6, 2015, since latest RMP submission
Contractor Safety Eval. Date
Aug. 24, 2010, since latest RMP submission
Ethyleneamines, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000057335
Safety Review Date
Feb. 14, 2014, since latest RMP submission
PHA Update Date
July 15, 2013, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Corrosion
  • Overfilling
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Power
  • Grounding Equipment
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Nov. 30, 2015, since latest RMP submission
Training Review Date
July 29, 2013, since latest RMP submission
Maintenance Review Date
April 28, 2010, since latest RMP submission
Maintenance Inspection Date
June 15, 2010, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Oct. 20, 2012
Management of Change Review Date
March 25, 2014
Pre-startup Review Date
Oct. 20, 2012
Compliance Audit Date
Feb. 14, 2014
Compliance Audit Change Completion Date
Dec. 31, 2014
Incident Investigation Date
June 25, 2015
Incident Invest. Change Completion Date
June 30, 2016
Participation Plan Review Date
May 19, 2010
Hot Work Review Date
Sept. 27, 2013
Contractor Safety Review Date
March 6, 2015, since latest RMP submission
Contractor Safety Eval. Date
Aug. 24, 2010, since latest RMP submission
Oxide 1, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000057331
Safety Review Date
May 12, 2013, since latest RMP submission
PHA Update Date
May 27, 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
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Power
  • Grounding Equipment
  • Rupture Disks
  • Quench System
  • Purge System
Mitigation Systems
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Oral Test
  • Demonstration
Procedure Review Date
Jan. 20, 2015, since latest RMP submission
Training Review Date
Sept. 14, 2015, since latest RMP submission
Maintenance Review Date
April 19, 2010, since latest RMP submission
Maintenance Inspection Date
Oct. 19, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 18, 2015
Management of Change Review Date
May 11, 2015
Pre-startup Review Date
Dec. 18, 2015
Compliance Audit Date
May 12, 2013
Compliance Audit Change Completion Date
Dec. 8, 2015
Incident Investigation Date
Feb. 20, 2013
Incident Invest. Change Completion Date
July 31, 2013
Participation Plan Review Date
Sept. 14, 2015
Hot Work Review Date
Sept. 27, 2013
Contractor Safety Review Date
March 6, 2015, since latest RMP submission
Contractor Safety Eval. Date
Aug. 24, 2010, since latest RMP submission
Polyethylene, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000057332
Safety Review Date
May 17, 2013, since latest RMP submission
PHA Update Date
Feb. 26, 2014, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • None
Process Controls
  • None
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Fire Walls
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
Dec. 1, 2015, since latest RMP submission
Training Review Date
May 17, 2013, since latest RMP submission
Maintenance Review Date
Dec. 16, 2015, since latest RMP submission
Maintenance Inspection Date
Aug. 7, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 13, 2015
Management of Change Review Date
May 11, 2015
Pre-startup Review Date
April 1, 2015
Compliance Audit Date
May 17, 2013
Compliance Audit Change Completion Date
Dec. 12, 2014
Incident Investigation Date
March 28, 2013
Incident Invest. Change Completion Date
Dec. 31, 2013
Participation Plan Review Date
March 24, 2014
Hot Work Review Date
June 9, 2015
Contractor Safety Review Date
March 6, 2015, since latest RMP submission
Contractor Safety Eval. Date
Aug. 24, 2010, since latest RMP submission
SPU, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000057333
Safety Review Date
June 10, 2013, since latest RMP submission
PHA Update Date
Sept. 8, 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
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Excess Flow Device
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
  • Water Curtain
  • Neutralization
Monitoring Systems
  • Process Area
Changes since PHA
  • Perimeter Monitoring
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
April 30, 2015, since latest RMP submission
Training Review Date
Feb. 12, 2015, since latest RMP submission
Maintenance Review Date
Nov. 13, 2014, since latest RMP submission
Maintenance Inspection Date
Oct. 13, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Oct. 15, 2015
Management of Change Review Date
May 11, 2015
Pre-startup Review Date
Oct. 15, 2015
Compliance Audit Date
June 10, 2013
Compliance Audit Change Completion Date
Nov. 30, 2013
Incident Investigation Date
Dec. 1, 2012
Incident Invest. Change Completion Date
Dec. 31, 2013
Participation Plan Review Date
Nov. 30, 2015
Hot Work Review Date
Sept. 27, 2013
Contractor Safety Review Date
March 6, 2015, since latest RMP submission
Contractor Safety Eval. Date
Aug. 24, 2010, since latest RMP submission
Acrylics, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000057334
Safety Review Date
June 10, 2013, since latest RMP submission
PHA Update Date
Sept. 8, 2014, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
Mitigation Systems
  • Dikes
  • Deluge System
  • Neutralization
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
  • Perimeter Monitoring
  • Mitigation Systems
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Dec. 1, 2015, since latest RMP submission
Training Review Date
Sept. 2, 2015, since latest RMP submission
Maintenance Review Date
Nov. 30, 2015, since latest RMP submission
Maintenance Inspection Date
Dec. 10, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 12, 2015
Management of Change Review Date
May 11, 2015
Pre-startup Review Date
Oct. 9, 2015
Compliance Audit Date
June 10, 2013
Compliance Audit Change Completion Date
Nov. 23, 2015
Incident Investigation Date
July 2, 2012
Incident Invest. Change Completion Date
March 31, 2013
Participation Plan Review Date
Jan. 30, 2015
Hot Work Review Date
Sept. 27, 2013
Contractor Safety Review Date
March 6, 2015, since latest RMP submission
Contractor Safety Eval. Date
June 17, 2015, since latest RMP submission
EOA, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000057336
Safety Review Date
Feb. 14, 2014, since latest RMP submission
PHA Update Date
July 15, 2013, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Corrosion
  • Overfilling
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Power
  • Grounding Equipment
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • Classrom
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Oct. 30, 2015, since latest RMP submission
Training Review Date
July 29, 2013, since latest RMP submission
Maintenance Review Date
Nov. 14, 2008, since latest RMP submission
Maintenance Inspection Date
June 15, 2010, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
June 30, 2015
Management of Change Review Date
March 25, 2014
Pre-startup Review Date
June 24, 2015
Compliance Audit Date
Feb. 14, 2014
Compliance Audit Change Completion Date
Dec. 31, 2014
Incident Investigation Date
Nov. 7, 2011
Incident Invest. Change Completion Date
Dec. 31, 2011
Participation Plan Review Date
May 19, 2010
Hot Work Review Date
Sept. 27, 2013
Contractor Safety Review Date
March 6, 2015, since latest RMP submission
Contractor Safety Eval. Date
Aug. 24, 2010, since latest RMP submission
EXP, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000057337
Safety Review Date
July 21, 2015, since latest RMP submission
PHA Update Date
July 21, 2015, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Power
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • Increased Inventory
  • Process Controls
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
Aug. 18, 2015, since latest RMP submission
Training Review Date
Oct. 14, 2015, since latest RMP submission
Maintenance Review Date
Aug. 20, 2015, since latest RMP submission
Maintenance Inspection Date
Dec. 8, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Oct. 14, 2015
Management of Change Review Date
April 30, 2013
Pre-startup Review Date
Oct. 13, 2015
Compliance Audit Date
Oct. 26, 2015
Compliance Audit Change Completion Date
Jan. 8, 2017
Incident Investigation Date
June 10, 2012
Incident Invest. Change Completion Date
July 15, 2012
Participation Plan Review Date
May 19, 2010
Hot Work Review Date
Aug. 25, 2015
Contractor Safety Review Date
Aug. 18, 2015, since latest RMP submission
Contractor Safety Eval. Date
Dec. 30, 2015, since latest RMP submission
Butanol, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000057339
Safety Review Date
Aug. 14, 2015, since latest RMP submission
PHA Update Date
Oct. 31, 2012, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Floods
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
May 8, 2015, since latest RMP submission
Training Review Date
Aug. 14, 2015, since latest RMP submission
Maintenance Review Date
Aug. 14, 2015, since latest RMP submission
Maintenance Inspection Date
June 5, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 2, 2015
Management of Change Review Date
May 11, 2015
Pre-startup Review Date
April 21, 2015
Compliance Audit Date
Aug. 14, 2015
Compliance Audit Change Completion Date
Dec. 31, 2016
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
May 19, 2010
Hot Work Review Date
Sept. 27, 2013
Contractor Safety Review Date
March 6, 2015, since latest RMP submission
Contractor Safety Eval. Date
Aug. 24, 2010, since latest RMP submission
MGE, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000057340
Safety Review Date
May 12, 2013, since latest RMP submission
PHA Update Date
May 27, 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
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Power
  • Grounding Equipment
  • Rupture Disks
  • Quench System
  • Purge System
Mitigation Systems
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Oral Test
  • Demonstration
Procedure Review Date
Jan. 20, 2015, since latest RMP submission
Training Review Date
Sept. 14, 2015, since latest RMP submission
Maintenance Review Date
April 19, 2010, since latest RMP submission
Maintenance Inspection Date
Oct. 19, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 18, 2015
Management of Change Review Date
May 11, 2015
Pre-startup Review Date
Dec. 18, 2015
Compliance Audit Date
May 12, 2013
Compliance Audit Change Completion Date
Dec. 8, 2015
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Sept. 14, 2015
Hot Work Review Date
Sept. 27, 2013
Contractor Safety Review Date
March 6, 2015, since latest RMP submission
Contractor Safety Eval. Date
Aug. 24, 2010, 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:
Dec. 28, 2015
Local Response Agency:
Local Response Agency Phone:
(985) 783-5050
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

Risk Management Plan Update

Executive Summary

UNION CARBIDE CORPORATION

A Wholly Owned Subsidiary of The Dow Chemical Company

St. Charles Operations (SCO)



This Risk Management Plan (RMP) update is being submitted in response to a routine review of our site program. As a result of interconnectivity, St. Charles Operations (SCO) is reporting three additional process units (Butanol, MGE, and Higher Glycols) as covered under the site RMP Plan. However, the RMP covered chemicals within these three unit battery limits are below the threshold quantities. SCO is also reporting one additional flammable chemical, 1-Pentene. Note that these additions do not change the release scenarios that are reported in this update. SCO has reviewed the Toxic and Flammable Worst Case Release and Alternative Case Release scenarios and has updated certain scenarios to be consistent with the PSM evaluations. Additionally, SCO has remodeled the scenarios using EPA's RMP Comp and MARPLOT software.



1. Accidental Release Prevention and Emergency Response Policies

St. Charles Operations of the Union Carbide Corporation (a wholly owned subsidiary of The Dow Chemical Company) is strongly committed to employee, public and environmental safety, as demonstrated by St. Charles Operations comprehensive accidental release prevention program that covers areas such as design, construction, operation, maintenance, and employee training associated with the processes at the facility. It is St. Charles Operations policy to implement the necessary and appropriate controls to prevent possible releases of regulated substances. If such a release does occur, St. Charles Operations emergency response personnel are at hand to control and mitigate the effects of the release. St. Charles Operations is also coordinated with the St. Charles Parish Office of Homeland Security and Emergency Preparedness (OHSEP) which provides additional emergency response expertise.



2. The Stationary Source and the Regul
ated Substances Handled

St. Charles Operations began operations in 1966 and produces multiple intermediate products that are found in a variety of consumer goods such as: plastics, insecticides, films and fabrics, antifreeze, jet fuel, brake fluid, paints and adhesives, textiles, lubricants, pharmaceuticals, medical supplies, personal care products, toothpaste, shampoos, soaps, cleaning agents, detergents, fabric softeners, and animal feed supplements.



SCO has 19 regulated substances present at this facility. These substances included in the following:



1,3-Butadiene

1-Butene

1-Pentene

2-Butene

2-Methylpropene [1-Propene, 2-methyl-]

Acetaldehyde

Acrolein [2-Propenal]

Ammonia (anhydrous)

Butene

Ethane

Ethylene [Ethene]

Ethylene oxide [Oxirane],

Ethylenediamine [1,2-Ethanediamine]

Isopentane [Butane, 2-methyl-]

Methane

Methyl mercaptan [Methanethiol]

Propane, Propylene [1-Propene]

Propylene [1-Propene]

Vinyl methyl ether [Ethene, methoxy-]



3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures

In accordance with the 2004 revisions to 40 CFR Part 68 (69 FR 18819-18832, April 9, 2004), the Worst Case Release and Alternative Release scenarios that were developed in the preparation of this submittal, are not discussed in this Executive Summary, but their results are included in the applicable elements of the submittal.



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

St. Charles Operations has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR Part 68 of the EPA. This facility operates in accordance with recognized and generally accepted good engineering practices. The following sections briefly describe the elements of the release prevention program that is in place at this stationary source.



Process Safety Information



St. Charles Operations ma
intains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Some of this documentation includes Material Safety Data Sheets, equipment spec sheets, and reactive chemicals tests.



Process Hazard Analysis



St. Charles Operations conducts periodic comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is RCPHA Checklist, HAZOP, Layer of Protection Analysis (LOPA), the Dow Fire and Explosion Index, the Dow Chemical Exposure Index, and Reactive Chemicals/Process Hazards Analysis. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of 3 years. Findings related to the hazard analysis are addressed in a timely manner.



Operating Procedures



St. Charles Operations maintains and periodically updates written standard 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 regularly reviewed and is readily accessible to operators.



Training



St. Charles Operations has a comprehensive training program in place to ensure that employees who operate processes are competent in the procedures associated with these processes. All new employees are provided the applicable training based on the nature and location of their assignments. Refresher training is provided as needed.



Mechanical Integrity



St. Charles Operations carries out and documents periodic maintenance checks on process and safety equipment to ensure proper operations and to minimize/prevent incidents resulting from mechanical failures or equipment breakdowns. Process equipment examined by these check
s includes, but is not limited to, pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, process instrumentation and controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.



Management of Change



Written procedures are in place at St. Charles Operations 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 provided training to deal with the modification.



Pre-startup Reviews



Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as part of the management of change policy at St. Charles Operations. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation.



Compliance Audits



St. Charles Operations conducts audits on a regular basis to verify that the provisions and requirements of the RMP rule are complied with. These audits are carried out at a minimum of every 3 years and corrective actions required as a result of the audits are undertaken in a safe and prompt manner.



Incident Investigation



St. Charles Operations 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. Reports are retained for a minimum of 5 years. There have been two RMP reportable inciden
ts at St. Charles Operations facility in the last 5 years.



Employee Participation



Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, all St. Charles Operations employees have access to the process safety information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular.



Contractors



St. Charles Operations hires contractors to conduct specialized maintenance, construction and various other activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. St. Charles Operations has a strict policy of informing the contractors of known potential hazards related to the contractor's work and the processes involved. Contractors are also informed of the procedures for emergency response should an accidental release of a regulated substance occur. Contractors are also required to inform St. Charles Operations of any hazards they may introduce at the site.



5. Five-year Accident History

There have been two RMP reportable incidents at St. Charles Operations facility in the last 5 years. Investigations were conducted for each incident and corrective actions were implemented in a safe and timely manner. Details of the two RMP reportable incidents are included in the applicable elements of this submittal.



6. Emergency Response Plan

St. Charles Operations has a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promp
tly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. St. Charles Parish Office of Homeland Security and Emergency Preparedness (OHSEP) is the Local Emergency Planning Committee with which our emergency plan has been coordinated and verified.



7. Planned Changes to Improve Safety

St. Charles Operations continually analyzes safety data to identify areas of opportunity. In 2016, improvement plans are focused around ensuring personnel fully understand and comply with life-critical standards.