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Rubicon LLC

Parent Companies:
EPA Facility ID:
100000146781
Other ID:
70734RBCNN9156
Facility DUNS:
8213191

Location:

Address:
9156 Highway 75
Geismar, LA 70734
County:
ASCENSION
Lat / Long:
30.201, -91.014 (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:
Rubicon LLC
Phone:
(225) 673-6141
Address:
9156 Highway 75
Geismar, LA 70734
Foreign Address:

Person responsible for RMP implementation:

Name:
Mark K. Dearman
Title:
General Manager
Email:

Emergency contact:

Name:
Mitch Latuso
Title:
Polyols Shift Foreman
Phone:
(225) 744-5417
24-hour phone:
(225) 744-5417
Ext or PIN:
Email:
N/A

Other contacts:

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

Safety:

Local Emergency Planning Committee:
Ascension Parish LEPC
Full-Time Equivalent Employees:
614
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
2391-V15
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Sept. 20, 2011
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

POLYOLS
RMP ID:
1000070647
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
120,000
No
Propylene oxide [Oxirane, methyl-]
75-56-9
430,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Reductions
RMP ID:
1000070648
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
400,000
No
Public OCA Chemical
0
No
Chlorine Dist. System
RMP ID:
1000070649
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Chlorine
7782-50-5
38,000
No
Public OCA Chemical
0
No
MDI I
RMP ID:
1000070650
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Formaldehyde (solution)
50-00-0
250,000
No
Phosgene [Carbonic dichloride]
75-44-5
25,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
MDI II
RMP ID:
1000070651
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Phosgene [Carbonic dichloride]
75-44-5
11,000
No
Public OCA Chemical
0
No
MDI III
RMP ID:
1000070652
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Phosgene [Carbonic dichloride]
75-44-5
26,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
April 8, 2016
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000056599

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 MDI I)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas liquified by pressure
Model used:
TRACE Version 10.1
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 POLYOLS)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas liquified by refrigeration
Model used:
TRACE Version 10.1
Wind speed (meters per sec):
2.60
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 POLYOLS)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Liquid
Model used:
TRACE Version 10.1
Wind speed (meters per sec):
2.60
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 Reductions)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas liquified by pressure
Model used:
TRACE Version 10.1
Wind speed (meters per sec):
2.60
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 Chlorine Dist. System)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas liquified by pressure
Model used:
TRACE Version 10.1
Wind speed (meters per sec):
2.60
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 MDI I)
CBI claimed:
No
Percent weight:
44.0
Physical state:
Liquid
Model used:
TRACE Version 10.1
Wind speed (meters per sec):
2.60
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 MDI III)
CBI claimed:
No
Percent weight:
73.0
Physical state:
Gas liquified by refrigeration
Model used:
TRACE Version 10.1
Wind speed (meters per sec):
2.60
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

4. Flammables: Worst-case

None

5. Flammables: Alternative release

None

6. Five-year accident history

April 21, 2016 at 17:20
ID:
1000046577
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Duration:
5 minutes
Chemicals involved:
  • Phosgene [Carbonic dichloride]
Release events:
Liquid spills/evaporation
Weather conditions at time of event
Wind speed:
9.0 miles/h SW
Temperature:
78.00 ℉
Atmospheric stability:
C
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:
2
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:
Equipment Failure
Contributing factors:
  • Equipment failure
  • Human error
Off-site responders notified:
Notified Only
Changes introduced as a result of the accident:
  • Revised training
  • Revised operating procedures
  • Change piping configuration
April 6, 2016 at 11:00
ID:
1000046418
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Duration:
2 minutes
Chemicals involved:
  • Phosgene [Carbonic dichloride]
Release events:
Gas release
Weather conditions at time of event
Wind speed:
13.1999998 miles/h SSW
Temperature:
71.00 ℉
Atmospheric stability:
C
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:
Equipment Failure
Contributing factors:
  • Equipment failure
Off-site responders notified:
Notified Only
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Revised training
  • Revised operating procedures
Nov. 11, 2015 at 13:40
ID:
1000043904
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Duration:
40 minutes
Chemicals involved:
  • Phosgene [Carbonic dichloride]
Release events:
Gas release
Weather conditions at time of event
Wind speed:
11.0 miles/h S
Temperature:
82.00 ℉
Atmospheric stability:
C
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:
0
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:
2000
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Equipment failure
  • Overpressurization
  • Loss of Power
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • New process controls
  • New mitigation systems
Oct. 29, 2015 at 07:50
ID:
1000043903
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Duration:
5 minutes
Chemicals involved:
  • Phosgene [Carbonic dichloride]
Release events:
Liquid spills/evaporation
Weather conditions at time of event
Wind speed:
6.69999981 miles/h NW
Temperature:
66.00 ℉
Atmospheric stability:
D
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:
  • Road Closure
Initiating event:
Equipment Failure
Contributing factors:
  • Equipment failure
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Removed instrument from process
May 12, 2014 at 16:20
ID:
1000043819
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Duration:
24 minutes
Chemicals involved:
  • Phosgene [Carbonic dichloride]
Release events:
Gas release
Weather conditions at time of event
Wind speed:
10.0 miles/h SSE
Temperature:
89.00 ℉
Atmospheric stability:
C
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:
0
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:
1000
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Equipment failure
  • Overpressurization
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Changed process controls for emergency shutdown
Sept. 24, 2013 at 07:56
ID:
1000043818
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Duration:
32 minutes
Chemicals involved:
  • Ammonia (anhydrous)
Release events:
Gas release
Weather conditions at time of event
Wind speed:
4.0 miles/h ESE
Temperature:
80.00 ℉
Atmospheric stability:
B
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:
0
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:
300
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Equipment failure
  • Overpressurization
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Revised operating procedures
  • New mitigation systems
  • Changed process

7. Prevention: Program level 3

POLYOLS, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000059133
Safety Review Date
March 23, 2016, since latest RMP submission
PHA Update Date
May 23, 2011, since latest RMP submission
PHA Techniques
  • What if
  • HAZOP
Hazards Identified
  • None
Process Controls
  • None
Mitigation Systems
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Parameters
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
March 16, 2016, since latest RMP submission
Training Review Date
Jan. 22, 2016, since latest RMP submission
Maintenance Review Date
March 21, 2016, since latest RMP submission
Maintenance Inspection Date
Sept. 22, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
March 24, 2016
Management of Change Review Date
Dec. 28, 2015
Pre-startup Review Date
March 17, 2016
Compliance Audit Date
Aug. 23, 2013
Compliance Audit Change Completion Date
March 31, 2016
Incident Investigation Date
April 4, 2016
Incident Invest. Change Completion Date
April 29, 2016
Participation Plan Review Date
Sept. 2, 2015
Hot Work Review Date
Aug. 15, 2013
Contractor Safety Review Date
Jan. 6, 2016, since latest RMP submission
Contractor Safety Eval. Date
April 1, 2016, since latest RMP submission
Reductions, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000059134
Safety Review Date
April 1, 2016, since latest RMP submission
PHA Update Date
May 9, 2011, since latest RMP submission
PHA Techniques
  • What if
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Equipment failure
  • Floods
Process Controls
  • None
Mitigation Systems
  • Dikes
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • Process Parameters
  • Process Controls
  • Mitigation Systems
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
Jan. 19, 2016, since latest RMP submission
Training Review Date
Jan. 22, 2016, since latest RMP submission
Maintenance Review Date
March 21, 2016, since latest RMP submission
Maintenance Inspection Date
March 21, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
March 22, 2016
Management of Change Review Date
Dec. 28, 2015
Pre-startup Review Date
March 2, 2016
Compliance Audit Date
Aug. 23, 2013
Compliance Audit Change Completion Date
March 31, 2016
Incident Investigation Date
March 27, 2016
Incident Invest. Change Completion Date
April 30, 2016
Participation Plan Review Date
Sept. 2, 2015
Hot Work Review Date
Aug. 15, 2013
Contractor Safety Review Date
Jan. 6, 2016, since latest RMP submission
Contractor Safety Eval. Date
April 1, 2016, since latest RMP submission
Chlorine Dist. System, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000059135
Safety Review Date
Dec. 11, 2013, since latest RMP submission
PHA Update Date
June 11, 2012, since latest RMP submission
PHA Techniques
  • What if
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Contamination
  • Cooling loss
  • Tornado
  • Hurricanes
Process Controls
  • None
Mitigation Systems
  • Deluge System
  • Neutralization
Monitoring Systems
  • None
Changes since PHA
  • None Recommended
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
Jan. 6, 2016, since latest RMP submission
Training Review Date
Jan. 22, 2016, since latest RMP submission
Maintenance Review Date
March 21, 2016, since latest RMP submission
Maintenance Inspection Date
March 21, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 20, 2015
Management of Change Review Date
Dec. 28, 2015
Pre-startup Review Date
Aug. 21, 2015
Compliance Audit Date
Aug. 23, 2013
Compliance Audit Change Completion Date
March 31, 2016
Incident Investigation Date
March 20, 2015
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Sept. 2, 2015
Hot Work Review Date
Aug. 15, 2013
Contractor Safety Review Date
Jan. 6, 2016, since latest RMP submission
Contractor Safety Eval. Date
April 1, 2016, since latest RMP submission
MDI I, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000059136
Safety Review Date
April 1, 2016, since latest RMP submission
PHA Update Date
June 4, 2014, since latest RMP submission
PHA Techniques
  • What if
  • HAZOP
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
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Rupture Disks
Mitigation Systems
  • Dikes
  • Deluge System
  • Neutralization
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Parameters
  • Process Controls
  • Process Detection
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
Feb. 1, 2016, since latest RMP submission
Training Review Date
Jan. 22, 2016, since latest RMP submission
Maintenance Review Date
March 21, 2016, since latest RMP submission
Maintenance Inspection Date
March 24, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Feb. 22, 2016
Management of Change Review Date
Dec. 28, 2015
Pre-startup Review Date
March 16, 2016
Compliance Audit Date
Aug. 23, 2013
Compliance Audit Change Completion Date
March 31, 2016
Incident Investigation Date
Sept. 26, 2016
Incident Invest. Change Completion Date
Sept. 26, 2019
Participation Plan Review Date
Sept. 2, 2015
Hot Work Review Date
Aug. 15, 2013
Contractor Safety Review Date
Jan. 6, 2016, since latest RMP submission
Contractor Safety Eval. Date
April 1, 2016, since latest RMP submission
MDI II, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000059137
Safety Review Date
April 4, 2016, since latest RMP submission
PHA Update Date
Oct. 20, 2015, since latest RMP submission
PHA Techniques
  • What if
  • HAZOP
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
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Dikes
  • Deluge System
  • Neutralization
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Detection
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
March 3, 2016, since latest RMP submission
Training Review Date
Jan. 22, 2016, since latest RMP submission
Maintenance Review Date
March 21, 2016, since latest RMP submission
Maintenance Inspection Date
March 3, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
March 3, 2016
Management of Change Review Date
Dec. 28, 2015
Pre-startup Review Date
March 16, 2016
Compliance Audit Date
Aug. 23, 2013
Compliance Audit Change Completion Date
March 31, 2016
Incident Investigation Date
Sept. 26, 2016
Incident Invest. Change Completion Date
Sept. 26, 2019
Participation Plan Review Date
Sept. 2, 2015
Hot Work Review Date
Aug. 15, 2013
Contractor Safety Review Date
Jan. 6, 2016, since latest RMP submission
Contractor Safety Eval. Date
April 1, 2016, since latest RMP submission
MDI III, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000059138
Safety Review Date
April 1, 2016, since latest RMP submission
PHA Update Date
March 27, 2015, since latest RMP submission
PHA Techniques
  • What if
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Floods
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Rupture Disks
Mitigation Systems
  • Dikes
  • Deluge System
  • Neutralization
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
  • Process Detection
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
Jan. 26, 2016, since latest RMP submission
Training Review Date
Jan. 22, 2016, since latest RMP submission
Maintenance Review Date
March 21, 2016, since latest RMP submission
Maintenance Inspection Date
March 31, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
March 29, 2016
Management of Change Review Date
Dec. 28, 2015
Pre-startup Review Date
April 1, 2016
Compliance Audit Date
Aug. 23, 2013
Compliance Audit Change Completion Date
March 31, 2016
Incident Investigation Date
March 18, 2016
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Sept. 2, 2015
Hot Work Review Date
Aug. 15, 2013
Contractor Safety Review Date
Jan. 6, 2016, since latest RMP submission
Contractor Safety Eval. Date
April 1, 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:
Oct. 20, 2015
Local Response Agency:
Local Response Agency Phone:
(225) 621-8360
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

Rubicon LLC

Geismar Facility

LDEQ AI:1468



Facility Overview



Rubicon LLC (Rubicon) is located near the city of Geismar, Louisiana in Ascension Parish. Specifically, Rubicon is located on Highway 75 about 1 mile south of the intersection of Highway 75 and Highway 73. Rubicon employs over 600 people including contract workers and manufactures chemicals that produce three main products: 1. Polyurethanes, 2. Antioxidant Additives, and 3. Maleic Anhydride. These products have a wide variety of commercial uses including automotive, marine, building materials, appliances, footwear, and sporting goods.



Rubicon handles six regulated chemicals above the Risk Management Program (RMP) threshold in its chemical manufacturing processes. These chemicals are ammonia, chlorine, ethylene oxide, formaldehyde, phosgene, and propylene oxide .



The 24 hour emergency contact listed in Section 1.8 of the RMP Plan is the Polyols Unit Shift Foreman which is an on-site shift foreman position that is manned at all times. Mitch Latuso, Bobby Martinez, Darren Jackson, and Ty Gaines currently fill this position.



Accidental Release Prevention and Emergency Response Policies



Rubicon's philosophy is that it is the responsibility of management and all other employees to operate safe, clean and efficient facilities in an environmentally and socially responsible manner. This is achieved by striving for continuous improvement through the implementation of programs such as Responsible Care and the OSHA Voluntary Protection Program (VPP). Rubicon has achieved the Star among Stars Qualifier designation under VPP . Other elements of this philosophy include ensuring that all employees have received adequate training on their Environmental Health & Safety (EHS) responsibilities and that all employees are held accountable for their EHS performance.



General Accidental Release Prevention Program and Chemical-Specific Prevention Steps



Rubicon is subject to several EPA and OSHA r
egulations including OSHA Process Safety Management Regulations and EPA Risk Management Program Regulations. Rubicon has management systems in place that provide for the assessment of risks associated with the manufacturing and handling of chemicals and for the continuous improvement of associated processes. Rubicon's philosophy is prevention first, through the use of good engineering design and nationally accepted standards. In addition, Rubicon conducts process hazard analyses, establishes EHS and unit operating policies and procedures, utilizes continuous process control and monitoring, and performs inspection and testing of equipment.



Five Year Accident History



Rubicon has had six incidents within the last five years:



On September 24, 2013, a temporary power surge caused the Distributive Computer Control System in the Reductions unit to shut down. This caused the DPA 2 Aniline Stripper to overpressure and relieve through the pressure safety valve. The pressure safety valve released 1,370 pounds of aniline and 28 pounds of ammonia over a 32 minute period. The percentage of ammonia in the stream is 2% which is greater than the 1% Risk Management Program rule threshold. The Ascension Parish Sheriff's Office was notified of a site alert, which is not expected to impact offsite receptors. Modeling indicated that the ammonia did not reach ground level off of the Rubicon facility. The Ascension Parish 911 dispatcher followed an incorrect response protocol and called for industrial sites downwind of the release to shelter in place.



On May 12, 2014, an unexpected power outage caused the MDI 2 unit to lose power. This caused a vapor mixture of hydrochloric acid/phosgene to enter the MDI test tank. The MDI test tank overpressured and relieved through the pressure safety valve. The pressure safety valve released 7 pounds of hydrochloric acid vapor and 0.5 pounds of phosgene vapor over a 24 minute period. The Ascension Parish Sherriff's Office was no
tified of a site alert that is expected to impact offsite receptors. Public roads surrounding the facility were closed during the incident. The surrounding industrial facilities were instructed to shelter in place. Modeling indicated that the phosgene and hydrochloric acid did not travel off of the Rubicon facility.



On October 29, 2014, a tubing leak developed on a process instrument on the recovery column feed pump in the MDI 1 unit that released a mixture of chlorobenzene and phosgene. The release lasted fifteen minutes during which 0.2 pounds of chlorobenzene and 0.8 pounds of phosgene were released to the air. The Ascension Parish Sherriff's Office was notified of a site alert that is expected to impact offsite receptors. One public road was closed during the release as a precautionary measure. During the emergency response, a Rubicon production technician received first and second degree burns to his hands. He was sent to the Baton Rouge General burn unit and released later that day.



On November 11, 2015, the MDI 3 unit lost power to its Distributive Control System (DCS) while maintenance activities were being performed on the MDI 3 Uninterrupted Power Supply (UPS) system. This temporary power loss resulted in a vapor release of phosgene from vents on two MDI 3 test tanks and a monochlorobenzene (MCB) storage tank. The release lasted approximately forty minutes and released 0.7 pounds of phosgene vapor. The Ascension Parish Sherriff's Office was notified of a site alert that is expected to impact offsite receptors. The surrounding industrial facilities were instructed to shelter in place.



On April 6, 2016, a leak on the MDI 1 C Phosgene Reactor cooling water system released a gaseous phosgene/chlorine/carbon monoxide mixture to the air due to a reactor tube failure. The release lasted two minutes and released 0.6 pounds of phosgene, 1.5 pounds of chlorine and 0.8 pounds of carbon monoxide. Chlorine is not held above the threshold quanti
ty in the MDI 1 unit. During the emergency response a Production Technician was exposed to phosgene. He was transported to St. Elizabeth Hospital where he received treatment for phosgene exposure. He was released later that night and returned to work on April 7, 2016. The Ascension Parish Sherriff's Office, the Louisiana State Police and the Louisiana Department of Environmental Quality were notified when the Production Technician was transported to the hospital.



On April 21, 2016, a release occurred from a bleed valve in the MDI 2 unit while clearing a pump for planned maintenance the following day. A liquid mixture of chlorobenzene, methylene diphenyl diisocyanate (MDI), phosgene and hydrochloric acid (HCl) was released. 0.62 pounds of phosgene and 0.1 pounds of chlorobenzene were released to the air from the spill pool. The rest of the liquid mixture was contained within the unit. Two Production Technicians were exposed to the liquid mixture. Both Production Technicians were transported St. Elizabeth Hospital and were treated for phosgene exposure. One Production Technician was also treated for burns. As a precautionary measure, the Production Technicians were transported to Louisiana State University Health Science Center (LSU HSC) in Shreveport, LA for further monitoring. Both Production Technicians were released from LSU HSC and were cleared to return to work on April 22, 2016. The Ascension Parish Sherriff's Office was notified of a site alert that was not expected to impact off site receptors. The Ascension Parish Sherriff's Office, the Louisiana State Police and the Louisiana Department of Environmental Quality were notified when the Production Technicians were transported to the hospital.



Emergency Response Program



Rubicon's emergency response program is based on the philosophy of prevention, preparation and response. Some practices at Rubicon for preventing situations that could possibly lead to an emergency incident are the use o
f good engineering design and nationally accepted standards, conducting process hazard analyses, safety procedures, the management of change system, unit operating policies and procedures, continuous process control and monitoring, inspection and testing of equipment and preventative maintenance of equipment. The second and third elements of Rubicon's emergency response program are preparation and response. Preparing for emergency situations at Rubicon includes exercises and drills for the training of the internal emergency response units. The internal emergency response units are the Fire Brigade, HAZMAT personnel with equipped van, medical first responders with equipped ambulance and a first aid station with nurse, and teams specializing in vertical and confined space rescues. Formal written fire and release preplans have been developed to assist training and drill scenarios. A plant-wide evacuation drill for all employees is performed at least once per year.



Another important aspect of preparation for an emergency is communication. Rubicon has the following internal communication systems: 888 emergency notification telephone system, two way radios, public announcement system in the units, fire alarms, gas alarms, telephones, cellular telephones and faxes. External communication systems include the Community Awareness Emergency Response (CAER) radio, the telephone system with backup switch and power, cellular telephones, and the use of 911. Upon using the CAER radio or 911, Rubicon coordinates with the Ascension Parish Sheriff's Office (APSO) the activation of all or part of the CAER emergency sirens that are designed to be heard within an approximate radius of 2.5 miles of each plant in the area where the CAER chemical facilities are located. This coordination can also activate the computerized Emergency Telephone Alerting System provided by the Community Alert Network (CAN) and the Emergency Broadcast System (television and/or radio) for Ascension Pa
rish. These external communication systems inform and coordinate efforts with neighboring chemical plants, the Ascension Parish Sheriff Department, Ascension Parish Office of Homeland Security and Emergency Preparedness, the Louisiana State Police and/or the general public.



Rubicon works closely with outside authorities and other neighboring companies to coordinate emergency response. These authorities are Louisiana State Police, Ascension Parish Sheriff Department, Ascension Parish Office of Homeland Security and Emergency Preparedness, Geismar Fire Department, Prairieville Fire Department, Red Cross, St. Elizabeth Hospital (Gonzales), Our Lady of the Lake Regional Hospital (Baton Rouge), Baton Rouge General Medical Center (Baton Rouge), Summit Hospital (Baton Rouge) and the Industrial Mutual Aid Group (IMAG). The Ascension Parish Office of Homeland Security and Emergency Preparedness has the ability to facilitate the activation of the National Guard Civil Support Team to respond to an on-site emergency. IMAG also has reciprocal agreements for equipment exchange with the St. James Mutual Aid and Baton Rouge Area Mutual Aid Systems. Rubicon performs annual training with most of these organizations or provides information necessary for coordinated emergency response.



Rubicon has also developed formal emergency action plans such as the SPC/SPCC Plan, RCRA Contingency Plan, and the One Plan for emergency situations. Rubicon also has emergency internal procedures that address Emergency Action and Crisis Management, Emergency Brigade, 888 Emergency Notification Telephone System, Radiation Sources, Plant-wide Evacuation, Bomb Threats, and Hurricanes and Parking Area Emergency Notification System. Preplanned emergency responses are practiced and are used during release drill scenarios. Other response practices include utilizing wind socks to determine wind direction, the SAFER System for air dispersion modeling of a toxic gas release, sampling on-site and off
-site by HAZMAT response personnel, the phosgene detection monitoring system in occupied buildings, water deluge systems for fire and toxic air release suppression, equipment and operating unit shutdown systems and waste handling procedures.



Planned Changes to Improve Safety



Rubicon's current philosophy on major safety improvements is to evaluate the use of pipelines in place of tank trucks or rail cars for transportation of chemicals. Utilizing pipelines allows Rubicon to reduce storage of these chemicals and it promotes less handling of these chemicals due to less loading and unloading. Pipelines also benefit the public because there is less vehicular transportation of these chemicals through their neighborhoods thus lowering the possibility of accidents.



Rubicon conducts business safely and effectively which is demonstrated by our outstanding safety record. Rubicon has, for the last 50 years, effectively managed our systems to minimize risk to our employees, our neighbors and our community. Rubicon is committed to maintaining this high standard of performance and plans to experience many more safe, productive years in this area. Rubicon is committed to improving the safety at our facility for our employees, our near neighbors, and our community.