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CS Metals of Louisiana LLC

Parent Companies:
CRI Metal Products, Inc.
Noble Metals, LLC
EPA Facility ID:
100000169649
Other ID:
LAR000032789
Facility DUNS:
0
Parent Company #1 DUNS:
0
Parent Company #2 DUNS:
0

Location:

Address:
7591 Highway 3214
Convent, LA 70723
County:
ST. JAMES
Lat / Long:
30.065, -90.829 (Get map)
Method:
Interpolation - Map
Description:
Center of Facility
Horizonal accuracy:
m
Horizontal reference datum:
Source map scale:

Owner/Operator:

Name:
CS Metals of Louisiana LLC
Phone:
(225) 562-1200
Address:
7591 Highway 3214
Convent, LA 70723 -2520
Foreign Address:

Person responsible for RMP implementation:

Name:
Ken Massett
Title:
Plant Manager

Emergency contact:

Name:
Dwayne Dugas
Title:
HSSE Supervisor
Phone:
(225) 562-1184
24-hour phone:
(225) 562-1181
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(225) 562-1200
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
St. James Parish LEPC
Full-Time Equivalent Employees:
58
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:
Inspecting Agency:
None
Using Predictive Filing:
No

Processes:

Unspecified process
RMP ID:
30012
CBI claimed:
No
Program Level:
3
NAICS:
Secondary Smelting, Refining, and Alloying of Nonferrous Metal (except Copper and Aluminum) (331492)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
100,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Environmental Resources Management
Address:
3501 N. Causeway Blvd.
Metairie, LA 70002
Foreign Address:

Phone:
(504) 831-6700

Latest RMP Submission:

Date:
May 22, 2000
Type:
First-time submission
Reason:
Registered:
No
RMP ID:
21311

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 Unspecified process)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
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:
  • 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 Unspecified process)
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:
Rural
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

No Registered Accidents

7. Prevention: Program level 3

, Secondary Smelting, Refining, and Alloying of Nonferrous Metal (except Copper and Aluminum) (331492)
Prevention Program ID:
16502
Safety Review Date
May 19, 2000, since latest RMP submission
PHA Update Date
Oct. 20, 1999, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Equipment failure
Process Controls
  • Relief Valves
  • Scrubbers
  • Manual Shutoffs
  • Interlocks
  • Alarms
  • Rupture Disks
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • Water Curtain
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • None
Procedure Review Date
May 19, 2000, since latest RMP submission
Training Review Date
May 19, 2000, since latest RMP submission
Maintenance Review Date
May 19, 2000, since latest RMP submission
Maintenance Inspection Date
March 14, 2000, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
None
Management of Change Review Date
May 12, 2000
Pre-startup Review Date
May 3, 2000
Compliance Audit Date
April 6, 2000
Compliance Audit Change Completion Date
May 12, 2000
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
May 9, 2000
Hot Work Review Date
March 23, 2000
Contractor Safety Review Date
May 19, 2000, since latest RMP submission
Contractor Safety Eval. Date
None, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
No
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:
May 12, 2000
Local Response Agency:
Local Response Agency Phone:
(225) 562-2265
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

CS Metals of Louisiana LLC (CS Metals) is a limited liability corporation owned by CRI Metal Products, Inc. and Noble Metals, LLC. The CS Metals facility is located in Convent, LA on Highway 3214. The facility will begin operation in May of 2000 and will employ approximately 60 full-time employees.

CS Metals views environmental and safety issues as a top priority and has dedicated resources to safety, health, and environmental programs. These programs are designed with a focus on accident prevention to CS Metals employees, neighbors, and the environment through the use of properly prepared and implemented safety procedures, operating procedures, inspection procedures, and training. These proactive measures also include periodic reviews, documentation of changes, and investigative steps to allow maximum protection of health, safety, and environmental concerns.

CS Metals manufactures specialty metal products such as vanadium and molybdenum primarily from used refinery catalysts. In order to properly manufacture these products, the Convent Facility uses anhydrous ammonia, which is stored in a single 20,000 gallon tank. CS Metals uses ammonia as a crystallizing agent for the specialty metals. The ammonia is recovered in the process through the use of scrubbing technology.

CS Metals has taken many precautions to prevent a release of this chemical from its facility and has invested significant amounts of time, capital, and planning to implement important safety precautions. These precautions include specific engineering design of equipment, use of pressure relief valves, standard operating procedures (SOP's), employee training, routine maintenance checks, and inspections. Pressure relief valves are in place to prevent failure of equipment integrity should pressure in equipment exceed normal operating ranges. The various procedures, training, maintenance checks, and inspections are strictly enforced to provide assurance that the equipment and process are
functioning as designed in order to provide maximum safety. Logs are kept for inspections and maintenance checks for review and planned action items for potential problems as additional preventative measures.

The Worst Case Release Scenario

CS Metals has performed an off-site consequence analysis for a worst-case scenario as defined by EPA. For this worst case scenario, it was assumed that the maximum capacity of the ammonia storage tank (20,000 gallons) would empty in 10 minutes assuming a wind speed of 1.5 meters per second, F class stability, and a temperature of 77? F. As a result of such a scenario, the potential off-site radius was estimated at 4.7 miles to the EPA defined toxic endpoint of 0.14 mg/l. This distance was calculated by the EPA software program RMP*Comp, which uses the RMP consequence analysis procedures recommended by the EPA.

This EPA consequence and procedure are quite conservative in its assumptions in order to maximize the potential distance in the radius for emergency planning purposes. The likelihood of ammonia traveling this distance off-site is nearly impossible since, at the very least, this distance does not account for the process controls and safety measures in place at the Convent Facility. For instance, CS Metals has operating procedures and administrative controls in place to prevent an ammonia release of the size required to be considered by the RMP rule. The tank is operated at less than half of its design pressure and temperature in order to provide substantially more protection against potential mechanical failure of the tank. In addition, administrative controls require that the ammonia storage tank is kept at only 85% of the tank capacity. Should the pressure in the tank rise above safe operating levels, the tank is equipped with two process safety valves which would provide a smaller and much more controlled release, should such be necessary.

The Alternate Case Release Scenario

The alte
rnate case scenario assumes that a ? inch valve on the discharge from the ammonia storage tank accidentally remains open for 60 minutes. This scenario was chosen as a conservative possibility and accounts for human error. The distance calculated by RMP*Comp for the alternate scenario was 0.2 miles before reaching the toxic endpoint of .14 mg/l. The calculation assumes a wind speed of 3 meters/second, D class stability, and a temperature of 77? F. This is a conservative estimation of the endpoint distance because the calculation also does not account for any passive or active mitigation measures. Also, sixty minutes is a long amount of time for a valve to be open without being noticed and corrected to stop the discharge. Written operating procedures, skilled operators, and routine equipment monitoring minimizes the chance of such an incident from occurring. However, even if such an incident was to occur and the ammonia was to reach 0.2 miles, the impact to the public or environment would be minimal. This is because this distance is just beyond property boundaries, a long and safe distance from residences, public receptors, or environmental receptors.

Accidental Release Prevention Program at CS Metals

CS Metals complies with all of the Program 3 Prevention Program Requirements as defined in the RMP rule. This includes an on-going program to maintain process safety information, current process hazard analyses, operating procedures, mechanical integrity, management of change programs, and training. In addition, CS Metals utilizes pre-startup safety reviews, compliance audits, and incident investigations to communicate and provide the opportunity for improvements when warranted. Use of hot work permits and a mandatory contractor safety plan is also part of the CS Metals Accidental Release Prevention Plan. Each of these areas is discussed further below:

A. Process Safety Information
CS Metals maintains documents which pertain to the hazards associated w
ith the process, the technology of the process, and the equipment in the process. To this end, Material Safety Data Sheets (MSDS) are kept on-site and describe the hazards associated with chemicals used in the process. The MSDS's contain information on toxicity, permissible exposure limits, physical data, reactivity data, corrosivity data, thermal and chemical stability data, and certain hazardous effects of mixing different materials.

CS Metals also maintains engineering design documents which provide the basis for design, process chemistry, intended inventories, equipment materials, and safe operating parameters. These documents include, but are not limited to, block flow diagrams, piping and instrumentation diagrams, equipment lists, operating manuals, and written procedure manuals.

B. Process Hazard Analyses (PHA)
CS Metals conducts comprehensive studies to ensure that hazards associated with its processes are identified and minimized through effective controls. The method used to carry out the PHA's is the HAZOP method. The studies are performed by a team of qualified personnel with expertise in engineering, process operations, and environmental, health, and safety. Each study is revalidated at a regular interval of at least every five years. The results of the hazard analyses are reviewed and potential problems noted during the analyses are prioritized for changes which adequately address the issue identified.

C. Operating Procedures
CS Metals has written necessary and numerous operating procedures to ensure safe operation of the process. The operating procedures are explained to the employees through appropriate training and cover many modes of operation including, start-up, shut-down, normal operation, and emergency conditions. These procedures and any changes to them are reviewed through the CS Metals management of change process as described in more detail below.

D. Training
CS Metals has a training program in place to ensure safe operat
ion of the process. The training consists of both off-site and on-the-job training. All employees are required to go through refresher training at least every three years to assure that the employees understand and adhere to the operating plans and procedures for the process areas to which they work. Safe work practices are included as duties for all employees.

E. Mechanical Integrity
CS Metals has written procedures in place to maintain the integrity of the process equipment. These procedures detail the inspection and testing requirements for the process equipment. The equipment inspected includes, but is not limited to, pressure vessels and storage tanks, piping systems, relief valves and other relief systems, emergency shutdown equipment, monitoring devices, alarms, and interlocks. The maintenance inspections are performed by employees skilled and trained in the procedures appropriate to their job tasks including the hazards associated with the process. The purpose of the mechanical integrity program is to identify and implement timely changes to potential problems noted during inspections and operations.

F. Management of Change
CS Metals has written procedures in place to manage changes in process chemicals, technology, equipment and procedures. Any changes, except "replacements in kind," must follow a rigorous management of change procedure. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are informed of, and trained in, the change prior to start-up of the process after such changes.

G. Pre-startup Safety Reviews
CS Metals performs pre-start up safety reviews for all new processes and modifications to existing processes. These reviews verify that construction and equipment meet the design specifications, appropriate operating and maintenance procedures, completion of a proper PHA, and required employee training.

H. Compliance Audits
Compliance audits
are conducted by person(s) knowledgeable of the process and are done at least every three years to verify the procedures and practices developed in accordance with 40 CFR 68 are being followed. CS Metals reviews the audit report and notes corrections when applicable.

I. Incident Investigation
CS Metals will promptly investigate incidents that result in, or could reasonably result in a catastrophic release of a regulated substance. An incident team comprised of knowledgeable employees will prepare a report describing the incident and give recommendations to prevent a reoccurrence. Such reports will be retained for at least 5 years.

J. Employee Participation
CS Metals encourages employees to express their opinions on improving process safety and incident prevention and has developed a written plan which fosters employee participation. CS Metals employees have full access to all PHA information and other information CS Metals has developed in accordance with the RMP rule.

K. Hot Work Permits
CS Metals has hot work procedures in place to control activities that have potential to cause accidental fires or other combustion at the Convent Facility. The strict procedures implement the fire prevention and protection requirements in 29 CFR 1910.252(a). Personnel who are to perform hot work are required to obtain a hot work permit issued by the Convent Facility before work may begin, and specific precautionary requirements must be met and maintained before and during hot work activity.

L. Contractors
CS Metals hires only contractors who have displayed good safety practices and are qualified to complete the desired job tasks. CS Metals also requires that every contractor employee has completed and passed the basic plant safety training administered by training agencies such as the Safety Council of Baton Rouge before access is allowed on-site. CS Metals explains all of the applicable hazards in the process, facility work procedures, and emergency response pro
cedures to the contractors. In addition, CS Metals periodically reviews contractor performance to determine if the contractor is maintaining their safety responsibilities.

The Five-Year Accident History

The CS Metals Convent Facility plans to begin full operations in May of 2000. To date, there have been no RMP accidents in the past five years.

The Emergency Response Program

CS Metals has a written emergency response plan and a contingency plan in place at the Convent Facility to protect public health and the environment. These plans detail specifics for notifying the public and the local emergency response agencies about accidental releases. These plans also detail a list of emergency personnel at the Convent Facility and the procedures for handling an emergency situation. Emergency equipment is inspected and tested on a regular basis to maintain the integrity of the emergency equipment. In addition, the CS Metals emergency response plan has been coordinated with the St James Parish Local Emergency Planning Committee (LEPC) community response plan.

Planned Changes to Improve Safety

CS Metals strives to provide safer operations at the Convent Facility through the on-going review and identified improvements to operating, inspection, and emergency response procedures. CS Metals will review all incident investigations thoroughly, and implement the appropriate changes to reduce the likelihood of future incidents. In addition, CS Metals willingly takes comments from employees as part of a joint effort between management and staff to continuously improve safety at the facility.