The Dow Chemical Company-Louisiana Operations - Executive Summary |
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Risk Management Executive Summary The Dow Chemical Company Louisiana Operations 1409-LDEQ Facility ID Number 1. Accidental Release Prevention and Emergency Response Policies We at The Dow Chemical Company-Louisiana Operations are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. If such a release does occur, our highly trained emergency response personnel are at hand to control and mitigate the effects of the release. We are also completely coordinated with Iberville and West Baton Rouge Parishes Office of Emergency Preparedness (LEPC) which provides additional emergency response expertise. 2. The Stationary Source and the Regulated Substances Handled The Dow Chemical Company-Louisiana Operations started operations in 1956 and has grown from the initial 3 production units to 23, producing over 50 different products used in a wide variety of consumer products such as Tupperware, antifreeze, shampoo ingredients, automotive fluids, cosmetics, and water purification. Louisiana Operations uses basic natural resources such as salt and natural gas to produce the basic chemical ingredients, chlorine and ethylene, which are further used to produce the 50 products. We have 28 regulated substances present at our facility. These substances include Propane, 1,3-Butadiene, Pentane, Chloroform [Methane, trichloro-], Propylene oxide [Oxirane, methyl-], Vinyl chloride [Ethene, chloro-], 2-Methylpropene [1-Propene, 2-methyl-], Isoprene [1,3-Butadiene, 2-methyl-], Methyl chloride [Methane, chloro-], Butane, Chlorine, 1,3-Pentadiene, Isopentane [Butane, 2-methyl-], 2-Butene-cis, Hydrogen chloride [Hydrochloric acid] , Propylene [1-Propene], Ammonia (anhydrous), Ethylene oxide [Oxirane], Epichlorohydrin [Oxirane, (chloromethyl)-], 2-Methyl-1-butene, Ethylene [Ethene], Ethyl chloride [Ethane, chloro-], Hydrogen, Isobutane [Propane, 2-methyl], Methyl ether [Methane, oxybis-], 1-Butene, Acetylene [Ethyne] and Methane. Anhydrous hydrogen chloride is used by Dow to produce vinyl chloride and also sold to customers to make silicones, some of which form computer chips. Inhalation can cause coughing, choking, inflammation and ulceration of the respiratory tract. Butadiene is a byproduct of ethylene production and is sold to make tires, automotive parts, roofing materials and other consumer products. It is a colorless, flammable gas with a mild aromatic odor. High vapor concentrations could cause eye, nose, throat irritation and dizziness. Chlorine is an element that occurs naturally as sodium chloride (table salt). It is used to purify 98% of our nation's drinking water, is in 85% of all medicines, is used in hospital sanitation, and is the basic building block in the production of many of Dow's products. Some of these consumer products are laundry bleach, garden and lawn herbicides, vinyl siding for homes, and PVC plumbing pipes. 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. Inventories for the RMP regulated substances at the Louisiana Division are listed in the following table. RMP Regulated Substance Inventory Quantity (lbs) 1,3-Butadiene 8,600,000 1,3-Pentadiene 2,200,000 1-Butene 2,300,000 2-Butene-cis 1,300,000 2-Methyl-1-butene 330,000 2-Methylpropene 3,600,000 Acetylene 10,000 Ammonia 500,000 Butane 2,900,000 Chlorine 12,000,000 Chloroform 22,000,000 Epichlorohydrin 360,000 Ethyl chloride 110,000 Ethylene 6,200,000 Ethylene oxide 1,600,000 Hydrogen 220,000 Hydrogen chloride/Hydrochloric Acid 980,000 Isobutane 160,000 Isopent ane 1,700,000 Isoprene 4,900,000 Methane 60,000 Methyl chloride 8,400,000 Methyl ether 45,000 Pentane 7,200,000 Propane 80,000,000 Propylene 3,200,000 Propylene oxide 24,000,000 Vinyl chloride 30,000,000 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures To evaluate the worst case scenarios, we have used the EPA's OCA Guidance Reference Tables or Equations. For alternative release scenario analyses we have employed the modeling programs PHAST and Safer Trace. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 3 toxic substances as a class involves a catastrophic release from the Solvents/EDC Plant. In this scenario 800,000 lbs. of Hydrogen chloride (anhydrous) [Hydrochloric acid] is released in a gaseous form over 10 minutes. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of >25 miles is obtained corresponding to a toxic endpoint of 0.030 mg/L. The alternative release scenario for Hydrogen chloride (anhydrous) [Hydrochloric acid] involves a release from the Solvents/EDC Plant. The scenario involves the release of 81,000 lbs. of Hydrogen chloride (anhydrous) [Hydrochloric acid] in a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.030 mg/L of Hydrogen chloride (anhydrous) [Hydrochloric acid] is 6.2 miles. The alternative release scenario for Chlorine involves a release from the Chlorine Plant. The scenario involves the release of 17,360 lbs. of Chlorine in a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of Chlorine is 6.9 miles. The alternative release scenario for Ethylene oxide [Oxirane] involves a release from the Glycol 2 Plant. The scenario involves the release of 41,250 lbs. of Ethylene oxide [Oxirane] in a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.090 mg/L of Ethylene oxide [Oxirane] is 1.9 miles. The alternative release scenario for Methyl chloride [Methane, chloro-] involves a release from the Cellulose Plant. The scenario involves the release of 49,400 lbs. of Methyl chloride [Methane, chloro-]. Toxic liquid is assumed to be released to form a 1-cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.82 mg/L of Methyl chloride [Methane, chloro-] is 0.60 miles. The alternative release scenario for Chloroform [Methane, trichloro-] involves a release from the Methanes Plant. The scenario involves the release of 80,000 lbs. of Chloroform [Methane, trichloro-]. Toxic liquid is assumed to be released to form a 1-cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.49 mg/L of Chloroform [Methane, trichloro-] is 0.30 miles. The alternative release scenario for Ammonia (anhydrous) involves a release from the Environmental Operations Plant. The scenario involves the release of 1070 lbs. of Ammonia (anhydrous) in a gaseous form over 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (anhydrous) is 0.20 miles. The alternative release scenario for Epichlorohydrin [Oxirane, (chloromethyl)-] involves a release from the Glycol 1 Plant. The scenario involves the release of 6010 lbs. of Epichlorohydrin [Oxirane, (chloromethyl)-]. Toxic liquid is assumed to be released to form a 1-cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Passive mitigation controls such as dike(s) are taken into account to calcu late the scenario. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.076 mg/L of Epichlorohydrin [Oxirane, (chloromethyl)-] is 0.07 miles. The alternative release scenario for Propylene oxide [Oxirane, methyl-] involves a release from the Glycol 1 Plant. The scenario involves the release of 1946 lbs. of Propylene oxide [Oxirane, methyl-]. Toxic liquid is assumed to be released to form a 1-cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 10 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.59 mg/L of Propylene oxide [Oxirane, methyl-] is 0.04 miles. The worst case release scenario submitted for Program 3 flammable substances as a class involves a catastrophic release from the LHC 3 Plant. In this scenario 6,700,000 lbs. of 1,3-Butadiene is released. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 1 0 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the calculated distance of 1.5 miles is obtained corresponding to an endpoint of 1 psi overpressure. The alternative release scenario submitted for Program 3 flammable substances involves a release from the LHC 3 Plant. The release is assumed to result in a Jet fire. The scenario involves the release of 88,400 lbs. of 1,3-Butadiene in 10 minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint is 0.12 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information The Dow Chemical Company-Loui siana 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 Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is What If/Checklist (combined), HAZOP, the Dow Fire and Explosion Index, the Dow Chemical Exposure Index, and Reactive Chemicals/Process Hazards Analysis. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of 3 years. Findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 03/22/1999. Operating Procedures For the purposes of safely conducting activities within our covered processes, The Dow Chemical Company-Louisiana Operations maintains written operating procedures. 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 The Dow Chemical Company-Louisiana Operations 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. Refresher training is provided as needed. Mechanical Integrity The Dow Chemical Company-Louisiana Operations carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, st orage tanks, piping systems, relief and vent systems, emergency shutdown systems, 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. Equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at The Dow Chemical Company-Louisiana Operations to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 05/20/1999. 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 offered 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 c onducted as a regular practice at The Dow Chemical Company-Louisiana Operations. The most recent review was performed on 05/25/1999. 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 The Dow Chemical Company-Louisiana Operations conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent compliance audit was conducted on 05/25/1999. These audits are carried out at least every 3 years and corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation The Dow Chemical Company-Louisiana Operations 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 The Dow Chemical Company-Louisiana Operations truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. Contractors Our company 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. The Dow Chemical Company-Louisiana Operations has a system in place to inform the contractors of known potential hazards related to the contractor's work and to the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. Contractors are also required to inform Dow Chemical Company of any hazards they may introduce at the site. 5. Five-year Accident History The Dow Chemical Company-Louisiana Operations 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 3 accidental releases as defined by the RMP rule of regulated substances from our facility within the last 5 years. The first release took place on 10/03/1994 and involved 7913 lbs. of Chlorine. No deaths or injuries occured offsite as a result of this accident. Several evacuations were issued. Onsite, there were no deaths or injuries. There was some onsite property damage. Another release, of 2977 l bs. of Ethylene oxide [Oxirane], occurred on 12/11/1994. No deaths or injuries occured offsite as a result of this accident. Onsite, there were no deaths or injuries. Another release, of 7500 lbs. of Vinyl chloride [Ethene, chloro-] and 4420 lbs. of Hydrogen chloride (anhydrous) [Hydrochloric acid], occurred on 04/28/1995. No deaths or injuries occured offsite as a result of this accident. Onsite, there were no deaths or injuries. There was some onsite property damage. 6. Emergency Response Plan The Dow Chemical Company-Louisiana Operations has a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. Iberville and West Baton Rouge Parish Offices of Emergency Preparedness are the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety There are no planned changes to improve safety at this time as a result of our implementing the accidental release prevention program. |