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The Dow Chemical Company - Grand Bayou Operations

Parent Companies:
The Dow Chemical Company
EPA Facility ID:
100000135757
Other ID:
Facility DUNS:
8187080
Parent Company DUNS:
1381581

Location:

Address:
Highway 70 South
Belle Rose, LA 70341
County:
ASSUMPTION
Lat / Long:
30.008, -91.111 (Get map)
Method:
Interpolation - Photo
Description:
Plant Entrance (General)
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
2400

Owner/Operator:

Name:
The Dow Chemical Company-GBO
Phone:
(985) 493-6001
Address:
875 Highway 70 South
Belle Rose, LA 70341
Foreign Address:

Person responsible for RMP implementation:

Name:
Michael D. Albano
Title:
Lead EH&S Director

Emergency contact:

Name:
Joey M. Dugas
Title:
Facility Emergency Coordinator
Phone:
(225) 776-2516
24-hour phone:
(225) 353-8888
Ext or PIN:
N/A

Other contacts:

Facility (or company) email:
Facility phone:
(985) 493-6001
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Assumption Parish LEPC
Full-Time Equivalent Employees:
24
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Jan. 20, 2016
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Brine Mining & HC Storage
RMP ID:
1000073366
CBI claimed:
No
Program Level:
3
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ethane
74-84-0
500,000,000
No
Propylene [1-Propene]
115-07-1
100,000,000
No
Butane
106-97-8
100,000,000
No
Propane
74-98-6
600,000,000
No
Chlorine
7782-50-5
8,000
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

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
Sept. 21, 2016
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000058778

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 Brine Mining & HC Storage)
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 Brine Mining & HC Storage)
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:
  • 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 Brine Mining & HC Storage)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Blast walls
Public OCA Chemical (in Brine Mining & HC Storage)
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 Brine Mining & HC Storage)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Water curtain
  • Excess flow valve

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

Brine Mining & HC Storage, Other Basic Inorganic Chemical Manufacturing (32518)
Prevention Program ID:
1000061551
Safety Review Date
June 21, 2016, since latest RMP submission
PHA Update Date
Feb. 24, 2016, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • None
Process Controls
  • None
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
June 8, 2016, since latest RMP submission
Training Review Date
Sept. 30, 2015, since latest RMP submission
Maintenance Review Date
July 19, 2016, since latest RMP submission
Maintenance Inspection Date
July 20, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Aug. 4, 2016
Management of Change Review Date
May 15, 2015
Pre-startup Review Date
June 30, 2016
Compliance Audit Date
June 19, 2014
Compliance Audit Change Completion Date
March 31, 2015
Incident Investigation Date
April 3, 2016
Incident Invest. Change Completion Date
Dec. 31, 2016
Participation Plan Review Date
Nov. 12, 2015
Hot Work Review Date
Jan. 14, 2016
Contractor Safety Review Date
July 20, 2016, since latest RMP submission
Contractor Safety Eval. Date
July 13, 2016, 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:
Sept. 18, 2015
Local Response Agency:
Local Response Agency Phone:
(985) 369-7386
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 Program - 5 Year Update

Executive Summary

The Dow Chemical Company - Grand Bayou Operations



1.Accidental Release Prevention and Emergency Response Policies



We at The Dow Chemical Company-Grand Bayou Operations (Dow-GBO) continue to maintain a strong commitment to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, 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. However, if a release should occur, we are coordinated with the Assumption Parish Office of Emergency Preparedness, which provides additional emergency response expertise.



2.The Stationary Source and the Regulated Substances Handled



Dow-GBO's primary activity includes the solution mining of salt from the Napoleonville Dome, which is located in Assumption Parish and underlies a surface area of approximately 1670 acres. Dow's operations on the Napoleonville Salt Dome began in 1957 with the drilling and mining of the Grace No. 1 well. Since then, an additional 26 Dow operated caverns have been mined into the dome. Seven of the active caverns are in hydrocarbon storage service with total physical storage capacity in excess of 25.6 million barrels. Three caverns are in mining service with a saturated brine deliverability of 4500 gallons per minute. In this resubmission 1 regulated substance, ethylene, was removed since the materials is no longer stored onsite. We have 5 regulated substances present at our facility. These substances (and their maximum inventory, in pounds) include Ethane (500,000,000), Butane (100,000,000), Propylene [1-Propene] (100,000,000), Propane (600,000,000) and Chlorine (8,000).



3.The Worst Case Release Scenarios and the Alternative Release Scenarios.



The WC
S and ARS scenarios remain unchanged from the last resubmission.

In accordance with the 2004 revisions to 40 CFR Part 68 (69 FR 18819-18832, April 9, 2004), it is no longer required to include a discussion of the WCS and ARS in the RMPs Executive Summary. However, their results are included in the body of the submittal.



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



The Dow-GBO facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source.



Process Safety Information



Dow-GBO maintains 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



Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is What If/Checklist (combined), 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. The most recent PHA/update was performed on February 4, 2016.



Operating Procedures



For the purposes of safely conducting activities within our covered processes, Dow-GBO maintains written standard operating procedures (SOPs). These procedures address various modes of operation such as initial startup, normal operations, temporary operations, em
ergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes.



Training



Dow-GBO 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.



Mechanical Integrity



Dow-GBO carries out and duly documents periodic maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes, among others, pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are provided 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 Dow-GBO to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of management of change procedures was performed on May 15, 2015. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions and/or operating practices are promptly made aware of and offered 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 a regular practice at Dow-GBO. The most recent review was performed on June 30 2016. 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



Dow-GBO conducts audits on a regular basis to determine whether the
provisions set out under the RMP rule are being implemented. The most recent compliance audit was conducted on June 9 2014 These audits are carried out at least every 3 years and corrective actions required as a result of the audits are undertaken in a safe and prompt manner.



Incident Investigation



Dow-GBO promptly investigates any incident that has 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 any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years.



Employee Participation



Dow-GBO truly believes that process safety management and accident prevention are a team effort. 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 facilities implementation of the RMP rule, including information resulting from process hazard analyses in particular.



Contractors



Our company 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. Dow-GBO has a system in place to inform the contractors of known potential hazards related to the contractor's work and the processes. Contractors are also required to inform Dow Chemical Company of any hazards they may introduce at the site.



5.Five-year Accident History



Dow-GBO has had an excellent record of preventing accidental releases over the last 5 years. Due to our release prevention policies, there have been no reportable accidental release of regulated substances, as defined by the RMP rule, during this period.



6.Emergency Response Plan



Dow-GBO has a written emergency response plan to deal with acc
idental 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 promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response.



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



7.Planned Changes to Improve Safety



There are no planned changes at this time as a result of our implementing the accidental release prevention program.