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CVD, Inc

Parent Companies:
Rohm and Haas Advanced Materials
The Dow Chemical Company
EPA Facility ID:
100000031887
Other ID:
70560MRTHHWY8
Facility DUNS:
21010749
Parent Company #1 DUNS:
1381581
Parent Company #2 DUNS:
0

Location:

Address:
11911 Advanced Materials Drive
New Iberia, LA 70562
County:
IBERIA
Lat / Long:
29.800, -91.813 (Get map)
Method:
Interpolation - Digital map source (TIGER)
Description:
Unknown
Horizonal accuracy:
100 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
The Dow Chemical Company
Phone:
(337) 867-4263
Address:
Midland Center
Midland, MI 48674
Foreign Address:

Person responsible for RMP implementation:

Name:
Mark Cresanti
Title:
Site Leader

Emergency contact:

Name:
Mark Cresanti
Title:
Site Leader
Phone:
(337) 256-9217
24-hour phone:
(337) 867-4263
Ext or PIN:
Ext: 2244

Other contacts:

Facility (or company) email:
Facility phone:
(337) 867-4263
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Iberia Parish LEPC
Full-Time Equivalent Employees:
75
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Aug. 19, 2009
Inspecting Agency:
EPA
Using Predictive Filing:
No

Processes:

Zinc Selenide CVD Process
RMP ID:
1000061468
CBI claimed:
No
Program Level:
3
NAICS:
Optical Instrument and Lens Manufacturing (333314)
Chemical name
CAS#
Quantity (lbs.)
CBI
Hydrogen selenide
7783-07-5
9,000
No
Public OCA Chemical
0
No
Silicon Carbide
RMP ID:
1000061469
CBI claimed:
No
Program Level:
3
NAICS:
Optical Instrument and Lens Manufacturing (333314)
Chemical name
CAS#
Quantity (lbs.)
CBI
Methyltrichlorosilane [Silane, trichloromethyl-]
75-79-6
73,500
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Chrystal L. Beasley
Address:
11911 Advanced Materials Rd.
New Iberia, LA 70562
Foreign Address:

Phone:
(337) 867-4263

Latest RMP Submission:

Date:
March 11, 2015
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
No
RMP ID:
1000049029

Deregistration:

Date:
Effective Date:
Reason:
Source terminated operations
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 Zinc Selenide CVD Process)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Rural
Passive mitigation
considered:
  • Enclosures
not considered:
  • Dikes
  • 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 Zinc Selenide CVD Process)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Rural
Passive mitigation
considered:
  • Enclosures
  • Alarms
not considered:
  • Dikes
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Sprinkler systems
  • Scrubbers
not considered:
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Emergency shutdown
Public OCA Chemical (in Silicon Carbide)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Rural
Passive mitigation
considered:
  • Dikes
not considered:
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Sprinkler systems
not considered:
  • 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

Feb. 28, 2015 at 12:41
ID:
1000037845
NAICS:
Commercial and Service Industry Machinery Manufacturing (33331)
Duration:
5 minutes
Chemicals involved:
  • Hydrogen selenide
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:
0
Property damage:
$0
Environmental damage:
Initiating event:
Human Error
Contributing factors:
  • Human error
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Revised operating procedures
Oct. 23, 2014 at 11:00
ID:
1000037846
NAICS:
Commercial and Service Industry Machinery Manufacturing (33331)
Duration:
3 minutes
Chemicals involved:
  • Hydrogen selenide
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:
0
Property damage:
$0
Environmental damage:
Initiating event:
Human Error
Contributing factors:
  • Human error
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Revised operating procedures
  • Changed process

7. Prevention: Program level 3

Zinc Selenide CVD Process, Optical Instrument and Lens Manufacturing (333314)
Prevention Program ID:
1000051114
Safety Review Date
Oct. 15, 2014, since latest RMP submission
PHA Update Date
Oct. 15, 2014, since latest RMP submission
PHA Techniques
  • None
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
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Fire Walls
  • Blast Walls
  • Deluge System
  • Water Curtain
  • Enclosure
  • Neutralization
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Feb. 26, 2015, since latest RMP submission
Training Review Date
Feb. 25, 2015, since latest RMP submission
Maintenance Review Date
July 15, 2014, since latest RMP submission
Maintenance Inspection Date
July 28, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 1, 2011
Management of Change Review Date
July 1, 2014
Pre-startup Review Date
Oct. 27, 2013
Compliance Audit Date
Sept. 16, 2013
Compliance Audit Change Completion Date
June 30, 2015
Incident Investigation Date
Jan. 14, 2015
Incident Invest. Change Completion Date
Dec. 31, 2015
Participation Plan Review Date
Aug. 19, 2014
Hot Work Review Date
Jan. 25, 2015
Contractor Safety Review Date
Jan. 25, 2015, since latest RMP submission
Contractor Safety Eval. Date
Jan. 25, 2015, since latest RMP submission
Silicon Carbide, Optical Instrument and Lens Manufacturing (333314)
Prevention Program ID:
1000051115
Safety Review Date
Oct. 14, 2014, since latest RMP submission
PHA Update Date
Oct. 14, 2014, since latest RMP submission
PHA Techniques
  • None
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
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Nov. 25, 2014, since latest RMP submission
Training Review Date
Feb. 25, 2015, since latest RMP submission
Maintenance Review Date
Dec. 25, 2014, since latest RMP submission
Maintenance Inspection Date
Feb. 28, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 1, 2011
Management of Change Review Date
July 1, 2014
Pre-startup Review Date
Oct. 27, 2013
Compliance Audit Date
Sept. 16, 2013
Compliance Audit Change Completion Date
June 30, 2015
Incident Investigation Date
Jan. 14, 2015
Incident Invest. Change Completion Date
Dec. 31, 2015
Participation Plan Review Date
Aug. 19, 2014
Hot Work Review Date
Jan. 25, 2015
Contractor Safety Review Date
Jan. 25, 2015, since latest RMP submission
Contractor Safety Eval. Date
Jan. 25, 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:
March 27, 2014
Local Response Agency:
Local Response Agency Phone:
(337) 369-4427
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





Accident Release Prevention Program and Emergency Response Policy



It is the policy of CVD, Inc, formerly known as Rohm and Haas Advanced Materials located at 11911 Advanced Materials Rd New Iberia, LA 7060, a wholly subsidiary of The Dow Chemical Company (Dow) who operates the facility to implement the requirements of the Risk Management Program (RMP) herein described in accordance with the USEPA regulations under 40 CFR Part 68 and with the corresponding regulations under OSHA's Process Safety Management (PSM) program. The objective is to minimize the impact to Advanced Materials' employees, the public and the environment. This objective is met by continuing to utilize general good operating procedures, providing appropriate training to all employees, and coordinating response activities, as necessary, with the local emergency response providers. Dow's management is committed to providing the resources necessary to implement this policy.



Facility Description



Dow is located in Weeks Island, LA and operates primarily as a manufacturer of zinc sulfide, zinc selenide, and silicon carbide. Methytrichlorosilane (MTS) and Hydrogen Selenide (H2SE) are utilized at the facility in sufficient quantities that exceed the threshold subject to the RMP requirements as detailed at 40 CFR Part 68. Another chemical H2S which is regarded as being potentially harmful is also used at the facility, but does not exceed the threshold applicability. These substances are handled and stored using the best manufacturing practices, including specially designed collectors, cylinders, or bulk tank with mitigation measures.



Emergency Contact

Mark Cresanti, site leader, is the designated emergency contact. Specific contact information is listed in the RMP eSubmit Tool.



Substance Description



Hydrogen selenide (N 29.4803.81 - W 91.4847.57) is generated at Weeks Island at the gas plant. Substance exceeds the threshold due to storage capacity. Hydrogen selenide is stored in i
ndividual 120 pound cylinder. There are approximately 100 cylinders in service during the generation of the substance. There are 20 cylinders connected by manifold and interconnected to the furnace. Maximum capacity of the equipment cylinders is 12,000 lbs minus the inventory controls. Daily production levels are entered into a database and monitored for total inventory. The inventory does not exceed 10,000 pounds. Maximum amount in the process: 10,000 pounds. The maximum flow rate to three furnaces is 30lbs/hour. H2Se is produced at DOW by bubbling hydrogen gas (H2) through molten selenium metal (Se). This batch process is accomplished in a high temperature, water cooled, pressurized stainless steel reactor. This heterogeneous reaction produces gaseous H2Se which is later condensed into cooled collectors. The hydrogen is stored both as a liquid in a vertical storage tank



MTS (N 29.480632 - W 91.484933) is a flammable, corrosive liquid, with a specific gravity of 1.28, and a vapor pressure of 150 torr at 25 C. It is delivered to Dow via a tank truck and transferred into a large above ground storage tank onsite at our Weeks Island Production Facility. Substance exceeds the regulatory threshold based on the storage capacity. From the large storage tank, the MTS is transferred to smaller stainless steel processing bubblers. The transfer is made by differential pressure through stainless steel tubing. The bubblers are used to vaporize the MTS for introduction into the high temperature vacuum furnace. Argon and/or nitrogen are used as a carrier gases for the MTS, as a flow component, and as an inerting gas. The argon and/or nitrogen are supplied from liquid storage tanks. MTS is stored in a 73,500 pound storage tank. When offloading occurs the tank level provides an indication when 1200 gallons are met. The safety interlock system will only allow 4540 gallons. Once the allocated amount is contained in the storage tank, the substance is transferred via pipeli
ne to (6) bubblers. Due to MTS reaction with moisture and water resulting in HCl residual blanket gas is diverted to the Silicon Carbide scrubber during unloading. Maximum capacity of the storage tank is 73,500 lbs, but the site's allowable storage capacity is 55,000 lbs.



Consequence Analysis



The accidental Release Prevention Program requires facilities to evaluate the impact of a release of the regulated chemicals under well-defined conditions. Two types of releases must be considered; first, a "worst case scenario" must be examined and secondly, and an alternate case scenario. The model represents the worst case failure of the H2Se cylinders and an alternate case for the MTS tank and H2Se pipe transfer leak.



The modeling for both case scenarios was completed using EPA's RMP Comp under rural conditions. Based on a further review, an investigation proved that the combination of vegetation and tree shrubs within close proximity would be better modeled to benefit the community and environment under the rural condition.



The toxic worst case scenario consequence analysis performed for H2Se indicated if there's a rupture failure of the entire (40) cylinder interconnected manifold than a release of 2400 pounds could potential impact residence, schools, recreational parks, and an industrial business before dissipating at the endpoint of 18 miles. The mitigation measure for this scenario is the enclosed location of the cylinders.



The toxic alternative case scenario consequence analysis performed for H2Se indicated if there's a pipe leak at the discharge of the manifold release rate of 31.2 pounds/minute for 10 minutes could potential impact an industrial business before dissipating at the endpoint of 1.5 miles. The mitigation measure for this scenario is the enclosed location of the cylinders.



The toxic alternative case scenario consequence analysis performed for MTS indicated if there's a pipe leak at the discharge of the tank into the process at a
rate of 460 pounds/minute for 10 minutes could potential impact an industrial business before dissipating at the endpoint of 0.6 miles. The mitigation measure for this scenario is the dike containment surrounding the tank.



Five Year Accident History



Dow has had nominal releases of H2Se from the facility that did not met the reporting criteria by causing injuries requiring medical treatment, significant property damage, affects the public or the environment. Therefore, the incidents are listed under the accident history and the quantity released was below 0.000001 pounds.



Emergency Response Program



Dow personnel are trained in emergency response and capable of responding 24 hours each day and seven days per week. These personnel receive annual training on emergency procedures and hazardous work operations (HAZWOPER) per OSHA related requirements. .



Planned Changes to Improve Safety



Dow completes a thorough review of the potential impact of all chemicals that are considered for use at the facility. This includes compounds that are not specifically addressed under the RMP regulation. Furthermore a review is conducted on a routine basis to ensure that each process that employs hazardous chemicals are thoroughly examined.



The facility is governed by a set of OSHA and USEPA regulations that require planning and facility activities intended to prevent a release of hazardous material, or if a release inadvertently occurs, to minimize the consequences of a release to the employees of the facility, the public and the environment. These regulations include:

- 40 CFR Part 68, Accidental Release Prevention

- 40 CFR Part 112, Spill Prevention, Control and Countermeasure

- 40 CFR Part 264, Hazardous Waste Contingency Plan

- 29 CFR Part 119, Process Safety Management



The key concepts in Dow's release prevention program are employee participation, appropriate design and maintenance of equipment, appropriate training of all employees, and ongoing commun
ication and training with local responders.



Employee participation in the release prevention program is encouraged and supported by Dow's leadership. Key personnel are responsible for conducting and implementing findings from the Process Hazard Analysis (PHA) for MTS and H2Se. Morton

Dow's policy is to construct all new equipment, systems, and facilities in accordance with the most current building and safety codes. This ensures the appropriate safety and release prevention systems are included during project initiation. Dow maintains a computerized program of maintenance activities to ensure that key systems are maintained appropriately to mitigate risk.



Dow is committed to providing comprehensive safety training to all employees regarding safety procedures. Each new employee is provided comprehensive safety training during his or her initial orientation for the facility. In addition, Dow conducts regularly scheduled safety training for all employees each year. Additional training is provided to maintenance personnel for the systems they are responsible for. Members of Morton's emergency response team receive annual training to ensure that response actions are promptly and safely completed. Annual training with local responders is part of this program.