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St. Charles Operations Cypress Polypropylene Plant

Parent Companies:
Union Carbide Corporation
The DOW Chemical Company
EPA Facility ID:
100000127132
Other ID:
70079CYPRS901P
Facility DUNS:
1289008
Parent Company #1 DUNS:
1289008
Parent Company #2 DUNS:
1289008

Location:

Address:
901 Prospect Ave.
Norco, LA 70079
County:
ST. CHARLES
Lat / Long:
30.003, -90.393 (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:
Union Carbide Corporation
Phone:
(985) 783-4387
Address:
La. Highways 18 and 3142
Hahnville, LA 70057
Foreign Address:

Person responsible for RMP implementation:

Name:
Stephen M. Moore
Title:
EH&S Delivery Specialist

Emergency contact:

Name:
Andrew G. Mosher
Title:
ES&S Leader
Phone:
(225) 353-8392
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:
75
Covered by OSHA PSM:
Yes
EPCRA section 302:
No
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
2520-00012-V2
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Feb. 27, 2003
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Polypropylene Production
RMP ID:
47099
CBI claimed:
No
Program Level:
3
NAICS:
Plastics Material and Resin Manufacturing (325211)
Chemical name
CAS#
Quantity (lbs.)
CBI
Propylene [1-Propene]
115-07-1
861,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
June 17, 2004
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
No
RMP ID:
32600

Deregistration:

Date:
Effective Date:
Reason:
Source terminated operations
Other Reason:

2. Toxics: Worst-case

None

3. Toxics: Alternative release

None

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 Polypropylene Production)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • Equipment pressure testing and inspection program, relief valves, high level alarm, high-high level interlocks, high pressure alarm, overpressure vent to flare.
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 Polypropylene Production)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • Equipment pressure testing and inspection program.
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Excess flow valve

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

Polypropylene Production, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
26931
Safety Review Date
April 28, 2003, since latest RMP submission
PHA Update Date
Feb. 28, 2002, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • 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
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
Nov. 6, 2003, since latest RMP submission
Training Review Date
Aug. 27, 2003, since latest RMP submission
Maintenance Review Date
Aug. 19, 2003, since latest RMP submission
Maintenance Inspection Date
April 1, 2004, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
March 8, 2004
Management of Change Review Date
April 10, 2004
Pre-startup Review Date
March 31, 2004
Compliance Audit Date
April 28, 2003
Compliance Audit Change Completion Date
April 28, 2004
Incident Investigation Date
May 5, 1999
Incident Invest. Change Completion Date
May 16, 1999
Participation Plan Review Date
June 27, 2003
Hot Work Review Date
Oct. 23, 2003
Contractor Safety Review Date
Sept. 1, 2003, since latest RMP submission
Contractor Safety Eval. Date
Feb. 23, 2004, 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:
Aug. 27, 2003
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:
No
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

Union Carbide Corporation
A Wholly Owned Subsidiary of The Dow Chemical Company
St. Charles Operations Cypress Polypropylene Facility
Risk Management Plan

Union Carbide Corporation St. Charles Operations Cypress Polypropylene Plant LDEQ (Louisiana Department of Environmental Quality) Identification Number is 24946.

1. Accidental Release Prevention and Emergency Response Policies

The St. Charles Operations Cypress Polypropylene Plant of the Union Carbide Corporation (a wholly owned subsidiary of The Dow Chemical Company) is committed to operating and maintaining all of our processes in a safe and responsible manner. We have implemented a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public, as well as to protect the environment. These programs include both Union Carbide's Responsible Care requirements and governmental requirements, such as the Environmental Protection Agency's (EPA) Risk Management Program (RMP) rule and the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) standard and the Louisiana Chemical Accident Prevention Program.

2. Description of the Facility and Regulated Substances

The St. Charles Operations Cypress Polypropylene Plant is a manufacturing facility that annually produces more than 500 million pounds of polypropylene resins. The material produced at this facility is sold to customers in the United States and abroad. Polypropylene is a type of plastic, which is produced in pellet form and then shipped to our customers, primarily in rail cars. The RMP rule requires that if a facility, such as the Cypress Polypropylene Plant, has a specific amount (threshold) or more of any one of 140 toxic and flammable chemicals , the facility must follow the RMP rule requirements for that chemical. The St. Charles Operations Cypress Polypropylene Plant has the following RMP regulated flammable substance: Propylene. N
o RMP toxic substances are stored at the St. Charles Operations Cypress Polypropylene Plant above the threshold quantities.

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

The general accident prevention program consists of compliance with the RMP rule, OSHA's PSM standard, Louisiana Chemical Accident Prevention Program and implementation of Union Carbides Operation Safety Program and Episodic Risk Management System. Key elements include:
Equipment Design: Vessels and other process equipment are designed according to recognized industry standards and/or governmental requirements.
Process Safety Information: Chemical Hazard, process technology, and equipment information is documented, maintained up to date, and available for operating personnel.
Process Hazard Analysis: Process Hazard Analyses are conducted every three years to identify major process hazard scenarios and to recommend corrective actions needed to prevent their occurrence.
Episodic Risk Management: Periodic reviews are conducted to identify hazards which could have significant community impact and to recommend corrective actions needed to prevent their occurrence. These reviews utilize advanced quantitative risk assessment techniques.
Operational Safety Standards: Design requirements for active and passive mitigation controls used to prevent major process hazards are documented in operation safety standards.
Operating Procedures: Operating procedures provide detail on how to safely operate a process and are maintained up to date.
Operator Training/Certification Program: The plant has a training and testing program which provides operators with the proper skills and knowledge prior to allowing them to independently operate a process.
Technical Staff Training and Support: Trained technical staff employees are available 24 hours a day to support operations.
Maintenance Procedures: The plant has specific procedures for maintaining process equipment so that it oper
ates safely.
Maintenance Training: The plant trains persons who perform routine or complex maintenance tasks on process equipment.
Mechanical Integrity Program: Vessels (including shipping containers) and other process equipment are periodically tested/inspected to ensure safe operation of process equipment, following recognized industry standards and/or governmental requirements.
Management of Change: The plant has a management of change process to ensure that modified facilities and process will be safe to operate.
Pre-startup Safety Reviews: Reviews are conducted prior to startup to ensure that modified facilities and process are safe for operation.
Incident Investigation: The plant has a program to ensure that accidents and incidents are properly investigated to determine causes and to implement corrective actions needed to prevent a reoccurrence of the event.
Employee Participation: The plants has a program to involve employees in prevention program elements.
Hot Work Permit: The plant has a procedure to ensure that all open flame work such as welding, cutting, and brazing are safely performed in areas where flammable or combustible materials may be present.
Contractor Safety Program: The plant has a program to ensure that contractors are properly trained and perform their work in compliance with safety requirements.
Compliance Audits: Periodic corporate and plant led audits are conducted to ensure that process operations comply with governmental and DOW requirements.
Process Safety Program: DOW Chemical has a comprehensive program to ensure that all elements listed above are implemented. This program includes accountabilities for timely and proper implementation of the program elements.

These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and employees are committed to the standards that these management systems set. We have specific accountabilities and controls to ensure that we are meeting o
ur own high standards for accident prevention.

4. Five-Year Accident History

In the last five years there has not been an accident or incident involving an EPA RMP chemical at the St. Charles Operations Cypress Polypropylene Plant that resulted in an on-site death, injury, or property damage, or a known off-site death, injury, evacuation, shelter in place, property damage, or environmental damage.

5. Emergency Response Program

The St. Charles Operations Cypress Polypropylene Plant maintains a written emergency response program to protect worker and public safety as well as the environment. The program consists of procedures for responding to releases of hazardous substances, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including:
Proper first aid and medical treatment for exposures
Evacuation plans and accounting for personnel after an evacuation
Notification of local emergency response agencies and the public if a release occurs
Post-incident cleanup and decontamination requirements, and
Inspecting, testing, maintaining, and using emergency response equipment.
The emergency response program is updated when necessary based on modifications made to the facility processes.

The St. Charles Operations Cypress Polypropylene Plant maintains a trained emergency squad to handle fires, explosions, toxic vapor releases, spills, and medical emergencies. The plant squad trains and drills with local emergency responders to enhance their skills and tactics for responding to an accidental chemical release. Critiques are held for drills and actual events. In addition to the plant emergency squad, St. Charles parish DEP is notified immediately of the incident. The DEP determines the community impact and takes the appropriate action to protect the community. Additional resources are also available thru the mutual aid organizations, if needed.

The emergency response
program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Detailed emergency response plans are developed and coordinated with the St. Charles Parish DEP and the community.

6. Planned Changes To Improve Safety

On-going programs, such as process hazard analysis reevaluations, continually aim to improve process safety. The following is a list of specific improvements that we are planning to implement at the St. Charles Operations Cypress Polypropylene Plant to help prevent and/or better respond to accidental chemical releases:
Complete the Layers of Protection Analysis to ensure the necessary layers are in place.
Conduct periodic process hazard analyses for all processes and implement resulting recommendations for improvements to safety equipment and procedures.
Conduct New Leader Reviews so that newly assigned production leaders have all of the process safety and reactive chemicals information necessary for their new jobs.
All new projects are designed around principles of inherent safety so that process safety is integrated directly into the design.
Changes to new or revised systems seek to minimize the quantities of hazardous materials.