houstonlogo rjilogo

The Right-to-Know Network

Back to search

The Dow Chemical Company-Louisiana Operations

Parent Companies:
The Dow Chemical Company
EPA Facility ID:
100000136523
Other ID:
Facility DUNS:
8187080
Parent Company DUNS:
1381581

Location:

Address:
21255 Highway 1
Plaquemine, LA 70765
County:
IBERVILLE
Lat / Long:
30.320, -91.226 (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:
The Dow Chemical Company-Louisiana
Phone:
(225) 353-1824
Address:
Highway 1 South
P.O. Box 150
Plaquemine, LA 70765 -0150
Foreign Address:

Person responsible for RMP implementation:

Name:
Title:
Responsible Care Leader
Email:

Emergency contact:

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

Other contacts:

Facility (or company) email:
Facility phone:
(225) 353-4374
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Iberville/West Baton Rouge Par
Full-Time Equivalent Employees:
1,438
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
2188-V0,2024-V3
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Aug. 3, 2015
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Cellulose
RMP ID:
1000050245
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Methyl ether [Methane, oxybis-]
115-10-6
45,000
No
Propylene oxide [Oxirane, methyl-]
75-56-9
39,000
No
Methyl chloride [Methane, chloro-]
74-87-3
180,000
No
Hydrogen chloride (anhydrous) [Hydrochloric acid]
7647-01-0
25,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Environmental Operations
RMP ID:
1000050248
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Chlorine
7782-50-5
10,000
No
Ammonia (anhydrous)
7664-41-7
40,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Glycol 1
RMP ID:
1000050249
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Propylene oxide [Oxirane, methyl-]
75-56-9
20,211,400
No
Epichlorohydrin [Oxirane, (chloromethyl)-]
106-89-8
150,500
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Glycol 2
RMP ID:
1000050250
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ethylene oxide [Oxirane]
75-21-8
2,500,000
No
Ethyl chloride [Ethane, chloro-]
75-00-3
150,000
No
Chlorine
7782-50-5
14,000
No
Ethylene [Ethene]
74-85-1
51,000
No
Methane
74-82-8
56,000
No
Methylamine [Methanamine]
74-89-5
500,000
No
Ammonia (anhydrous)
7664-41-7
60,000
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
LHC 2
RMP ID:
1000050251
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ethane
74-84-0
1,500,000
No
Hydrogen
1333-74-0
200,000
No
1-Butene
106-98-9
31,258
No
1,3-Butadiene
106-99-0
107,346
No
Propylene [1-Propene]
115-07-1
1,450,000
No
Butane
106-97-8
13,986
No
Ethylene [Ethene]
74-85-1
1,000,000
No
Methane
74-82-8
26,000
No
Propane
74-98-6
310,000
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
LHC 3
RMP ID:
1000050252
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
1,3-Butadiene
106-99-0
8,150,000
No
Ethane
74-84-0
1,500,000
No
Methane
74-82-8
35,000
No
Propane
74-98-6
80,000,000
No
2-Methylpropene [1-Propene, 2-methyl-]
115-11-7
3,607,365
No
Propylene [1-Propene]
115-07-1
1,600,000
No
Ethylene [Ethene]
74-85-1
2,900,000
No
Isoprene [1,3-Butadiene, 2-methyl-]
78-79-5
3,183,107
No
1,3-Pentadiene
504-60-9
2,200,000
No
1-Butene
106-98-9
1,966,177
No
2-Butene-cis
590-18-1
1,332,450
No
2-Methyl-1-butene
563-46-2
336,000
No
Butane
106-97-8
2,892,736
No
Isopentane [Butane, 2-methyl-]
78-78-4
498,000
No
Hydrogen
1333-74-0
125,000
No
Pentane
109-66-0
11,234,000
No
Isobutane [Propane, 2-methyl]
75-28-5
162,494
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
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
Energy Systems
RMP ID:
1000050253
CBI claimed:
No
Program Level:
3
NAICS:
Other Electric Power Generation (221118)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
59,725
No
Chlorine
7782-50-5
5,200
No
Hydrogen
1333-74-0
47,500
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Poly A
RMP ID:
1000050254
CBI claimed:
No
Program Level:
3
NAICS:
Plastics Material and Resin Manufacturing (325211)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ethylene [Ethene]
74-85-1
60,000
No
Public OCA Chemical
0
No
Poly B
RMP ID:
1000050255
CBI claimed:
No
Program Level:
3
NAICS:
Plastics Material and Resin Manufacturing (325211)
Chemical name
CAS#
Quantity (lbs.)
CBI
1-Butene
106-98-9
430,000
No
Propylene [1-Propene]
115-07-1
170,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Poly C
RMP ID:
1000050256
CBI claimed:
No
Program Level:
3
NAICS:
Plastics Material and Resin Manufacturing (325211)
Chemical name
CAS#
Quantity (lbs.)
CBI
Hydrogen chloride (anhydrous) [Hydrochloric acid]
7647-01-0
6,000
No
Chlorine
7782-50-5
4,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Railroad:Rail Car Storage
RMP ID:
1000050258
CBI claimed:
No
Program Level:
3
NAICS:
Support Activities for Rail Transportation (48821)
Chemical name
CAS#
Quantity (lbs.)
CBI
Methylamine [Methanamine]
74-89-5
4,800,000
No
Ammonia (anhydrous)
7664-41-7
1,800,000
No
Methyl chloride [Methane, chloro-]
74-87-3
7,200,000
No
1,3-Butadiene
106-99-0
1,200,000
No
Isoprene [1,3-Butadiene, 2-methyl-]
78-79-5
1,200,000
No
1-Butene
106-98-9
1,550,000
No
Methyl ether [Methane, oxybis-]
115-10-6
2,700,000
No
Ethylene oxide [Oxirane]
75-21-8
20,640,457
No
Propylene oxide [Oxirane, methyl-]
75-56-9
3,348,147
No
Hydrogen chloride (anhydrous) [Hydrochloric acid]
7647-01-0
2,271,092
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

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
July 20, 2016
Type:
Resubmission
Reason:
Voluntary update (not described by any of the above reasons)
Registered:
Yes
RMP ID:
1000040785

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 Glycol 2)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
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 Cellulose)
CBI claimed:
No
Percent weight:
30.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
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
Public OCA Chemical (in Cellulose)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
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
Public OCA Chemical (in Glycol 1)
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:
Urban
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
Public OCA Chemical (in Glycol 1)
CBI claimed:
No
Percent weight:
30.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
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
Public OCA Chemical (in Glycol 2)
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:
Urban
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
Public OCA Chemical (in Energy Systems)
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:
Urban
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
Public OCA Chemical (in Poly C)
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:
Urban
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 LHC 3)
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 Glycol 2)
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
  • Deluge systems
  • Water curtain
  • Excess flow valve
Public OCA Chemical (in LHC 3)
CBI claimed:
No
Model used:
PHAST
Passive mitigation
considered:
  • None
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

Oct. 24, 2013 at 19:18
ID:
1000033133
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Duration:
7 minutes
Chemicals involved:
  • Chlorine
Release events:
Liquid spills/evaporation
Weather conditions at time of event
Wind speed:
2.5 miles/h SW
Temperature:
67.00 ℉
Atmospheric stability:
F
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:
0
Property damage:
$0
Environmental damage:
Initiating event:
Human Error
Contributing factors:
  • Maintenance activity/inactivity
Off-site responders notified:
No, not notified
Changes introduced as a result of the accident:
  • Revised operating procedures

7. Prevention: Program level 3

Cellulose, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000042978
Safety Review Date
Oct. 14, 2015, since latest RMP submission
PHA Update Date
Dec. 4, 2013, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Corrosion
  • Overfilling
  • Equipment failure
  • Cooling loss
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • Reduced Inventory
  • Increased Inventory
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
Oct. 2, 2015, since latest RMP submission
Training Review Date
Dec. 10, 2014, since latest RMP submission
Maintenance Review Date
Sept. 26, 2015, since latest RMP submission
Maintenance Inspection Date
Nov. 13, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Sept. 22, 2015
Management of Change Review Date
July 20, 2015
Pre-startup Review Date
Oct. 14, 2015
Compliance Audit Date
March 7, 2016
Compliance Audit Change Completion Date
March 7, 2017
Incident Investigation Date
May 20, 2015
Incident Invest. Change Completion Date
Dec. 31, 2015
Participation Plan Review Date
Dec. 9, 2015
Hot Work Review Date
June 18, 2015
Contractor Safety Review Date
May 12, 2016, since latest RMP submission
Contractor Safety Eval. Date
May 12, 2016, since latest RMP submission
Environmental Operations, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000042968
Safety Review Date
Feb. 15, 2016, since latest RMP submission
PHA Update Date
March 17, 2014, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Grounding Equipment
  • Excess Flow Device
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
  • Water Curtain
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
  • Process Detection
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
Dec. 1, 2015, since latest RMP submission
Training Review Date
Nov. 18, 2015, since latest RMP submission
Maintenance Review Date
Aug. 24, 2015, since latest RMP submission
Maintenance Inspection Date
June 30, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Feb. 3, 2015
Management of Change Review Date
Nov. 18, 2015
Pre-startup Review Date
June 2, 2015
Compliance Audit Date
Oct. 17, 2015
Compliance Audit Change Completion Date
April 30, 2016
Incident Investigation Date
Sept. 1, 2015
Incident Invest. Change Completion Date
Feb. 3, 2016
Participation Plan Review Date
Dec. 9, 2015
Hot Work Review Date
June 17, 2014
Contractor Safety Review Date
May 9, 2012, since latest RMP submission
Contractor Safety Eval. Date
May 9, 2012, since latest RMP submission
Glycol 1, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000042969
Safety Review Date
Oct. 31, 2013, since latest RMP submission
PHA Update Date
Oct. 31, 2013, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
  • Water Curtain
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
Oct. 13, 2015, since latest RMP submission
Training Review Date
Nov. 10, 2014, since latest RMP submission
Maintenance Review Date
May 1, 2015, since latest RMP submission
Maintenance Inspection Date
June 3, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Sept. 1, 2015
Management of Change Review Date
Oct. 24, 2014
Pre-startup Review Date
June 3, 2013
Compliance Audit Date
Oct. 14, 2014
Compliance Audit Change Completion Date
Dec. 31, 2015
Incident Investigation Date
March 31, 2015
Incident Invest. Change Completion Date
Sept. 13, 2015
Participation Plan Review Date
Dec. 9, 2015
Hot Work Review Date
Oct. 14, 2014
Contractor Safety Review Date
May 12, 2016, since latest RMP submission
Contractor Safety Eval. Date
May 12, 2016, since latest RMP submission
Glycol 2, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000042970
Safety Review Date
July 1, 2015, since latest RMP submission
PHA Update Date
April 9, 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
  • 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
  • Blast Walls
  • Deluge System
  • Water Curtain
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
Feb. 19, 2016, since latest RMP submission
Training Review Date
June 19, 2015, since latest RMP submission
Maintenance Review Date
April 24, 2015, since latest RMP submission
Maintenance Inspection Date
July 23, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
July 30, 2015
Management of Change Review Date
July 29, 2015
Pre-startup Review Date
May 11, 2015
Compliance Audit Date
July 17, 2015
Compliance Audit Change Completion Date
Jan. 31, 2016
Incident Investigation Date
Nov. 12, 2013
Incident Invest. Change Completion Date
Oct. 31, 2014
Participation Plan Review Date
Nov. 3, 2014
Hot Work Review Date
Jan. 25, 2016
Contractor Safety Review Date
May 12, 2016, since latest RMP submission
Contractor Safety Eval. Date
May 12, 2016, since latest RMP submission
LHC 2, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000042971
Safety Review Date
Nov. 30, 2015, since latest RMP submission
PHA Update Date
Aug. 31, 2013, 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
  • Quench System
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Fire Walls
  • Blast Walls
  • Deluge System
  • Water Curtain
  • Neutralization
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
March 31, 2016, since latest RMP submission
Training Review Date
Oct. 31, 2015, since latest RMP submission
Maintenance Review Date
March 4, 2015, since latest RMP submission
Maintenance Inspection Date
Feb. 3, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
March 31, 2015
Management of Change Review Date
Sept. 30, 2015
Pre-startup Review Date
April 7, 2016
Compliance Audit Date
Aug. 29, 2013
Compliance Audit Change Completion Date
Feb. 4, 2014
Incident Investigation Date
Feb. 16, 2016
Incident Invest. Change Completion Date
April 30, 2016
Participation Plan Review Date
Dec. 7, 2015
Hot Work Review Date
Dec. 15, 2015
Contractor Safety Review Date
May 12, 2016, since latest RMP submission
Contractor Safety Eval. Date
May 12, 2016, since latest RMP submission
LHC 3, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000042972
Safety Review Date
Feb. 1, 2016, since latest RMP submission
PHA Update Date
Aug. 31, 2013, 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
  • Quench System
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
March 21, 2016, since latest RMP submission
Training Review Date
Oct. 31, 2015, since latest RMP submission
Maintenance Review Date
April 7, 2016, since latest RMP submission
Maintenance Inspection Date
Feb. 5, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 26, 2016
Management of Change Review Date
Sept. 30, 2015
Pre-startup Review Date
April 7, 2016
Compliance Audit Date
Aug. 29, 2013
Compliance Audit Change Completion Date
Feb. 4, 2014
Incident Investigation Date
Jan. 18, 2016
Incident Invest. Change Completion Date
July 31, 2016
Participation Plan Review Date
Dec. 7, 2015
Hot Work Review Date
July 24, 2015
Contractor Safety Review Date
May 12, 2016, since latest RMP submission
Contractor Safety Eval. Date
May 12, 2016, since latest RMP submission
Energy Systems, Other Electric Power Generation (221118)
Prevention Program ID:
1000042980
Safety Review Date
Jan. 26, 2016, since latest RMP submission
PHA Update Date
July 23, 2015, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
  • Enclosure
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
March 22, 2016, since latest RMP submission
Training Review Date
July 6, 2015, since latest RMP submission
Maintenance Review Date
April 6, 2016, since latest RMP submission
Maintenance Inspection Date
Feb. 15, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Jan. 25, 2016
Management of Change Review Date
Feb. 6, 2016
Pre-startup Review Date
Nov. 13, 2015
Compliance Audit Date
March 24, 2014
Compliance Audit Change Completion Date
April 13, 2015
Incident Investigation Date
Jan. 20, 2016
Incident Invest. Change Completion Date
Feb. 15, 2016
Participation Plan Review Date
Jan. 15, 2015
Hot Work Review Date
April 30, 2015
Contractor Safety Review Date
May 12, 2016, since latest RMP submission
Contractor Safety Eval. Date
May 12, 2016, since latest RMP submission
Poly A, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000042973
Safety Review Date
March 9, 2015, since latest RMP submission
PHA Update Date
June 26, 2014, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Corrosion
  • Overfilling
  • Equipment failure
  • Cooling loss
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Blast Walls
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
Sept. 28, 2015, since latest RMP submission
Training Review Date
Oct. 21, 2014, since latest RMP submission
Maintenance Review Date
June 10, 2015, since latest RMP submission
Maintenance Inspection Date
Sept. 15, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Aug. 24, 2015
Management of Change Review Date
Oct. 21, 2014
Pre-startup Review Date
Aug. 29, 2015
Compliance Audit Date
March 9, 2015
Compliance Audit Change Completion Date
Dec. 31, 2015
Incident Investigation Date
April 16, 2011
Incident Invest. Change Completion Date
Aug. 10, 2011
Participation Plan Review Date
Dec. 9, 2015
Hot Work Review Date
Feb. 13, 2012
Contractor Safety Review Date
May 12, 2016, since latest RMP submission
Contractor Safety Eval. Date
May 12, 2016, since latest RMP submission
Poly B, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000042974
Safety Review Date
Aug. 4, 2015, since latest RMP submission
PHA Update Date
April 13, 2014, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • None
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
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Fire Walls
  • Deluge System
  • Water Curtain
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
Aug. 24, 2015, since latest RMP submission
Training Review Date
Oct. 3, 2014, since latest RMP submission
Maintenance Review Date
June 25, 2015, since latest RMP submission
Maintenance Inspection Date
Aug. 24, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Aug. 4, 2015
Management of Change Review Date
Jan. 29, 2015
Pre-startup Review Date
Aug. 4, 2015
Compliance Audit Date
Dec. 9, 2013
Compliance Audit Change Completion Date
Aug. 29, 2014
Incident Investigation Date
May 9, 2015
Incident Invest. Change Completion Date
Sept. 3, 2015
Participation Plan Review Date
Dec. 9, 2015
Hot Work Review Date
June 5, 2014
Contractor Safety Review Date
May 12, 2016, since latest RMP submission
Contractor Safety Eval. Date
May 12, 2016, since latest RMP submission
Poly C, Plastics Material and Resin Manufacturing (325211)
Prevention Program ID:
1000042975
Safety Review Date
June 30, 2015, since latest RMP submission
PHA Update Date
June 17, 2013, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • 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
  • Rupture Disks
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Fire Walls
  • Deluge System
  • Water Curtain
  • Neutralization
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
Sept. 25, 2015, since latest RMP submission
Training Review Date
Nov. 6, 2013, since latest RMP submission
Maintenance Review Date
Sept. 25, 2015, since latest RMP submission
Maintenance Inspection Date
June 27, 2012, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Sept. 25, 2015
Management of Change Review Date
June 27, 2012
Pre-startup Review Date
July 23, 2015
Compliance Audit Date
Jan. 12, 2016
Compliance Audit Change Completion Date
Dec. 31, 2016
Incident Investigation Date
Dec. 31, 2014
Incident Invest. Change Completion Date
June 30, 2016
Participation Plan Review Date
Dec. 9, 2015
Hot Work Review Date
Sept. 25, 2015
Contractor Safety Review Date
May 12, 2016, since latest RMP submission
Contractor Safety Eval. Date
May 12, 2016, since latest RMP submission
Railroad:Rail Car Storage, Support Activities for Rail Transportation (48821)
Prevention Program ID:
1000042977
Safety Review Date
April 25, 2012, since latest RMP submission
PHA Update Date
Oct. 26, 2015, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Equipment failure
  • Hurricanes
Process Controls
  • Relief Valves
  • Excess Flow Device
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • Reduced Inventory
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
Nov. 5, 2015, since latest RMP submission
Training Review Date
Jan. 15, 2015, since latest RMP submission
Maintenance Review Date
Oct. 29, 2015, since latest RMP submission
Maintenance Inspection Date
April 16, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Sept. 30, 2015
Management of Change Review Date
Nov. 5, 2015
Pre-startup Review Date
None
Compliance Audit Date
Oct. 12, 2015
Compliance Audit Change Completion Date
Aug. 1, 2016
Incident Investigation Date
Sept. 28, 2015
Incident Invest. Change Completion Date
Nov. 10, 2015
Participation Plan Review Date
Nov. 16, 2011
Hot Work Review Date
Nov. 30, 2015
Contractor Safety Review Date
May 12, 2016, since latest RMP submission
Contractor Safety Eval. Date
May 12, 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:
June 11, 2012
Local Response Agency:
Local Response Agency Phone:
(225) 687-5104
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 - Resubmission for: 3 Processes transferred to owner and covered under a new RMP.



The Dow Chemical Company

Louisiana Operations



1409-LDEQ Facility ID Number



This Resubmission is being made to update the Dow Chemical Company, Louisiana Operations RMP to remove existing covered processes that have been transferred to new owners. The covered processes, Chorine, Methanes, and Solvents/EDC, were transferred to a new owner (Olin) effective October 5, 2015, and incorporated into a new Olin RMP on March 9, 2016.



1. Accidental Release Prevention and Emergency Response Policies

The Dow Chemical Company-Louisiana Operations (Dow-LAO) continues to be strongly committed to employee, public and environmental safety, as demonstrated by Dow - LAO's comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at the facility. It is Dow - LAO's policy to implement the necessary and appropriate controls to prevent possible releases of regulated substances. If such a release does occur, Dow - LAO's well-trained emergency response personnel are at hand to control and mitigate the effects of the release. Dow - LAO is also completely coordinated with the Iberville and West Baton Rouge Parishes Office of Emergency Preparedness (LEPC) which provides additional emergency response expertise.



2. The Stationary Source and the Regulated Substances Handled

Dow - LAO started operations in 1956 with 3 production units. At present Dow continues to own and operate 10 production units, producing many different products used in a wide variety of consumer products such as Tupperware, antifreeze, shampoo ingredients, automotive fluids, and cosmetics,. The 10 productions units and 1 logistics department are RMP covered processes. Dow - LAO uses natural gas to produce the basic chemical ingredient, ethylene and propylene, which are furt
her used to produce the final products. We have 28 regulated substances present at our facility.



Ethtylene Oxide is used for the production of monoethylene glycol (MEG) and for the production of ethylene oxide derivatives such as glycol ethers, polyglycols, polyether polyols, diethylene, triethylene and tetraethylene glycols (DEG, TEG and Tetra) and ethanolamines. EO is both flammable and highly reactive. Acute exposures to EO gas may result in respiratory irritation and lung injury, headache, nausea, vomiting, diarrhea, shortness of breath, and cyanosis. Chronic exposure has been associated with the occurrence of cancer, reproductive effects, mutagenic changes, neurotoxicity, and sensitization.



Anhydrous hydrogen chloride is used at Dow - LAO for water treatment. Inhalation can cause coughing, choking, inflammation and ulceration of the respiratory tract.



Butadiene is a byproduct of ethylene production and is sold to make tires, automotive parts, roofing materials and other consumer products. It is a colorless, flammable gas with a mild aromatic odor. High vapor concentrations could cause eye, nose, throat irritation and dizziness.



Chlorine is an element that occurs naturally as sodium chloride (table salt). It is used to purify 98% of our nation's drinking water, is in 85% of all medicines, is used in hospital sanitation, and is used at Dow - LAO's for water treatment. Chlorine is a greenish yellow gas with a strong, irritating odor. The vapor can be irritating to the eyes, nose and throat. High concentrations could cause more serious problems.



RMP regulated substances at the Louisiana Division are listed in the following table.

RMP Regulated Substance

1,3-Butadiene

1,3-Pentadiene

1-Butene

2-Butene-cis

2-Methyl-1-butene

2-Methylpropene

Ammonia

Butane

Chlorine

Chloroform

Epichlorohydrin

Ethane

Ethyl chloride

Ethylene

Ethylene oxide

Hydrogen

Hydrogen chloride/Hydrochloric Acid

Isobutane

Isopentane

I
soprene

Methane

Methyl chloride

Methyl ether

Methylamine

Pentane

Propane

Propylene

Propylene oxide



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

Dow - LAO 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 was designed and constructed in accordance with Dow Loss Prevention Principles and Dow Engineering Standards. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source.



Process Safety Information

The Dow Chemical Company-Louisiana Operations 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

Dow - LAO 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 What If/Checklist (combined), HAZOP, 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. Any f
indings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on September 26, 2012.



Operating Procedures

For the purposes of safely conducting activities within the covered processes, Dow - LAO maintains and periodically updates written standard operating procedures (SOPs). 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 involved in the processes.



Training

Dow - LAO 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. All new employees are provided the applicable training (initial class-room training and on-the-job mentoring), depending on the nature and location of their assignments, before they are allowed to perform on their own. Refresher training is provided as needed.



Mechanical Integrity

Dow - LAO 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 checks 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. Any 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 - LAO to manage changes in process chemicals, technology, equipme
nt 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 a regular practice at Dow - LAO. 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 - LAO 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 least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner.



Incident Investigation

Dow - LAO 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. There have been no RMP-reportable incidents at Dow - LAO facility in the last 5 years.





Employee Participation

Dow - LAO 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, all Dow - LAO 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

Dow - LAO hires contractors to conduct specialized maintenance, construction and various other activities. Prior to sel
ecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Dow - LAO 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 all the procedures for emergency response should an accidental release of a regulated substance occur. Contractors are also required to inform Dow Chemical Company of any hazards they may introduce at the site.



5. Five-year Accident History

Dow - LAO has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, the number of accidental releases has been reduced to a minimum.



There was one RMP-reportable accidental release as defined by the RMP rule of regulated substances from our facility within the last 5 years which occurred on October 23, 2013.



6. Emergency Response Plan

Dow - LAO carries 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 promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response.

Iberville and West Baton Rouge Parishes Office of Emergency Preparedness (LEPC) are 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 to improve safety at this time as a result of our implementing the accidental release prevention program.