Cytec-Fortier Plant - Executive Summary |
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Executive Summary Fortier's Risk Management Plan (40 CFR 68, EPA Chemical Accident Prevention Provisions) 1357 LDEQ Facility ID Number Fortier Executive Summary (a) ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Cytec 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 Cytec's way of doing business. Cytec has established safety, health, emergency response and environmental policies and standards to meet or exceed all regulatory requirements. As a member of the Chemical Manufacturers' Association (CMA), Cytec subscribes to the codes established for Responsible Care .. (b) THE STATIONARY SOURCE AND THE REGULATED SUBSTANCES HANDLED Our facility consists of nine different continuous and batch manufacturing plants producing a variety of end products, including acrylonitrile, acrylamide, methyl methacrylate, melamine , ammonia, sulfuric acid and methanol. Acrylonitrile, a regulated substance, is used as a raw material to make a variety of products such as plastic fibers, rubbers and fuel mixtures. Other regulated substances involved with this continuous operation are propylene, hydrocyanic acid, propane and ammonia. Acrylamide is used to make water treatment chemicals, paper treatment chemicals and oil recovery chemicals. The regulated substance involved with this continuous operation is acrylonitrile. Methyl methacrylate 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. Melamine is used to make a variety of products such as hard plastics, laminates, microwave plates, flame retardants, spray paints and adhesives. The regulated substance involved with this continuous operation is ammonia. Ammonia, a regulated substance, is used as a fertilizer, refrigerant and in household clea ning agents. Another regulated substance involved with this continuous process is a flammable mixture containing methane and hydrogen. Sulfuric acid is used in car batteries, gasoline refining, fertilizer production, paper production and more. The regulated substance involved with this continuous process is oleum. Methanol is used in the manufacture of formaldehyde, acetic acid, antifreeze, paints and more. The regulated substance involved with this continuous process is a flammable mixture containing methane and hydrogen. The Distribution Services Department stores and transports acrylonitrile, as well as transports chlorine, propylene and oleum via railcar within the plant. All of these chemicals are regulated substances. The Utilities Department uses ammonia as a refrigerant and chorine for water treatment. Both are regulated substances. (c) WORST-CASE RELEASE SCENARIOS AND ALTERNATIVE RELEASE SCENARIOS The toxic worst-case scenario is the failure of a rail car and th e release of 110,000 pounds of chlorine. The release formed by the evaporating chlorine could reach offsite endpoints and nearby public and environmental receptors. The flammable worst-case scenario is the failure of a storage sphere and release of 6,000,000 pounds of propylene. The overpressure from ignition of the vapors could reach offsite endpoints and nearby public and environmental receptors. The alternative release scenario for propylene is the failure of a rail car transfer hose and the release of 25,000 pounds of material. The overpressure from ignition of the vapors would not reach off-site endpoints and nearby public and environmental receptors. The alternative release scenario for ammonia is the failure of a relief valve and the release of 700 pounds of material. The mitigating effects of a sprinkler system, an emergency shutdown system and our fire brigade response were included in the evaluation of the possible consequences. The release formed by the evaporating a mmonia could reach offsite endpoints and nearby public receptors. The alternative release scenario for chlorine is the failure of a one inch line at the chlorine vapor header and the release of 240 pounds of material. The mitigating effects of a vapor monitoring system and our fire brigade response were included in the evaluation of the possible consequences. The release formed by the evaporating chlorine would not reach off-site endpoints and nearby public and environmental receptors. The alternative release scenario for hydrocyanic acid is a pipe leak due to thermal expansion and the release of 200 pounds of material. The mitigating effects of a sprinkler system, an HCN monitoring system and our fire brigade response were included in the evaluation of the possible consequences. The release formed by the evaporating hydrocyanic acid could reach offsite endpoints and nearby public receptors. The alternative release scenario for acrylonitrile is the rupture of a one and one half inch pipe and the release of 4,000 pounds of material. The mitigating effects of a sprinkler system and our fire brigade response were included in the evaluation of the possible consequences. The release formed by the evaporating acrylonitrile could reach offsite endpoints and nearby public receptors. The alternative release scenario for oleum is a leak from a pipeline and the release of 240 pounds of material. The mitigating effects of a dike, sprinkler system, neutralization and our fire brigade response were included in the evaluation of the possible consequences. The release formed by the evaporating oleum would not reach off-site endpoints and nearby public and environmental receptors. (d) THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Cytec'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 CF R 1910.120 - Hazardous Waste Operations & Emergency Response - Other EPA, OSHA, DOT and State regulations - Generally recognized & accepted engineering codes and standards - Cytec Safety, Health, Environmental and Engineering standards The following engineering and administrative controls have been implemented in the Acrylonitrile Plant to prevent releases of covered chemicals: - Chemicals are stored in above ground tanks contained within concrete dikes. - All pipelines and vessels are built according to engineering standards using materials fit for the service. - Area monitors are used to detect releases of propylene and hydrocyanic acid, in order to prevent off-site release. - Scrubbers and flares are used to prevent release of toxics or flammables to the enviroment. - Sumps and concrete containment are used to prevent contamination of the ground. - Alarms and interlocks are used to prevent out-of-control conditions, which could lead to a release. - All operators have been train ed and are certified under our POTC training system. - Emergency response plans are written and in place to address the handling of releases and spills. The following engineering and administrative controls have been implemented in the Utilities Plant to prevent a release of chlorine: - The chlorine rail car is stored on it's own spur (rail), with a derail device installed to prevent entry of another car. - The car is grounded per D.O.T. regulations - The rail car is equipped with a double-lined carbon steel shell. - The tank car is visually inspected twice a day, at a minimum. - The perimeter of the loading station is monitored by 12 chlorine sensors, that are set to detect a release. Activation of the alarms causes the valves on the unloading line to automatically close. - The rail car is equipped with an excess flow valve. - All operators have been trained and are certified under our POTC training system. The following engineering and administrative controls have been impleme nted in the AMD Plant to prevent a release of acrylonitrile: - The material is stored in above ground tanks, which are located in a diked area. - The diked area flows to a sump that pumps to the effluent treatment system. - All tanks have level control and alarms. - The air space above the material in the storage tank is nitrogen purged. - All tanks vent to a seal pot. These vapors are sent to a recovery column and remaining vapors are burned in a flare. - All operators have been trained and are certified under our POTC training system. - All process equipment is inspected and maintained according to our mechanical integrity standards. The following engineering and administrative controls have been implemented in the Acid Plant to prevent a release of oleum: - Both oleum storage tanks are equipped with high and "high high" level alarms. The alarms annunciate on the control panel. - Both oleum tanks are located within concrete secondary containment. - Both oleum tanks are protected from overpressure and vacuum by a conservation vent. The relief device is routined every 24 months. - The oleum piping system is classified as a Class I system per our mechanical integrity program. This sytem is inspected every 5 years to insure it's integrity. - All operators have been trained and are certified under our POTC training system. The following engineering and administrative controls have been implemented in the Methanol Plant to prevent a release of flammable mixture: - Piping and equipment designs meet all national and international standards. - All process vent systems go to flare. - Welded pipe and equipment connections in synthesis gas loop replace flange connections. - Process shutdown interlocks are used to mitigate potential release. - Preventative maintenance programs are established on piping and pressure safety valves. - Flammable gas leak detection devices are installed over flammable gas compressors. - Operational procedures are used to manually check for the presence of flammable gas. - All operators have been trained and are certified under our POTC training system. The following engineering and administrative controls have been implemented in the Ammonia Plant to prevent releases of ammonia from the ammonia storage tank: - The ammonia is stored in an above ground tank contained within an earthen dike. - The ammonia storage tank area is visually monitored by certified operators every two hours. - A formal visual inspection of the ammonia storage tank is performed and documented monthly. - There are numerous pressure transmitters / indicators /alarms to warn of storage tank high pressure. - The tank is automatically vented to a flare in the event of high pressure. - There are numerous level transmitters / indicators / alarms to warn of high storage tank level. - There are administrative controls (maximum inventory) to prevent overfilling the ammonia storage tank. - There are two emergency shut-off valves at the base of the tank t o enable isolation in the event of a leak on an out-loading line. - All operators have been trained and are certified under our POTC training system. The following engineering and administrative controls have been implemented in the Melamine Plant to prevent a release of ammonia: - Gaseous leak detection - Pressure safety valves and rupture disks on all pressure rated vessels - Mechanical integrity inspection schedules on equipment - Vent flares - Alarms and controls - Emergency shutdown system - All operators have been trained and are certified under our POTC training system. - State of the art DCS monitoring & control system - Fugitive emissions monitoring system The following engineering and administrative controls have been implemented in the MMA Plant to prevent a release of hydrocyanic acid (HCN): - High level interlock on 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 t ank 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 or 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. (e) 5-YEAR ACCIDENT HISTORY The following incidents occurred at Fortier during the past five years: A release of 39 pounds of a 1.7% ammonia solution resulted in one on-site injury and complaints of off-site damage. A release of 89 pounds of acrylonitrile and 14 pounds of hydrocyanic acid from a pipeline resulted in on-site equipment damage and complaints of off-site damage. A spill of 1 pound of hydrocyanic acid resulted in one employee being treated for exposu re. No off-site impacts occurred. A release of 5,800 pounds of a flammable mixture containing methane from a pipeline caused on-site equipment damage. No off-site impacts occurred. A release of 1,120 pounds of ammonia from a process vessel caused on-site equipment damage and resulted in complaints from neighbors concerning odors and dust. (f) EMERGENCY RESPONSE PROGRAM Fortier's Emergency 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 well as call in additiona l 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. (g) PLANNED CHANGES TO IMPROVE SAFETY The Fortier Plant of Cytec Industries is constantly striving to upgrade its processes, control technology, employee training, and inspection, repair and maintenance of process equipment in order to improve safety. We are also executing an organized plan to ensure minimum possible negative impact from Y2K. |