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Plaquemine Facility

Parent Companies:
The Dow Chemical Company
EPA Facility ID:
100000183954
Other ID:
LAR00001821
Facility DUNS:
0
Parent Company DUNS:
1381581

Location:

Address:
21225 Highway 1
Plaquemine, LA 70764
County:
IBERVILLE
Lat / Long:
30.322, -91.235 (Get map)
Method:
Interpolation - Digital map source (TIGER)
Description:
Process Unit Area Centroid
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
The Dow Chemical Company
Phone:
(225) 353-8700
Address:
PO Box 150
Plaquemine, LA 70765 -0150
Foreign Address:

Person responsible for RMP implementation:

Name:
Title:
Responsible Care Leader
Email:

Emergency contact:

Name:
Central Control Room
Title:
Operator
Phone:
(225) 353-8700
24-hour phone:
(225) 353-8700
Ext or PIN:
Email:
N/A

Other contacts:

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

Safety:

Local Emergency Planning Committee:
Iberville Parish LEPC
Full-Time Equivalent Employees:
56
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
1280-00096-V1
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Dec. 14, 2004
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Anhydrous Ammonia
RMP ID:
76560
CBI claimed:
No
Program Level:
3
NAICS:
Electric Power Generation (22111)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
66,000
No
Public OCA Chemical
0
No
Water Treatment
RMP ID:
76561
CBI claimed:
No
Program Level:
3
NAICS:
Electric Power Generation (22111)
Chemical name
CAS#
Quantity (lbs.)
CBI
Chlorine
7782-50-5
6,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
Sept. 16, 2008
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
No
RMP ID:
52569

Deregistration:

Date:
Effective Date:
Reason:
Other
Other Reason:
FAC_ID 100000183954 has been consolidated to FAC_ID 100000136523 per Region 6.

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 Anhydrous Ammonia)
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:
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 Anhydrous Ammonia)
CBI claimed:
No
Percent weight:
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:
  • Excess flow valve
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Flares
  • Scrubbers
Public OCA Chemical (in Water Treatment)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP Guidance for Waste Water Treatment Plants Reference Tables or Equations
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

None

5. Flammables: Alternative release

None

6. Five-year accident history

July 5, 2006 at 12:48
ID:
8439
NAICS:
Electric Power Generation (22111)
Duration:
42 minutes
Chemicals involved:
  • Chlorine
Release events:
Gas release
Weather conditions at time of event
Wind speed:
9.0 miles/h NW
Temperature:
87.00 ℉
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:
Human Error
Contributing factors:
  • Human error
Off-site responders notified:
Notified Only
Changes introduced as a result of the accident:
  • Revised training
  • Revised operating procedures

7. Prevention: Program level 3

Anhydrous Ammonia, Electric Power Generation (22111)
Prevention Program ID:
45074
Safety Review Date
March 31, 2008, since latest RMP submission
PHA Update Date
May 3, 2007, since latest RMP submission
PHA Techniques
  • What if/Checklist
Hazards Identified
  • Toxic release
  • Fire
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Cooling loss
  • Tornado
  • Hurricanes
Process Controls
  • Relief Valves
  • Check Valves
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Grounding Equipment
  • Excess Flow Device
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
March 31, 2008, since latest RMP submission
Training Review Date
Dec. 31, 2007, since latest RMP submission
Maintenance Review Date
Aug. 11, 2008, since latest RMP submission
Maintenance Inspection Date
Oct. 18, 2006, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Sept. 15, 2003
Management of Change Review Date
Oct. 1, 2003
Pre-startup Review Date
Oct. 15, 2003
Compliance Audit Date
March 31, 2008
Compliance Audit Change Completion Date
Dec. 31, 2008
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Sept. 15, 2006
Hot Work Review Date
Sept. 15, 2006
Contractor Safety Review Date
Sept. 15, 2006, since latest RMP submission
Contractor Safety Eval. Date
Oct. 1, 2003, since latest RMP submission
Water Treatment, Electric Power Generation (22111)
Prevention Program ID:
45075
Safety Review Date
March 31, 2008, since latest RMP submission
PHA Update Date
May 3, 2007, since latest RMP submission
PHA Techniques
  • What if/Checklist
Hazards Identified
  • Toxic release
  • Overpressurization
  • Corrosion
  • Equipment failure
Process Controls
  • Relief Valves
  • Check Valves
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
  • Rupture Disks
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Oral Test
  • Demonstration
Procedure Review Date
March 29, 2008, since latest RMP submission
Training Review Date
Sept. 15, 2003, since latest RMP submission
Maintenance Review Date
Dec. 31, 2007, since latest RMP submission
Maintenance Inspection Date
Sept. 9, 2008, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Sept. 18, 2005
Management of Change Review Date
Nov. 30, 2007
Pre-startup Review Date
June 24, 2008
Compliance Audit Date
March 31, 2008
Compliance Audit Change Completion Date
Dec. 31, 2008
Incident Investigation Date
July 5, 2006
Incident Invest. Change Completion Date
Oct. 30, 2006
Participation Plan Review Date
Dec. 31, 2007
Hot Work Review Date
Sept. 15, 2003
Contractor Safety Review Date
Sept. 22, 2003, since latest RMP submission
Contractor Safety Eval. Date
Sept. 22, 2003, 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:
No
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
No
Plan Review Date:
Response Training Date:
None
Local Response Agency:
Local Response Agency Phone:
(225) 678-5140
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
No
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

Accidental Release Prevention and Emergency Response Policies
The Dow Chemical Company (Dow) is committed to proactively protecting human health, safety and the environment. We operate our business in a manner that consciously safeguards our employees, customers and communities in which we do business. In striving for responsible environmental, health & safety (EH&S) stewardship, Dow pledges to:
* Diligently develop, construct and operate our facilities in an environmentally responsible manner that promotes pollution prevention and places the highest priority on health and safety.
* Operate facilities that meet or exceed all applicable federal, state and local EH&S rules, regulations, ordinances and statues as well as recognized industry guidelines and standards.
* Continually measure, evaluate and improve our EH&S performance.
* Promote EH&S awareness that fosters a caring, ownership-driven culture among employees, contractors and vendors.

Description of the Stationary Source and Regulated Substances
The Plaquemine Cogeneration Facility (PCF), located in Plaquemine, LA is a gas-fired combustion turbine power plant that produces electricity. As a means of reducing nitrogen oxide emissions from the four gas-fired combustion turbines, anhydrous ammonia is injected into the turbine exhaust streams. Anhydrous ammonia is stored on-site in a dedicated, specially designed storage tank. The storage capacity of the tank exceeds the threshold quantity for RMP applicability. Additionally, the facility uses chlorine in its water treatment facility. Chlorine is stored in up to three pressurized cylinders, one of which is connected for use at any one time.

Accidental Release Prevention Program & Chemical-Specific Prevention Steps
PCF is subject to OSHA's PSM standard and Program 3 of EPA's RMP rule. The accidental release prevention program at PCF includes:

Employee Participation
All PCF employees are actively encouraged to participate in the accidental release pre
vention program. Each employee is urged to participate in the continual upgrading and maintaining of all health and safety programs. Employee involvement is achieved through direct participation on a voluntary basis, active consultation with affected employees, and representative participation in the process hazard analysis. Employees have access to all information required under the PSM and RMP regulations.

Process Safety Information (PSI)
PCF maintains a variety of technical documents to ensure that process hazards are understood and that the plant is operated and maintained in a safe manner. These documents include information concerning the hazards of anhydrous ammonia and chlorine, process technology, and process equipment. PSI data is updated when changes in the process occur. Information concerning the hazards of ammonia and chlorine is found on Material Safety Data Sheets, which are maintained for all hazardous chemicals.

Information concerning the process technology includes process flow information, maximum intended inventory information, safe upper and lower process limits, and consequences of deviating from safe limits.

Information concerning the process equipment includes the materials of construction, piping specifications, piping and instrument diagrams, relief design calculations and design basis, design codes and standards employed, safety systems.

Process Hazard Analysis (PHA)
PCF has a comprehensive PHA program to ensure that hazards associated with the ammonia and chlorine processes are systematically identified and controlled. The analysis is conducted in accordance with regulatory requirements, generally accepted industry standards, and guidance from safety organizations such as the Center for Chemical Process Safety. The plant has a system in place to ensure that PHA recommendations are resolved in a timely manner.

Operating Procedures
PCF maintains written operating procedures that address the various modes of process operations
, including initial startup, normal startups and shutdowns, emergency shutdowns, emergency operations, and normal operations. The procedures also discuss safe upper and lower process limits, consequences of deviation from the safe limits, and how to return the process to safe operations. The procedures are readily available to operations personnel, and are reviewed and certified annually. Safe work practices such as hot work, lockout, and line breaking, are referenced in operating procedures, where applicable.

Training
All operations personnel of PCF are initially trained in an overview of the ammonia and chlorine processes, as well as procedures to safely operate the processes. Operations personnel receive refresher training at least every three years.

Contractors
The PCF uses contractors to supplement its workforce for certain maintenance or construction activities. Because some contractors will work on or near the ammonia or chlorine process equipment, the plant has procedures in place to ensure that contractors are pre-qualified before performing work, aware of the hazards of the process, understand what to do in the event of an emergency, understand site safety rules, and inform plant personnel of any hazards they encounter during their work. The PCF also evaluates contractor safety programs and performance during the selection process.

Pre-Startup Safety Reviews (PSSR)
The PCF conducts a pre-startup safety review for any new facility or significant facility modification. The purpose of the PSSR is to ensure that safety systems, procedures, training, and equipment are prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with design specifications and that all supporting systems are operationally ready. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accidental release preventi
on programs are properly implemented.

Mechanical Integrity
PCF has implemented practices and procedures to maintain pressure vessels, piping systems, relief systems, controls, pumps and emergency shutdown systems, in a safe operating condition. The program includes: (1) the development of a maintenance schedule for equipment in the ammonia and chlorine processes and critical safety equipment, (2) developing written maintenance procedures, (3) conducting maintenance training, (4) performing and documenting inspections, (5) correcting identified equipment deficiencies, and (6) applying quality assurance measures to ensure replacement equipment meets the required specifications.

Hot Work Permits
PCF has a hot work permit program in place to ensure worker and process safety. The hot work permit program is designed to control heat and spark-producing activities and to ensure that adequate precautions are in place before work begins in the process area. These procedures (and others), along with training of affected personnel, form a system to help ensure that maintenance activities are performed safely.

Management of Change
PCF has a system in place to ensure safety concerns associated with changes to the ammonia and chlorine processes are reviewed and addressed prior to the change. Changes meeting PSM/RMP criteria are reviewed to ensure that adequate controls are in place to manage any new hazards, as well as to verify that existing safeguards and controls have not been compromised by the change. The system requires that process safety information and operating procedures are updated and that operations and maintenance personnel are trained before the change is implemented.

Incident Investigation
PCF will promptly investigate all incidents that resulted in, or could reasonably be expected to result in, the release of ammonia or chlorine. The findings of the investigation, along with any corrective actions taken to prevent recurrence of the incident, will be
reviewed with all affected personnel (including contractors).

Compliance Audits
To ensure that the accidental release prevention program is functioning properly, PCF will conduct a compliance audit every three years. The facility will quickly resolve any deficiencies noted by the audit team, and will review the audit report and corrective actions taken with all affected personnel.

Additional Safety Systems
PCF has additional systems in place to prevent accidental releases of ammonia or chlorine, as well as systems to lessen the impact of accidental releases. These systems include:
* Redundant instrumentation to monitor critical process parameters
* Redundant critical equipment
* Automated shutdown systems
* Pressure relief valves
* Toxic gas sensors

Five Year Accident History
There has been one RMP reportable accident at the plant.

Emergency Response Program
PCF maintains a written emergency action program. The program addresses important aspects of emergency action as required by OSHA. PCF is a defensive responder to release emergencies. Dow Chemical emergency responders are notified to respond to major releases. The emergency action program is coordinated with Dow Chemical and the Iberville Parrish Office of Emergency Planning.

Planned Changes to Improve Safety
PCF continually reviews opportunities to improve the safety of its process. No specific improvements are planned, at this time, however, PCF employees attend regular operations and maintenance training sessions.

Change of Ownership
Please note that on November 30, 2006, ownership of the PCF was transferred from American Electric Power (AEP) to The Dow Chemical Company (Dow).