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Evonik CYRO - Fortier Plant

Parent Companies:
EVONIK CYRO Industries LLC
EPA Facility ID:
100000192374
Other ID:
Facility DUNS:
60809647
Parent Company DUNS:
0

Location:

Address:
10800 River Road (LA Hwy. 18)
Waggaman, LA 70094
County:
JEFFERSON
Lat / Long:
29.957, -90.270 (Get map)
Method:
Interpolation - Map
Description:
Other
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Evonik CYRO Industries LLC
Phone:
(973) 541-8000
Address:
379 Interpace Parkway
Parsipanny, NJ 07054
Foreign Address:

Person responsible for RMP implementation:

Name:
Michael Rinner
Title:
Evonik CYRO Plant Manager

Emergency contact:

Name:
Michael Rinner
Title:
Evonik CYRO Plant Manager
Phone:
(504) 431-6706
24-hour phone:
(504) 239-1494
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(504) 431-6164
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Jefferson Parish
Full-Time Equivalent Employees:
78
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
1982 (V-7)
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
July 19, 2013
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Methyl Methacrylate
RMP ID:
1000062650
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Hydrocyanic acid
74-90-8
2,900
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Robert Hillman
Address:
10800 River Road
Evonik Cyro Unit
Waggaman, LA 70094
Foreign Address:

Phone:
(504) 431-6164

Latest RMP Submission:

Date:
May 20, 2015
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000049821

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 Methyl Methacrylate)
CBI claimed:
No
Percent weight:
5.4
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:
D
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 Methyl Methacrylate)
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):
1.50
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers

4. Flammables: Worst-case

None

5. Flammables: Alternative release

None

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

Methyl Methacrylate, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000052040
Safety Review Date
March 31, 2015, since latest RMP submission
PHA Update Date
Nov. 17, 2010, since latest RMP submission
PHA Techniques
  • What if/Checklist
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • None
Procedure Review Date
March 31, 2015, since latest RMP submission
Training Review Date
April 8, 2015, since latest RMP submission
Maintenance Review Date
Feb. 25, 2015, since latest RMP submission
Maintenance Inspection Date
May 19, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Nov. 17, 2014
Management of Change Review Date
July 3, 2012
Pre-startup Review Date
Jan. 13, 2015
Compliance Audit Date
Feb. 17, 2014
Compliance Audit Change Completion Date
March 31, 2015
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
April 6, 2010
Hot Work Review Date
Dec. 10, 2014
Contractor Safety Review Date
Oct. 27, 2014, since latest RMP submission
Contractor Safety Eval. Date
March 23, 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:
Jan. 16, 2015
Local Response Agency:
Local Response Agency Phone:
(504) 349-5360
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

Evonik CYRO's Risk Management Plan

(40 CFR 68, EPA Chemical Accident Prevention Provisions)



LDEQ Facility ID Number:

EPA Facility Identifier:



Evonik-CYRO-Fortier Executive Summary



68.155 (a) ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES



Evonik-CYRO is a leader among chemical manufacturers in its safety, health and environmental programs. Our commitment to protect our employees and the communities that are home to our operations is an integral part of Evonik CYRO's way of doing business. Evonik CYRO-Fortier facility is located at the Fortier industrial site, owned and operated by Cornerstone Chemical Company (CCC). Evonik CYRO-Fortier uses Cornerstone Chemical Company's established safety, health, emergency response and environmental policies and standards to meet or exceed all regulatory requirements. As part of the Fortier site, Evonik CYRO subscribes to the codes established for American Chemistry Council Responsible Care®.



68.155 (b) THE STATIONARY SOURCE AND THE REGULATED SUBSTANCES HANDLED



The Evonik CYRO-Fortier facility consists of a continuous manufacturing plant producing methyl methacrylate (the MMA process). The process at the Fortier facility that produces a regulated substance is methyl methacrylate.



Methyl methacrylate (MMA Process) is used to make many products such as plastics, floor wax and medical devices. The regulated substance involved with this continuous operation is hydrocyanic acid (HCN).



68.155 (c) THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS



Evonik CYRO's general accidental release prevention program includes:



- EPA 40 CFR 68 - Risk Management Plans

- OSHA 29 CFR 1910.119 - Process Safety Management of Highly Hazardous Chemicals

- OSHA 29 CFR 1910.120 - Hazardous Waste Operations & Emergency Response

- Other EPA, OSHA, DOT and State regulations

- Generally recognized & accepted engineering codes and standards


- Cornerstone Chemical Company's Safety, Health, Environmental and Engineering standards



The following engineering and administrative controls have been implemented in the MMA Plant to prevent a release of hydrocyanic acid (HCN) a raw material supplied by Cytec Industries:



- High level interlock on acetone cyanohydrin (ACH) Reactor shuts valves on HCN inlet to prevent overflow.

- Leak detection systems on ACH Stock Tanks to provide early detection of a leak on the ACH tank floor.

- Upgraded material of construction on ACH Stock Tanks to stainless steel.

- Installed system to collect vent emissions from ACH Stock Tanks to prevent emissions to atmosphere.

- Interlocks on ACH Reactor system to prevent release due to overpressure or high temperature.

- Upgraded level control and installed redundant level indicator on Stripper Lights Collection Pot to minimize the potential for release to atmosphere due to overpressure of Stripper Column.

- Installed sealless pumps on the Crude ACH system.



68.155 (d) THE FIVE-YEAR ACCIDENT HISTORY



Upon review of the accident history files for the Evonik CYRO-Fortier MMA plant, it has been determined that no applicable incidents occurred at the MMA plant during the past five years.





68.155 (e) THE EMERGENCY RESPONSE PROGRAM



Evonik CYRO's Emergency Procedures are implemented under Cornerstone Chemical Company's Emergency Response Program. The procedures, which contain plant emergency response guidelines, were developed to reduce the risk of a chemical release to employees and the public. Communications are with both Jefferson and St. Charles Parish's departments of emergency management, the City of Kenner fire department, Louisiana State Emergency Response, and others as needed. Fortier responds to incidents with a facility Emergency Response Team that is trained to First Responders Operations level. We have a Community Alert Network (CAN) automated system that can call to warn neighbors of emergency, as w
ell as call in additional Cytec personnel if needed in the event of an emergency. We also have access to a parish-wide siren/message warning system, should it become necessary to notify neighboring residents of a plant emergency. Planned quarterly drills are used to test the procedures. Fortier also has mutual aid agreements with local agencies, which can assist in the event of an emergency.





68.155 (f) PLANNED CHANGES TO IMPROVE SAFETY



The Evonik CYRO-Fortier Plant is constantly striving to upgrade its processes, control technology, employee training, and inspection, repair and maintenance of process equipment in order to improve safety.





TITLE V AIR PERMITS



Evonik CYRO-Fortier currently has one Title V Operating Permit as follows:



Facility Permit I.D.

Methyl Methacrylate Plant 1982 (V-7)



Following the closure of sale on May 31, 2005, an application was be made to the Louisiana Department of Environmental Quality. The permit is in Evonik CYRO's name.





TOPOGRAPHY



The urban option was used in dispersion projections for endpoint. Urban was chosen because of the immediate urban area north of the river and the quasi-urban environment inside of the plant boundaries.