houstonlogo rjilogo

The Right-to-Know Network

Back to search

Blue Cube Operations LLC - Plaquemine Site

Parent Companies:
Olin Corporation
EPA Facility ID:
100000231536
Other ID:
Facility DUNS:
0
Parent Company DUNS:
79767589

Location:

Address:
21255 Highway 1 S
Plaquemine, LA 70765
County:
IBERVILLE
Lat / Long:
30.314, -91.241 (Get map)
Method:
Interpolation - Digital map source (TIGER)
Description:
Plant Entrance (General)
Horizonal accuracy:
30 m
Horizontal reference datum:
World Geodetic System of 1984
Source map scale:

Owner/Operator:

Name:
Blue Cube Operations LLC
Phone:
(225) 353-1869
Address:
21255 Highway 1 S
P.O. Box 424
Plaquemine, LA 70765 -0150
Foreign Address:

Person responsible for RMP implementation:

Name:
Stephen Ledoux
Title:
Site Leader

Emergency contact:

Name:
Mark Mitchell
Title:
Sr EH&S Manager
Phone:
(225) 353-1869
24-hour phone:
(225) 324-4153
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(225) 353-1500
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Iberville Parish LEPC
Full-Time Equivalent Employees:
205
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
2573-V8 2188-V7
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Dec. 17, 2015
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Chlorine
RMP ID:
1000068765
CBI claimed:
No
Program Level:
3
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Chemical name
CAS#
Quantity (lbs.)
CBI
Chlorine
7782-50-5
6,200,000
No
Public OCA Chemical
0
No
Solvents/EDC
RMP ID:
1000068766
CBI claimed:
No
Program Level:
3
NAICS:
Other Basic Organic Chemical Manufacturing (32519)
Chemical name
CAS#
Quantity (lbs.)
CBI
Chloroform [Methane, trichloro-]
67-66-3
180,000
No
Hydrogen chloride (anhydrous) [Hydrochloric acid]
7647-01-0
580,000
No
Methyl chloride [Methane, chloro-]
74-87-3
3,830,000
No
Chlorine
7782-50-5
3,028
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Sarah Babin
Address:
21255 Highway 1 S
P.O. Box 424
Plaquemine, LA 70765 -0150
Foreign Address:

Phone:
(225) 353-1245

Latest RMP Submission:

Date:
March 11, 2016
Type:
First-time submission
Reason:
Registered:
Yes
RMP ID:
1000054957

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 Solvents/EDC)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas liquified by refrigeration
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 Chlorine)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
PHAST
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 Solvents/EDC)
CBI claimed:
No
Percent weight:
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 Solvents/EDC)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by refrigeration
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 Solvents/EDC)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
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

March 16, 2017 at 09:26
ID:
1000049220
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Duration:
30 minutes
Chemicals involved:
  • Chlorine
Release events:
Gas release
Weather conditions at time of event
Wind speed:
None
Temperature:
None ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
Yes
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:
  • Improper procedure
  • Maintenance activity/inactivity
Off-site responders notified:
Notified Only
Changes introduced as a result of the accident:
  • Revised training
  • Revised operating procedures
Dec. 2, 2016 at 15:05
ID:
1000049219
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Duration:
2 hours
Chemicals involved:
  • Chlorine
Release events:
Gas release
Weather conditions at time of event
Wind speed:
None
Temperature:
None ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
Yes
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:
20
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Upset condition
  • Complete Site Power and Utility Failure
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • New mitigation systems
  • Revised emergency response plan
Oct. 24, 2013 at 19:18
ID:
1000043218
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Duration:
7 minutes
Chemicals involved:
  • Chlorine
Release events:
Gas release
Weather conditions at time of event
Wind speed:
2.5 meters/second SW
Temperature:
67.00 ℉
Atmospheric stability:
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

Chlorine, Other Basic Inorganic Chemical Manufacturing (32518)
Prevention Program ID:
1000058092
Safety Review Date
Aug. 31, 2015, since latest RMP submission
PHA Update Date
June 10, 2014, since latest RMP submission
PHA Techniques
  • Checklist
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • 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
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
  • Water Curtain
  • Neutralization
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
Oct. 28, 2015, since latest RMP submission
Training Review Date
Oct. 31, 2014, since latest RMP submission
Maintenance Review Date
Sept. 10, 2015, since latest RMP submission
Maintenance Inspection Date
Jan. 19, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 9, 2015
Management of Change Review Date
May 12, 2015
Pre-startup Review Date
Nov. 3, 2015
Compliance Audit Date
April 24, 2015
Compliance Audit Change Completion Date
Jan. 31, 2016
Incident Investigation Date
Oct. 10, 2015
Incident Invest. Change Completion Date
June 30, 2016
Participation Plan Review Date
Jan. 18, 2016
Hot Work Review Date
Dec. 17, 2015
Contractor Safety Review Date
Sept. 16, 2015, since latest RMP submission
Contractor Safety Eval. Date
Sept. 16, 2015, since latest RMP submission
Solvents/EDC, Other Basic Organic Chemical Manufacturing (32519)
Prevention Program ID:
1000057552
Safety Review Date
Dec. 8, 2015, since latest RMP submission
PHA Update Date
Dec. 8, 2015, since latest RMP submission
PHA Techniques
  • Checklist
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
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Excess Flow Device
  • Quench System
  • 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
Jan. 18, 2016, since latest RMP submission
Training Review Date
Nov. 13, 2014, since latest RMP submission
Maintenance Review Date
Feb. 11, 2016, since latest RMP submission
Maintenance Inspection Date
Feb. 1, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Jan. 12, 2016
Management of Change Review Date
May 5, 2015
Pre-startup Review Date
Feb. 12, 2016
Compliance Audit Date
Jan. 27, 2014
Compliance Audit Change Completion Date
March 31, 2015
Incident Investigation Date
Jan. 28, 2016
Incident Invest. Change Completion Date
Oct. 31, 2016
Participation Plan Review Date
Jan. 18, 2016
Hot Work Review Date
July 31, 2015
Contractor Safety Review Date
Sept. 16, 2015, since latest RMP submission
Contractor Safety Eval. Date
Sept. 16, 2015, 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:
Aug. 12, 2015
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: Initial Submission



Executive Summary

Blue Cube Operations LLC

Plaquemine Site



196702 LDEQ Facility ID Number



This is the initial submission for RMP for the Blue Cube Operations LLC Plaquemine Site (BCO-Plaq). BCO-Plaq consists of Chlor-Alkali and Chlorinated Organics operating units that were previously owned and operated by The Dow Chemical Company at their Louisiana Operations Site (Dow-LAO). On October 5, 2015, BCO-Plaq became a subsidiary of Olin Corporation. All BCO-Plaq units were previously included in DOW-LAO Site RMP.



1. Accident Release Prevention and Emergency Response Policies

Blue Cube Operations LLC Plaquemine Site (BCO-Plaq) continues to be strongly committed to employee, public and environmental safety, as demonstrated by BCO-Plaq'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 BCO-Plaq's policy to implement the necessary and appropriate controls to prevent possible releases of regulated substances. If such a release does occur, BCO-Plaq 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. BCO-Plaq is also completely coordinated with the Iberville Parish Office of Emergency Preparedness (LEPC) which provides additional emergency response expertise.



2. The Stationary Source and the Regulated Substances Handled

As previously stated above, BCO-Plaq process units were previously part of The Dow Chemical Company Louisiana Operations (Dow-LAO). Of the all process units, only 2 units are RMP covered processes: Chlorine Unit and Solvents/EDC Unit. There are only 4 regulated substances present at the facility that are above the threshold limits: Chlorine, Chloroform [Methane, trichloro-], Hydrogen chlor
ide (anhydrous) [Hydrochloric acid] and Methyl chloride [Methane, chloro-].



Anhydrous hydrogen chloride is produced at BCO-Plaq to be used internally to make aqueous hydrogen chloride or to be sold to customers to make silicones, some of which form computer chips. Inhalation can cause coughing, choking, inflammation and ulceration of the respiratory tract.



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, and is used in hospital sanitation. It is a product of the Chlorine Unit and is the basic building block in the production of many of Solvent/EDC's products as well as other costumers. Some of these consumer products are laundry bleach, garden and lawn herbicides, vinyl siding for homes, and PVC piping and fittings. 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.



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

BCO-Plaq 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 BCO Loss Prevention Principles and BCO 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

BCO-Plaq 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 Safety Data Sheets, equipment spec sheets, and reactive chemicals tests.



Process Hazard Analysis

BCO-Plaq conducts periodic comprehensive studies to ensure that hazards associated with our processes are identified and controlled ef
ficiently. The methodology used to carry out these analyses is What If/Checklist (combined), HAZOP, the BCO Fire and Explosion Index, the BCO 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 December 8, 2015.



Operating Procedures

For the purposes of safely conducting activities within the covered processes, BCO-Plaq 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

BCO-Plaq 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

BCO-Plaq 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 qual
ified 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 BCO-Plaq 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 BCO-Plaq. 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

BCO-Plaq 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

BCO-Plaq 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 has been 1 RMP-reportable incidents at BCO-Plaq facility in the last 5 years.



Employee Participation

BCO-Plaq 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 BCO-Plaq 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

BCO-Plaq hires contractors to conduct specialized maintenance, construction and various other activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. BCO-Plaq 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 BCO of any hazards they may introduce at the site.



4.Five-year Accident History

BCO-Plaq 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 has been 1 RMP-reportable accidental releases as defined by the RMP rule of regulated substances from our facility within the last 5 years. A release of Chlorine occurred on 10/24/13. No deaths or injuries occured offsite as a result of this accident. Onsite, there was 1 injury. There was no onsite property damage.



5. Emergency Response Plan

BCO-Plaq, in coordination with the Dow-LAO Emergency Services Department, 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 perti
nent changes taking place within our processes that would require a modified emergency response.



Iberville Parish Office of Emergency Preparedness (LEPC) is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified.



6. 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.