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Equilon Enterprises LLC, - Norco, LA Refinery

Parent Companies:
Shell Oil Products US
EPA Facility ID:
100000026009
Other ID:
LAD008186579
Facility DUNS:
23383867
Parent Company DUNS:
0

Location:

Address:
15536 River Road
Norco, LA 70079
County:
ST. CHARLES
Lat / Long:
29.996, -90.410 (Get map)
Method:
Interpolation - Satellite
Description:
Plant Entrance (Personnel)
Horizonal accuracy:
1 m
Horizontal reference datum:
World Geodetic System of 1984
Source map scale:

Owner/Operator:

Name:
Equilon Enterprises LLC
Phone:
(504) 465-7911
Address:
15136 River Road
P.O. Box 10, River Road
Norco, LA 70079
Foreign Address:

Person responsible for RMP implementation:

Name:
Jody Licatino
Title:
PSM Manager

Emergency contact:

Name:
David Masson
Title:
Norco Site Supervisor
Phone:
(504) 465-7342
24-hour phone:
(504) 915-9325
Ext or PIN:

Other contacts:

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

Safety:

Local Emergency Planning Committee:
St. Charles Parish LEPC
Full-Time Equivalent Employees:
864
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
Multiple
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Nov. 30, 2016
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Alkylation
RMP ID:
1000080313
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Hydrochloric acid (conc 37% or greater)
7647-01-0
270,000
No
Propane
74-98-6
120,000
No
Propylene [1-Propene]
115-07-1
130,000
No
Butane
106-97-8
20,000
No
Isobutane [Propane, 2-methyl]
75-28-5
140,000
No
Flammable Mixture
00-11-11
73,000
No
Flammable Mixture
00-11-11
2,000,000
No
Flammable Mixture
00-11-11
81,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
HCU/Hydrogen Plant
RMP ID:
1000080314
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Hydrogen
1333-74-0
1,000,000
No
Butane
106-97-8
13,000
No
Propane
74-98-6
11,000
No
Isobutane [Propane, 2-methyl]
75-28-5
28,000
No
Hydrogen sulfide
7783-06-4
13,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
CR-2
RMP ID:
1000080315
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Hydrogen
1333-74-0
960,000
No
Methane
74-82-8
15,000
No
Butane
106-97-8
210,000
No
Propane
74-98-6
4,100,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Distillation
RMP ID:
1000080316
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Hydrogen
1333-74-0
60,000
No
Butane
106-97-8
3,000,000
No
Isobutane [Propane, 2-methyl]
75-28-5
500,000
No
Propane
74-98-6
500,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Logistics
RMP ID:
1000080317
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Butane
106-97-8
10,000,000
No
1-Pentene
109-67-1
15,000,000
No
Flammable Mixture
00-11-11
30,000,000
No
Propylene [1-Propene]
115-07-1
2,900,000
No
Ethyl mercaptan [Ethanethiol]
75-08-1
39,000
No
Flammable Mixture
00-11-11
150,000,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
NHT
RMP ID:
1000080318
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Hydrogen
1333-74-0
500,000
No
Public OCA Chemical
0
No
RCCU/RGHT
RMP ID:
1000080319
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Butene
25167-67-3
410,000
No
Propylene [1-Propene]
115-07-1
120,000
No
Butane
106-97-8
86,000
No
Isobutane [Propane, 2-methyl]
75-28-5
330,000
No
Propane
74-98-6
28,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
DHT/S-2
RMP ID:
1000080320
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Hydrogen sulfide
7783-06-4
320,000
No
Public OCA Chemical
0
No
S-3
RMP ID:
1000080321
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Hydrogen
1333-74-0
60,000
No
Hydrogen sulfide
7783-06-4
520,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Environmental Resources Management
Address:
775 North University Boulevard
Suite 280
Mobile, AL 36608
Foreign Address:

Phone:
(251) 706-8600

Latest RMP Submission:

Date:
July 7, 2017
Type:
Resubmission
Reason:
Newly regulated substance above TQ in already covered process (40 CFR 68.190(b)(3))
Registered:
Yes
RMP ID:
1000064017

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 S-3)
CBI claimed:
No
Percent weight:
1.0
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:
  • 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 Alkylation)
CBI claimed:
No
Percent weight:
37.0
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:
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in S-3)
CBI claimed:
No
Percent weight:
1.0
Physical state:
Gas
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:
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown

4. Flammables: 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 Logistics)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Blast walls
Public OCA Chemical (in Logistics)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Blast walls

5. Flammables: 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 Logistics)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Excess flow valve

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

Alkylation, Petroleum Refineries (32411)
Prevention Program ID:
1000067551
Safety Review Date
May 17, 2017, since latest RMP submission
PHA Update Date
May 31, 2017, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • None
Process Controls
  • None
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
April 3, 2017, since latest RMP submission
Training Review Date
June 1, 2013, since latest RMP submission
Maintenance Review Date
March 1, 2017, since latest RMP submission
Maintenance Inspection Date
Dec. 1, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 7, 2017
Management of Change Review Date
Dec. 1, 2016
Pre-startup Review Date
Dec. 8, 2014
Compliance Audit Date
July 15, 2015
Compliance Audit Change Completion Date
None
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
July 1, 2015
Hot Work Review Date
Dec. 1, 2016
Contractor Safety Review Date
June 1, 2015, since latest RMP submission
Contractor Safety Eval. Date
March 1, 2016, since latest RMP submission
HCU/Hydrogen Plant, Petroleum Refineries (32411)
Prevention Program ID:
1000067552
Safety Review Date
July 1, 2014, since latest RMP submission
PHA Update Date
April 1, 2016, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • None
Process Controls
  • None
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
April 3, 2017, since latest RMP submission
Training Review Date
April 3, 2017, since latest RMP submission
Maintenance Review Date
March 1, 2017, since latest RMP submission
Maintenance Inspection Date
Dec. 1, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 18, 2017
Management of Change Review Date
Dec. 1, 2016
Pre-startup Review Date
April 20, 2017
Compliance Audit Date
July 15, 2015
Compliance Audit Change Completion Date
March 1, 2016
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
July 1, 2015
Hot Work Review Date
Dec. 1, 2016
Contractor Safety Review Date
June 1, 2015, since latest RMP submission
Contractor Safety Eval. Date
March 1, 2016, since latest RMP submission
CR-2, Petroleum Refineries (32411)
Prevention Program ID:
1000067553
Safety Review Date
Oct. 3, 2016, since latest RMP submission
PHA Update Date
Oct. 3, 2016, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
April 3, 2017, since latest RMP submission
Training Review Date
Dec. 12, 2016, since latest RMP submission
Maintenance Review Date
March 1, 2017, since latest RMP submission
Maintenance Inspection Date
Dec. 1, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
March 23, 2017
Management of Change Review Date
Dec. 1, 2016
Pre-startup Review Date
Oct. 16, 2016
Compliance Audit Date
July 15, 2015
Compliance Audit Change Completion Date
March 1, 2016
Incident Investigation Date
Feb. 1, 2010
Incident Invest. Change Completion Date
Oct. 1, 2011
Participation Plan Review Date
July 1, 2015
Hot Work Review Date
Dec. 1, 2016
Contractor Safety Review Date
June 1, 2015, since latest RMP submission
Contractor Safety Eval. Date
March 1, 2016, since latest RMP submission
Distillation, Petroleum Refineries (32411)
Prevention Program ID:
1000067554
Safety Review Date
May 1, 2015, since latest RMP submission
PHA Update Date
May 1, 2015, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • None
Process Controls
  • None
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
April 3, 2017, since latest RMP submission
Training Review Date
Feb. 13, 2017, since latest RMP submission
Maintenance Review Date
March 1, 2017, since latest RMP submission
Maintenance Inspection Date
Dec. 1, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 12, 2017
Management of Change Review Date
Dec. 1, 2016
Pre-startup Review Date
Feb. 10, 2014
Compliance Audit Date
July 15, 2015
Compliance Audit Change Completion Date
March 1, 2016
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
July 1, 2015
Hot Work Review Date
Dec. 1, 2016
Contractor Safety Review Date
June 1, 2015, since latest RMP submission
Contractor Safety Eval. Date
March 1, 2016, since latest RMP submission
Logistics, Petroleum Refineries (32411)
Prevention Program ID:
1000067555
Safety Review Date
Oct. 1, 2015, since latest RMP submission
PHA Update Date
Oct. 1, 2015, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • None
Process Controls
  • None
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
Procedure Review Date
April 3, 2017, since latest RMP submission
Training Review Date
June 1, 2017, since latest RMP submission
Maintenance Review Date
March 1, 2017, since latest RMP submission
Maintenance Inspection Date
Dec. 1, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 18, 2017
Management of Change Review Date
Dec. 1, 2016
Pre-startup Review Date
Jan. 25, 2017
Compliance Audit Date
July 15, 2015
Compliance Audit Change Completion Date
March 1, 2016
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
July 1, 2015
Hot Work Review Date
Dec. 1, 2016
Contractor Safety Review Date
June 1, 2015, since latest RMP submission
Contractor Safety Eval. Date
June 1, 2015, since latest RMP submission
NHT, Petroleum Refineries (32411)
Prevention Program ID:
1000067556
Safety Review Date
July 1, 2015, since latest RMP submission
PHA Update Date
July 1, 2015, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • None
Process Controls
  • None
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
April 3, 2017, since latest RMP submission
Training Review Date
Dec. 9, 2015, since latest RMP submission
Maintenance Review Date
March 1, 2017, since latest RMP submission
Maintenance Inspection Date
Dec. 1, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 5, 2017
Management of Change Review Date
Dec. 1, 2016
Pre-startup Review Date
Feb. 25, 2016
Compliance Audit Date
July 15, 2015
Compliance Audit Change Completion Date
March 1, 2016
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
July 1, 2015
Hot Work Review Date
Dec. 1, 2016
Contractor Safety Review Date
June 1, 2015, since latest RMP submission
Contractor Safety Eval. Date
March 1, 2016, since latest RMP submission
RCCU/RGHT, Petroleum Refineries (32411)
Prevention Program ID:
1000067557
Safety Review Date
Jan. 2, 2017, since latest RMP submission
PHA Update Date
Jan. 2, 2017, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • None
Process Controls
  • None
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
Procedure Review Date
April 3, 2017, since latest RMP submission
Training Review Date
June 1, 2016, since latest RMP submission
Maintenance Review Date
March 1, 2017, since latest RMP submission
Maintenance Inspection Date
Dec. 1, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 18, 2017
Management of Change Review Date
Dec. 1, 2016
Pre-startup Review Date
May 16, 2014
Compliance Audit Date
July 15, 2015
Compliance Audit Change Completion Date
March 1, 2016
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
July 1, 2015
Hot Work Review Date
Dec. 1, 2016
Contractor Safety Review Date
June 1, 2015, since latest RMP submission
Contractor Safety Eval. Date
March 1, 2016, since latest RMP submission
DHT/S-2, Petroleum Refineries (32411)
Prevention Program ID:
1000067558
Safety Review Date
Dec. 1, 2016, since latest RMP submission
PHA Update Date
Dec. 1, 2016, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • None
Process Controls
  • None
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
April 3, 2017, since latest RMP submission
Training Review Date
Nov. 13, 2016, since latest RMP submission
Maintenance Review Date
March 1, 2017, since latest RMP submission
Maintenance Inspection Date
Dec. 1, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
March 30, 2017
Management of Change Review Date
Dec. 1, 2016
Pre-startup Review Date
Feb. 11, 2015
Compliance Audit Date
July 15, 2015
Compliance Audit Change Completion Date
March 1, 2016
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
July 1, 2015
Hot Work Review Date
Dec. 1, 2016
Contractor Safety Review Date
June 1, 2015, since latest RMP submission
Contractor Safety Eval. Date
March 1, 2016, since latest RMP submission
S-3, Petroleum Refineries (32411)
Prevention Program ID:
1000067559
Safety Review Date
March 1, 2017, since latest RMP submission
PHA Update Date
March 1, 2017, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • None
Process Controls
  • None
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
April 3, 2017, since latest RMP submission
Training Review Date
July 16, 2016, since latest RMP submission
Maintenance Review Date
March 1, 2017, since latest RMP submission
Maintenance Inspection Date
Dec. 1, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 21, 2017
Management of Change Review Date
Dec. 1, 2016
Pre-startup Review Date
April 27, 2017
Compliance Audit Date
July 15, 2015
Compliance Audit Change Completion Date
March 1, 2016
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
July 1, 2015
Hot Work Review Date
Dec. 1, 2016
Contractor Safety Review Date
June 1, 2015, since latest RMP submission
Contractor Safety Eval. Date
March 1, 2016, 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 2, 2017
Local Response Agency:
Local Response Agency Phone:
(504) 783-5050
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

Equilon Enterprises LLC, dba Shell Oil Products US

Norco, Louisiana Refinery

Risk Management Plan (RMP) - Executive Summary



Equilon Enterprises LLC, dba Shell Oil Products US ("Equilon") operates an oil refinery in Norco, Louisiana. The following is a list of RMP toxic and flammable substances stored at Equilon in quantities and concentrations above applicable thresholds:



Flammables:

- Butene;

- Propane;

- Propylene;

- Butane;

- Isobutane;

- Methane;

- Hydrogen;

- 1,3 Butadiene;

- Ethyl Mercaptan;

- 1-Pentene;



Toxics:

- Hydrochloric Acid;

- Hydrogen Sulfide.



This summary provides an overview of various RMP activities at Equilon, including the following:



- A list of RMP regulated substances;

- A summary of potential RMP release scenarios and potential off-site consequences;

- A five-year history of RMP accidental releases of chemicals regulated by EPA's RMP rule;

- An overview of emergency response; and

- An overview of the RMP Accident Prevention Program.



HSSE MANAGEMENT SYSTEM AND THE RMP PREVENTION PROGRAM



Equilon maintains a Health, Safety, Security, and Environmental (HSSE) management system and associated policies, procedures, standing instructions, programs and work practices that are related to the RMP Prevention Program's elements.



These policies, procedures, standing instructions, programs and work practices are measures that are designed to help the site identify planned changes, which vary at any given time, that are designed to further enhance the site's existing safety programs and procedures. The following is a summary of some of these measures:



Employee Participation



The site has an employee participation plan that outlines the various ways that employees can participate, including, for example, the site health and safety committee, Process Hazards Analysis (PHA), incident investigation, and management of change activities.



Process Hazards Analysis



Process Hazards Analysis (PHA) is conducted for a
variety of the plant's process units. Typically, the hazard and operability (HAZOP) PHA methodology is used to conduct process unit PHAs. PHA team members include operations, maintenance, and engineering personnel who are familiar with the process being reviewed. PHA team recommendations are required to be tracked on a quarterly basis until resolved. PHAs for covered process units are required to be revalidated every 5 years. Process safety information is available to the PHA team for their use.



Operating Procedures



Operating procedures address various operating phases, such as the following: (1) initial startup, (2) normal operations, (3) temporary operations, (4) emergency shutdowns, (5) emergency operations, (6) normal shutdown, and (7) startup following a turnaround or after an emergency shutdown. Operating procedures are available to all employees who work in or maintain a process, and the operating procedures are required to be reviewed and certified annually as current and accurate.



Operator Training



The operator training program requires operators to complete operator training, including refresher training every three years. New operating employees receive classroom training on basic operating principles and the operating procedures of their assigned process unit. The operator training includes information related to unit specific safety and health hazards, and emergency operating conditions, including shutdown. Operators must complete written and oral tests, as well as field demonstration of skills as part of the qualification training. Operator training is required to be documented.



Contractors



The contractor safety program includes a contractor selection process and a contract coordinator. The contractor selection process is based on a variety of data, such as contractor provided contractor safety programs and contractor performance information. Contractor safety performance is also part of the weekly safety statistics.



Pre-Startup S
afety Review (PSSR)



A PSSR procedure is in place and requires a PSSR be conducted for any new facility or facility modification that requires a change in process safety information. In addition, major projects and maintenance turnarounds require a PSSR to be completed.



Mechanical Integrity



Mechanical integrity procedures and practices related to maintaining the integrity of pressure vessels, storage tanks, piping systems, relief and vent systems, process controls, pumps, and critical instrument systems are in place. The mechanical integrity program includes, for example, ongoing inspection and testing (and resolution of inspection results, as applicable) of various types of process equipment. Also, quality assurance practices are used, as applicable, to verify their suitability for the process application for which they will be used.



Safe Work Practices and Work Permits



A variety of safe work practices are in place that apply to employees and contractors, as applicable. Examples include, but are not limited to, the following: (1) control of entry into a stationary source site by maintenance, contractor, laboratory or other support personnel; (2) equipment lockout/tagout; (3) opening process equipment or piping; (4) the issuance of hot work permits; and (5) the issuance of entry permits for entry into confined spaces, as applicable.



Management of Change



The management of change procedure is designed to manage various types of changes to process chemicals, process technology, equipment, and procedures and changes to stationary sources that affect a covered process. The procedure is designed to confirm review of the technical basis of the proposed change, the impact of the change on process related safety and health, modifications to operating procedures, the necessary time period for the change, and authorization requirements for the proposed change. The procedure includes a step for informing and training employees involved in operating the proce
ss and maintenance and contractor employees whose job tasks will be affected by a change in the process.



Incident Investigation



Incident investigation procedures are in place for the investigation of RMP incidents that resulted in, or could have reasonably resulted in an RMP incident involving fire, explosion, significant toxic gas release, major property damage, environmental loss, or personal injury affecting site personnel or the community. The investigation team's recommendations are required to be tracked to resolution and documented. The RMP incident investigation results are required to be reviewed with all affected personnel whose job tasks are relevant to the incident findings including contract employees where applicable.



RMP Compliance Audit



An RMP Compliance audit is required to be conducted every three years, with the RMP Compliance audit team's findings developed in a report. The RMP compliance audit report is required to be reviewed to promptly determine and document resolution of the audit team's findings. The two most recent RMP compliance audit reports are required to be retained.



RMP FIVE YEAR ACCIDENT HISTORY



No reportable accidents, as defined in 40 CFR Part 68.42, involving an RMP regulated substance have occurred at the Equilon - Norco facility within the past five (5) years.



EMERGENCY RESPONSE



Emergency response is coordinated by the site with the St. Charles Parish Department of Emergency Preparedness (DEP), and the St. Charles Parish Local Emergency Planning Committee (LEPC). This coordination includes periodic committee meetings with or communications to local emergency response officials, local government officials, community members, and industry representatives. Trained and equipped site firefighting, HAZMAT, and medical/rescue teams are available. There is a 24 hour communications capability with DEP officials, as well as area emergency response organizations (i.e. local fire departments, Sheriff's department,
State Police, etc.) In addition to established lines of communication with area emergency response organizations, the site is also a member of the St. Charles Parish Industrial Mutual Aid Association. Periodic emergency drills are held with the LEPC, DEP, Mutual Aid Organization members, and local emergency response organizations. Refresher information that is related to the RMP regulated substances is also made available to local emergency response organizations.



The DEP is responsible for maintaining written plans for the preparedness, mitigation, response and recovery of any natural or technological disaster that may occur in St. Charles Parish. This responsibility includes coordination with neighboring parishes that may be affected by an emergency incident within St. Charles Parish. The DEP is also responsible for coordinating the plans and operations of various emergency response agencies in St. Charles Parish such as fire, police, emergency medical services, public works, volunteers, and other groups that respond to emergencies.



The written emergency response plan covers topics such as responding to a potential release, fire, explosion, or chemical release. Procedures and practices related to the maintenance, inspection, testing, and use of emergency response equipment are also in place. Employees receive training in these procedures as necessary to perform their specific response duties.



Site-Specific Prevention Steps



Types of RMP site specific prevention steps include the following:



Release detection

- Various process alarms

- Operator surveillance

- Portable hydrocarbon monitoring equipment;



Release containment and control

- Various relief systems

- Dikes to contain liquid releases

- Redundant equipment (i.e. back-up firewater pump)

- Control valves to allow isolation of the process;



Release Mitigation

- Area firewater monitors

- Mobile emergency response equipment

- Trained emergency response personnel.



OFF-SITE CONSEQUEN
CE ANALYSIS (OCA)

An off-site consequence analysis (OCA) was performed on the potential worst-case scenario (WCS) and alternative release scenario (ARS) involving toxic and flammable substances at Equilon. The WCS is considered to be unrealistic because it does not reflect actual operating conditions, nor allow credit for existing mitigation measures that have been identified. Based on the review conducted when preparing this executive summary, the ARS is considered a more realistic scenario and takes into account actual operating conditions.



The following are summaries of the toxic and flammable WCS and ARS modeling at Equilon. All OCA release modeling was performed using the U.S. Environmental Protection Agency's (USEPA) RMP*Comp Version 2.01 off-site consequence analysis program. Population estimates, public receptors and environmental receptors were analyzed using the USEPA's and NOAA's MARPLOT Mapping Software, version 5.0.3. MARPLOT currently uses 2010 U.S. census data.



Although the RMP rule does not allow credit for the consideration of mitigation measures in WCS modeling, various prevention measures that are in place should reduce the likelihood of the WCS and its impacts should it occur. These measures include, but are not limited to, the following:



- Mechanical integrity inspection and preventive maintenance programs;

- Routine surveillance by trained operators;

- Various audible and visual alarm and notification systems;

- Responder call-out, incident command establishment and staging, and agency notification, as necessary.



1. Toxic Worst- Case Release Scenario - Hydrogen Sulfide



The two RMP-regulated toxic chemicals located at the facility stored both in quantities and concentrations greater than their respective threshold quantities are hydrogen sulfide and hydrochloric acid. It was determined through OCA modeling of the catastrophic rupture of the process or vessel storing the largest quantity of each of these chemicals that a hydrog
en sulfide release would have the largest impact and thus is considered the worst-case release scenario.



The "process" containing the largest volume of hydrogen sulfide is the K-478 sour water storage tank where approximately 650,000 gallons of sour water containing hydrogen sulfide in concentrations of 1% by weight are possible. An estimated maximum storage quantity of 59,631 lbs. of hydrogen sulfide can be present at this concentration in the K-478 storage tank. The catastrophic failure of the tank results in a toxic endpoint distance of 13.0 miles (20.9 kilometers).



MARPLOT was utilized to estimate the population impacted by this accidental release. This worst-case scenario has the potential to impact an estimated population of 250,273 people (102,689 residences). Multiple schools including Norco Elementary, Sacred Heart of Jesus, and Bethune High School could be impacted by this scenario. Bayou Trepagnier, which is a designated scenic stream and is located adjacent to the northern fence line at the storage and treatment area, could also be affected by this release scenario. Lake Pontchartrain and Lac Des Allemonds could also be impacted by this release along with western portions of the Cities of New Orleans and Metairie, Louisiana, which are heavily populated metropolitan areas with multiples schools and other sensitive receptors potentially impacted.



2. Toxic Alternative Release Scenario #1 - Hydrochloric Acid (concentration 37% or greater)



The hydrochloric acid toxic alternative release scenario chosen occurs at the hydrochloric acid storage tank (L-432), which has a release as a result of a 3" transfer hose line leak during vessel charging. A calculated amount of 28,900 pounds of hydrochloric acid (37% concentration) will be released in approximately 10 minutes before mitigation of the leak can occur. This scenario was selected due to a history of similar releases that have occurred during similar tank transfer operations and because of the locat
ion of the vessel with respect to offsite receptors. This release scenario (hydrochloric acid toxic alternative case scenario) results in a toxic endpoint distance of 0.8 miles (1.3 kilometers).



According to the MARPLOT software, this alternative release scenario has the potential to impact 1,845 people (803 residences). Bethune High School could be impacted by this release but the other schools in the area should be just outside of the impacted radius (endpoint distance).



3. Toxic Alternative Release Scenario #2 - Hydrogen Sulfide

An alternative release scenario for hydrogen sulfide is the overfilling of the K-478 storage vessel spilling approximately 100,000 gallons of sour water over a conservatively estimated 10-minute time period. Multiple prevention measures are in place to mitigate or prevent this release from occurring and the actual pumping rate in the event of a release would be significantly lower than the modeled scenario. The overfilling (hydrogen sulfide toxic alternative-case scenario) results in a toxic endpoint distance of 1.9 miles (3.1 kilometers).



MARPLOT was utilized to estimate the population impacted by this accidental release of hydrogen sulfide. This alternative scenario has the potential to impact an estimated population of 5,294 people (2,209 residences). Multiple schools including Norco Elementary, Sacred Heart of Jesus, and Bethune High School could be impacted by this scenario. Bayou Trepagnier, which is a designated scenic stream and is located adjacent to the northern fence line at the storage and treatment area, could also be affected by this release scenario.



4. Flammable Worst-Case Release Scenario



Multiple flammable substances and NFPA No. 4 flammable mixtures are stored and processed at the facility and determining the flammable worst-case release scenario is not a straightforward analysis. It was determined that two worst-case scenarios are appropriate for the facility due to the potential of a release from each
storage vessel to potentially impact different population receptors. Each worst-case release scenario is expected to involve the release of a flammable mixture (PY Gas Blend) that contains over 1%, by weight, of a regulated flammable substance (isoprene). The two tanks that store the PY Gas Blend and used for OCA modeling at the facility are tanks F-491 and F-502. Tank F-491 stores approximately 48,580,242 pounds of PY Gas Blend. Tank F-502 stores approximately 71,072,895 pounds of PY Gas Blend. For modeling purposes, the flammable mixtures assumed to be released during each worst-case release scenario were conservatively assumed to contain 100% isoprene.



Tank F-502 Worst-Case Release Scenario



The F-502 worst-case release scenario was conservatively assumed to involve the release and subsequent ignition of approximately 71,072,895 pounds of PY Gas Blend (assumed 100% isoprene) in a vapor cloud explosion due to a catastrophic failure of F-502. The endpoint distance calculated as a result of this release and subsequent vapor cloud explosion is 3.3 miles (5.3 kilometers),



The F-502 worst-case release scenario has the potential to impact 10,438 people (4,056 residences). Multiple schools, including Norco Elementary, Ethel Schoeffner Elementary, Sacred Heart of Jesus, and Bethune High School; and Bayou Trepagnier (is a designated scenic stream located adjacent to the northern fence line at the storage and treatment area).





Tank F-491 Worst-Case Release Scenario



The F-491 worst-case release scenario was conservatively assumed to involve the release and subsequent ignition of approximately 48,580,242 pounds of PY Gas Blend (assumed 100% isoprene) in a vapor cloud explosion due to a catastrophic failure of F-491. The endpoint distance calculated as a result of this release and subsequent vapor cloud explosion is 2.9 miles (4.7 kilometers). The F-491 worst-case release scenario has the potential to impact 11,822 people (4,705 residences). Multiple sc
hools, including Norco Elementary, Sacred Heart of Jesus, and Bethune High School; and Bayou Trepagnier, a designated scenic stream located adjacent to the northern fence line at the storage and treatment area, are located within the potential impact area.



5. Flammable Alternative Release Scenario - Propylene



The flammable alternative scenario selected results in an estimated 229,000 pounds of propylene being released over a 25-minute period at the PV-503 propylene storage vessel due to a failure in an 8" feed line flange that could result in a 2" leak opening in the flange. This scenario was selected due to the volume of propylene stored, the pressure at which it is stored, and the location of the storage vessels at the refinery with respect to offsite receptors. The endpoint distance calculated as a result of this release and subsequent vapor cloud explosion is 0.3 miles (0.5 kilometers).



The MARPLOT population estimate indicates this scenario has the potential to impact an estimated population of 159 people (81 residences). No schools or hospitals should be affected by this release.