DuPont Pontchartrain Works - Executive Summary |
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17113 LDEQ Facility ID Number ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The DuPont Pontchartrain Plant adheres to Corporate policies, which could be summarized as follows: - All Safety and Environmental incidents are preventable. - The Goal is Zero - Zero Incidents, Period. - All employees and contractors are responsible for their safety. The Corporate policies are embodied in the numerous Safety, Health, and Environmental (SHE) and Engineering Standards, which apply globally. At the Pontchartrain Plant, the policies are implemented through the Pontchartrain Plant Process Management Manual (PMM). This manual is available to all employees through hard copies. In addition, the Pontchartrain Plant Emergency Manual lays out the complete Emergency Response program for the site. FACILITY DESCRIPTION The DuPont Pontchartrain Plant consists of 1132 acres, located in St John the Baptist Parish between the unincorporated areas of LaPlace and Reserve. About 200 acres o f the property are used for manufacturing areas, 590 acres are leased for cattle grazing, 30 acres are leased for recreation, and the remainder is set aside for wildlife habitat and future manufacturing needs. A portion of the area used for manufacturing is leased to DuPont Dow Elastomers, LLC. The DuPont Dow Elastomers facilities are considered to be a separate "stationary source" for the purposes of 40 CFR part 68. The DuPont Pontchartrain Plant site consists of 2 manufacturing processes: * Paraphenylene Diamine * Isophorone Diamine In the production of these products, anhydrous ammonia is the only regulated substance and is used as raw material. On site storage of ammonia railcars is also treated as a separate process for the purposes of 40 CFR part 68. WORST-CASE TOXIC RELEASE SCENARIO The worst-case release scenario for a toxic chemical is failure of an ammonia storage tank, with no mitigation assumed. This release has an off-site impact, as determined by the use of t he EPA's RMP Comp program. This release is unlikely due to the high-integrity design of the tank and associated equipment. WORST-CASE FLAMMABLE RELEASE SCENARIO There are no regulated flammables present above the threshold quantities. ALTERNATIVE TOXIC RELEASE SCENARIOS A pipe leak in the Anhydrous Ammonia unloading transfer piping was assumed, with a 10 minute duration because of the requirement for monitoring during unloading operations. This release was assumed to be mitigated by the proper function of excess flow valves installed on the railcar being unloaded and on the ammonia tank receiving the material. The excess flow valves limit the amount of ammonia released to the contents of the unloading lines. This release has an off-site industrial impact, but no impact on residential populations, as determined by the use of the OCA Guidance and the "Landview" program census data. ALTERNATIVE FLAMMABLE RELEASE SCENARIO There are no regulated flammables present above the thres hold quantities. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS The DuPont Pontchartrain Plant processes follow the requirements of DuPont Corporate SHE Standard S21A, "Process Safety Management." This Standard includes and embraces the requirements of 29 CFR 1910.119 and 40 CFR Part 68. Our Safety Programs include: Designing for Safety ... - A documented process technology system covers hazards of materials, equipment design basis, and process design basis. - Extensive accident prevention and mitigation systems are strategically located. - Applicable codes and standards are met or exceeded. - Materials of construction are chosen to provide mechanical integrity. - Quality Assurance ensures fabrication in accordance with design specifications and proper assembly. Maintaining our Plant ... - Maintenance personnel are trained and experienced. - Contractors are trained and qualified. - A work permit system controls hazards. Operating Safe ty ... - Operators are trained and job qualified. - Technical resources are available and utilized as required. - Operators follow approved procedures. Auditing our Operations ... - Routine safety inspections are conducted. - Corporate, independent and governmental audits and reviews are conducted. - Process Hazards Analyses are conducted. - Safety critical equipment is set up on a periodic inspection frequency to ensure ongoing mechanical integrity. - Pre-startup safety reviews are conducted prior to starting up any new or modified equipment. - Quality assurance of critical equipment ensures fabrication in accordance with design specifications. - All incidents are investigated and actions taken to prevent recurrence. SAFETY IS A JOB REQUIREMENT FOR ALL EMPLOYEES AND CONTRACTORS! THE FIVE-YEAR ACCIDENT HISTORY No deaths, injuries, or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmen tal damage has resulted from a release of Anhydrous Ammonia in the past five years. EMERGENCY RESPONSE PROGRAM The DuPont Pontchartrain Plant is operated 24 hours per day, 7 days per week by four rotating shifts. Each shift has an emergency response team lead by an emergency director. Only one of these emergency directors is listed in the data portion of the RPM. All of the emergency directors are listed below: A Shift: G. Mike Bankston B Shift: Mike Vicknair C Shift: Steve Larkey D Shift: Milton Hill Relief: Raymond Ernst Relief: Darryl "Slim" Nicholas Plant personnel are trained and equipped to respond to any releases of Anhydrous Ammonia. The program can be summarized as follows: Training and Preparation ... - Plant personnel receive emergency response training. - Plant emergency responders are trained. - Emergency response plans are current. - Plant participates in emergency drills. - Critiques are held on drills and actual events. - Plant is a membe r of the St John the Baptist Parish Local Emergency Planning Committee. If a Major Release Occurs ... - Emergency alarm is sounded. - Plant Emergency Operating Center is activated. - Plant Incident Commander and emergency squad respond. - The Community Alert system is sounded. - Community emergency responders are notified as appropriate. PLANNED CHANGES TO IMPROVE SAFETY .* Installing state-of-the-art ammonia gas detectors around ammonia storage tanks. * Continued focus on the "The Goal is Zero" for injuries and incidents. * Training in "Operational Discipline" for all process-related employees. |