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Dexco Polymers, Vector SBC Plant

Parent Companies:
Taiwan Synthetic Rubber Company
EPA Facility ID:
100000215028
Other ID:
Facility DUNS:
556963940
Parent Company DUNS:
0

Location:

Address:
21255 Hwy 1
Plaquemine, LA 70764
County:
IBERVILLE
Lat / Long:
30.317, -91.244 (Get map)
Method:
Interpolation - Photo
Description:
Administrative Building
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Dexco Polymers
Phone:
(225) 309-0201
Address:
P.O.Box 495
Plaquemine, LA 70764
Foreign Address:

Person responsible for RMP implementation:

Name:
Title:
Plant Manager
Email:

Emergency contact:

Name:
Kevin Stacey
Title:
Plant Manager
Phone:
(225) 309-0172
24-hour phone:
(225) 309-0201
Ext or PIN:

Other contacts:

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

Safety:

Local Emergency Planning Committee:
Iberville Parish LEPC
Full-Time Equivalent Employees:
57
Covered by OSHA PSM:
Yes
EPCRA section 302:
No
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
2025-V5
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Sept. 8, 2008
Inspecting Agency:
Federal Rail Administration
Using Predictive Filing:
No

Processes:

Vector SBC Plant
RMP ID:
1000076316
CBI claimed:
No
Program Level:
3
NAICS:
Synthetic Rubber Manufacturing (325212)
Chemical name
CAS#
Quantity (lbs.)
CBI
Isopentane [Butane, 2-methyl-]
78-78-4
340,000
No
1,3-Butadiene
106-99-0
660,000
No
Isoprene [1,3-Butadiene, 2-methyl-]
78-79-5
750,000
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:
Dec. 13, 2016
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000061105

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

None

3. Toxics: Alternative release

None

4. Flammables: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Vector SBC Plant)
CBI claimed:
No
Model used:
RMP Comp
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 Vector SBC Plant)
CBI claimed:
No
Model used:
RMP Comp
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Water curtain

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

Vector SBC Plant, Synthetic Rubber Manufacturing (325212)
Prevention Program ID:
1000064137
Safety Review Date
Dec. 1, 2016, since latest RMP submission
PHA Update Date
Dec. 15, 2015, since latest RMP submission
PHA Techniques
  • Checklist
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • 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
  • Inhibitor Addition
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
  • Water Curtain
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Oct. 19, 2016, since latest RMP submission
Training Review Date
Nov. 10, 2014, since latest RMP submission
Maintenance Review Date
Sept. 18, 2014, since latest RMP submission
Maintenance Inspection Date
Nov. 30, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Oct. 8, 2016
Management of Change Review Date
Feb. 2, 2010
Pre-startup Review Date
May 16, 2016
Compliance Audit Date
Dec. 9, 2016
Compliance Audit Change Completion Date
Dec. 9, 2017
Incident Investigation Date
July 19, 2016
Incident Invest. Change Completion Date
July 19, 2017
Participation Plan Review Date
Oct. 19, 2016
Hot Work Review Date
Oct. 24, 2016
Contractor Safety Review Date
Jan. 12, 2015, since latest RMP submission
Contractor Safety Eval. Date
Dec. 7, 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, 2016
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

Executive Summary

Dexco Polymers, Vector SBC Plant



100000215028-LDEQ Facility ID Number



1.Accidental Release Prevention and Emergency Response Policies

The DEXCO Polymers, VECTOR SBC Plant is strongly committed to employee, public and environmental safety, as demonstrated by the plant'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 DEXCO Polymers policy to implement the necessary and appropriate controls to prevent possible releases of regulated substances. If such a release does occur, the DEXCO Polymers, VECTOR SBC Plant personnel along with contracted services of the Dow Chemical Company, Louisiana Operations well-trained emergency response personnel are at hand to control and mitigate the effects of the release. DEXCO Polymers is also coordinated with the Iberville Office of Emergency Preparedness (LEPC) which provides additional emergency response expertise.



2.The Stationary Source and the Regulated Substances Handled

DEXCO Polymers, VECTOR SBC Plant started operations in 1989 as a joint venture of the Dow Chemical Company and Exxon. In April 2011, Taiwan Synthetic Rubber Company purchased DEXCO Polymers.

DEXCO Polymers, VECTOR SBC Plant uses butadiene, isoprene, and styrene to produce a styrenic block copolymers. We have 3 regulated substances present at our facility. These substances are 1,3-Butadiene, Isoprene [1,3-Butadiene, 2-methyl-], and Isopentane [Butane, 2-methyl-].

Butadiene and Isoprene are raw materials used to make the block copolymer synthetic rubber product. They are flammable gases with a mild aromatic odor. High vapor concentrations could cause eye, nose, throat irritation and dizziness.

Isopentane is a solvent used in the production of the block copolymer synthetic rubber product. It has mild gasoline like odor. Effects of overex
posure may include nausea vomiting diarrhea abdominal pain signs of nervous system depression (e.g., headache, drowsiness, dizziness, loss of coordination, disorientation and fatigue) irritation of the digestive tract irritation of the respiratory tract.



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

DEXCO Polymers, VECTOR SBC Plant 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 originally designed and constructed in accordance with the Dow Chemical Company's Loss Prevention Principles and Dow Chemical 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



Dexco Polymers 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



Dexco Polymers 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), Fire and Explosion Index, 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 findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 12/15/2015.



Operating Procedures



For the purposes of safely conducting activities within the covered processes, Dexco Polymers 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. The procedures are readily accessible to operators involved in the processes.



Training



Dexco Polymers 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 required.



Mechanical Integrity



Dexco Polymers 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 tim
ely manner.





Management of Change



Written procedures are in place at Dexco Polymers to manage changes in process chemicals, technology, equipment 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 Dexco Polymers. 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



Dexco Polymers 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



Dexco Polymers promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years.



Employee Participation



Dexco Polymers 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 Dexco 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. Also, annual LOPA training is conducted for all Dexco Employ
ees.



Contractors



Prior to selecting a contractor to perform maintenance and construction activities at the Dexco facility, past safety performance of the contractor is reviewed. Dexco's expectations are communicated to the contractor and evaluated frequently during activities. Contractors are required to communicate hazards discovered during their activities and their plan to mitigate the risk. All significant safety or environmental events are investigated and appropriate corrective action taken.



5.Five-year Accident History

The DEXCO Polymers, VECTOR SBC Plant 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 have been no RMP-reportable accidental releases as defined by the RMP rule of regulated substances from our facility within the last 5 years.



6. Emergency Response Plan

Dexco Polymers has a written emergency response procedure that provides a general description of the actions to take in the event of a plant emergency involving an injury, fire, spill, or explosion. Links to more specific emergency procedures, such as loss of utilities, are also included in this procedure for reference. The emergency response plan and the emergency procedures are reviewed and updated, if required, annually. Iberville Parish Office of Emergency Preparedness (LEPC) is the Local Emergency Planning Committee (LEPC).



If a serious event were to occur, Dexco has contracted additional emergency respnonse from Dow - LAO employees. Dow - LAO has a written plan which includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, as well as post-incident decontamination of affected areas. To ensure proper functioning, Dow - LAO emergency response equipment is regularly inspected and serviced.



7. Planned Changes to Improve Safety

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