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Hexion Inc. - Geismar Facility

Parent Companies:
Hexion LLC
EPA Facility ID:
100000168016
Other ID:
Facility DUNS:
1338797
Parent Company DUNS:
166495924

Location:

Address:
4338 Hwy. 73
Geismar, LA 70734
County:
ASCENSION
Lat / Long:
30.207, -91.018 (Get map)
Method:
Interpolation - Digital map source (TIGER)
Description:
Center of Facility
Horizonal accuracy:
15 m
Horizontal reference datum:
World Geodetic System of 1984
Source map scale:

Owner/Operator:

Name:
Hexion Inc.
Phone:
(225) 744-2000
Address:
P.O. Box 232
Geismar, LA 70734
Foreign Address:

Person responsible for RMP implementation:

Name:
Rick Dickmyer
Title:
Site Leader

Emergency contact:

Name:
Ricky Dickmyer
Title:
Site Leader
Phone:
(225) 744-2021
24-hour phone:
(225) 290-5691
Ext or PIN:

Other contacts:

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

Safety:

Local Emergency Planning Committee:
Ascension Parish LEPC
Full-Time Equivalent Employees:
60
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
2019 and 2631
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Dec. 3, 2015
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Formaldehyde Solutions
RMP ID:
1000066568
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Formaldehyde (solution)
50-00-0
24,000,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Bruce Raff with CK Associates, LLC
Address:
17170 Perkins Road
Baton Rouge, LA 70810
Foreign Address:

Phone:
(225) 755-1000

Latest RMP Submission:

Date:
May 2, 2016
Type:
Resubmission
Reason:
Revised PHA / Hazard Review due to process change (40 CFR 68.190(b)(5))
Registered:
Yes
RMP ID:
1000052900

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 Formaldehyde Solutions)
CBI claimed:
No
Percent weight:
52.0
Physical state:
Liquid
Model used:
EPA's OCA Guidance Reference Tables or Equations
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • Dikes
not considered:
  • 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 Formaldehyde Solutions)
CBI claimed:
No
Percent weight:
52.0
Physical state:
Liquid
Model used:
EPA's OCA Guidance Reference Tables or Equations
Wind speed (meters per sec):
2.70
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
  • Sumps
not considered:
  • Enclosures
  • Berms
  • Drains
Active mitigation
considered:
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

No Registered Accidents

7. Prevention: Program level 3

Formaldehyde Solutions, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000055433
Safety Review Date
July 20, 2015, since latest RMP submission
PHA Update Date
Oct. 1, 2015, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Overfilling
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
Mitigation Systems
  • Sprinkler System
  • Dikes
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
Procedure Review Date
July 20, 2015, since latest RMP submission
Training Review Date
Sept. 3, 2015, since latest RMP submission
Maintenance Review Date
May 31, 2013, since latest RMP submission
Maintenance Inspection Date
May 21, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Oct. 19, 2015
Management of Change Review Date
Dec. 4, 2014
Pre-startup Review Date
July 31, 2014
Compliance Audit Date
May 8, 2013
Compliance Audit Change Completion Date
April 24, 2014
Incident Investigation Date
March 10, 2015
Incident Invest. Change Completion Date
July 1, 2015
Participation Plan Review Date
Jan. 15, 2016
Hot Work Review Date
April 15, 2015
Contractor Safety Review Date
Oct. 19, 2015, since latest RMP submission
Contractor Safety Eval. Date
Oct. 19, 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:
Dec. 31, 2014
Local Response Agency:
Local Response Agency Phone:
(225) 621-8300
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

Executive Summary



The March 2016 update was done as required by 40 CFR 68.190(b)(6) which requires an update within six months of a change that requires a revised PHA or hazard review. Hexion is starting up the G-6 project which required a revised PHA. Hexion is using this update to increase the maximum on-site quantity. The WCS and ARS were updated using the EPA Consequence Analysis Guidelines.



On January 15, 2015, the previous company name of Momentive was changed to Hexion LLC. There was no change in ownership associated with this change.



1.Accidental release prevention and emergency response policies



As stated in our Worldwide Health, Safety, and Environmental Policy and Principles, Hexion LLC.is committed to health, safety, and environmental excellence. To accomplish this we integrate health, safety, and environmental planning into all business activities. This includes complying with applicable laws, responsibly managing risks, and working collaboratively with others in addressing health, safety, and environmental issues.



In the Hexion Safety Manual, the Safety Policy Statement clearly states that safety will not be compromised to achieve any other operational or business objective. This manual defines requirements and guidelines developed to prevent injuries and accidental releases.



Included in the Safety Manual are Emergency Response Policies that state that safety is the top priority in all emergency response situations. This policy refers to the plant Emergency Response Plan for specific procedures for handling releases of hazardous materials.



2.Stationary source and regulated substances handled



This plant primarily makes formaldehyde solutions. The site includes five (5) formaldehyde manufacturing facilities.



The regulated substance used in the plant and the maximum quantity stored are:



Formaldehyde 10,771,340 lbs.


.

.

3.Accidental release prevention program and chemical-specific prevention steps



This plant has a comprehensive process safety management program that is in compliance with the EPA Accidental Release Prevention Rule, the OSHA Process Safety Management Standard, and all applicable state codes and regulations. A safety management system is in place to assure on-going compliance. This management system includes the Safety Manual, a list of site safety responsibilities, a file system to maintain records of compliance, and a monthly Safety Committee meeting, where a management control checksheet is used to verify that tasks were completed on schedule. The Site Manager has overall responsibility for this program.



"Process stewards" are assigned to maintain and improve the safety of their units. Their duties include keeping operating procedures up-to-date, training operators so they can safely carry out these procedures, assuring that the plant is run safely on a daily basis, and when necessary, investigating incidents in their unit. All employees participate in the safety program to improve safety and plant operation.



Each Process Steward maintains an Operating Guide that includes process safety information, operating procedures, and a training certification program. Operators use this Operating Guide as a training tool and for reference. By applying the information it contains their actions will prevent accidental releases.



Process hazard analyses are conducted on an on-going basis to identify hazards and recommend safeguards that will prevent an accidental release. As a result of initial process hazard reviews, a significant investment was made in process control systems. In the formaldehyde plant, an automatic shutdown system is installed that will shut down the plant before a release oc
curs if safe operating conditions cannot be maintained For the urea-formaldehyde resin reactor, improved procedures reduce the risk of a release.



Two methods are used to assure that changes to plant equipment, procedures, or processes do not cause accidents. For equipment and procedure changes, a Change Worksheet initiates a safety review. This review may include process hazard analysis. Changes to product formulations initiate a review by a chemist, process engineer, and the site manager. Training is performed as needed to assure that those affected by the change understand its impact. Pre-Start-up Safety Reviews are performed to assure that the plant can be started up safely after a significant change is made.



A preventive maintenance program maintains the mechanical integrity of process equipment. A computer database is used to manage the preventive maintenance schedule and other corrective or improvement repairs necessary to maintain the ongoing integrity and reliability of the facility equipment. Each month scheduled equipment inspections, tests, or servicing are performed. The schedule is based on plant experience to reduce the likelihood of an accidental release caused by equipment failure



The requirements in the Safety Manual include safe work practices which prevent accidental releases. One important section describes safety measures for welding or other "hot" work, which includes a permit system to reduce the risk of fire. The Safety Manual also includes requirements for locking out equipment for maintenance. These procedures reduce the likelihood that a valving error will lead to a release.



Contractors, who periodically perform work in the plant, are given safety orientations to brief them on plant hazards and safety practices. Contractor safety programs and performance are evaluated prior to their selection for jobs that impact process safety.



Incidents that cause or could have caused a release are investigated and recommendat
ions are made to prevent recurrence. These recommendations may lead to improvements in equipment, procedures, operating conditions, or training.



Internal Corporate Health, Safety and Environmental Audits are conducted periodically to maintain compliance with local, state and federal regulations. Regional Safety and Environmental professionals periodically review the health, safety, and environmental programs. Addressing recommendations from these audits and reviews keeps the Facility's Safety and Environmental programs effective.



4.Five-year accident history



Within the past 5 years (June 23, 2009 to June 23, 2014), Hexion has had no accidental releases from covered processes that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage.



5.Emergency response program



The plant Emergency Response Plan describes procedures for actual and threatened releases, including coordination with fire department responders. This plan is written in the "One Plan" format to satisfy regulatory requirements of several agencies. An emergency response drill is conducted annually to test the Emergency Response Plan and reinforce training that plant responders receive.



6. Planned changes to improve safety



No significant changes are planned.