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DAVISON CATALYSTS -- LAKE CHARLES

Parent Companies:
W. R. GRACE & CO. -- CONN.
EPA Facility ID:
100000031324
Other ID:
70663WRGRCDAVIS
Facility DUNS:
8080434
Parent Company DUNS:
1367846

Location:

Address:
1800 DAVISON ROAD
SULPHUR, LA 70665
County:
CALCASIEU
Lat / Long:
30.156, -93.339 (Get map)
Method:
Interpolation - Photo
Description:
Center of Facility
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
W. R. GRACE & CO. -- CONN.
Phone:
(337) 583-2611
Address:
P. O. BOX 3247
LAKE CHARLES, LA 70602 -3247
Foreign Address:

Person responsible for RMP implementation:

Name:
MARVIN V. PAGGEN
Title:
PLANT MANAGER

Emergency contact:

Name:
MARVIN V. PAGGEN
Title:
PLANT MANAGER
Phone:
(337) 583-2611
24-hour phone:
(337) 625-8382
Ext or PIN:

Other contacts:

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

Safety:

Local Emergency Planning Committee:
Calcasieu Parish LEPC
Full-Time Equivalent Employees:
340
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
0520-00001-V5
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Inspecting Agency:
Never had one
Using Predictive Filing:
No

Processes:

Unspecified process
RMP ID:
45728
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Inorganic Chemical Manufacturing (325188)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (conc 20% or greater)
7664-41-7
580,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Gary Whitaker
Address:
1800 Davison Road
Sulphur, LA 70665 -3247
Foreign Address:

Phone:
(337) 583-3510

Latest RMP Submission:

Date:
June 14, 2004
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
No
RMP ID:
31526

Deregistration:

Date:
Effective Date:
Reason:
Source no longer uses any regulated substance
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:
27.0
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:
Rural
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 Unspecified process)
CBI claimed:
No
Percent weight:
27.0
Physical state:
Liquid
Model used:
EPA's OCA Guidance Reference Tables or Equations
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

, All Other Basic Inorganic Chemical Manufacturing (325188)
Prevention Program ID:
26221
Safety Review Date
Oct. 10, 2002, since latest RMP submission
PHA Update Date
April 29, 2004, since latest RMP submission
PHA Techniques
  • What if
  • HAZOP
Hazards Identified
  • Toxic release
  • Corrosion
  • Overfilling
  • Equipment failure
  • Cooling loss
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
Mitigation Systems
  • Dikes
Monitoring Systems
  • None
Changes since PHA
  • None Recommended
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 30, 2004, since latest RMP submission
Training Review Date
April 12, 2004, since latest RMP submission
Maintenance Review Date
April 5, 2004, since latest RMP submission
Maintenance Inspection Date
April 2, 2001, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 16, 2004
Management of Change Review Date
May 18, 2004
Pre-startup Review Date
May 18, 2004
Compliance Audit Date
Oct. 10, 2002
Compliance Audit Change Completion Date
Nov. 10, 2002
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Oct. 10, 2002
Hot Work Review Date
Jan. 14, 2003
Contractor Safety Review Date
Aug. 13, 2003, since latest RMP submission
Contractor Safety Eval. Date
March 31, 2004, 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:
Feb. 12, 2004
Local Response Agency:
Local Response Agency Phone:
(337) 437-3500
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
W. R. GRACE & CO., LAKE CHARLES, LA

EPA FACILITY ID# 1000 0003 1324
17903 LDEQ FACILITY ID NUMBER

ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES

The W. R. Grace, Lake Charles facility has a long standing commitment to community and worker safety. This commitment is evidenced by the time and resources spent on training, safe design, operation and maintenance of all plant processes. The objective of this commitment is to prevent any release from ever happening.

DESCRIPTION OF STATIONARY SOURCE AND REGULATED SUBSTANCES

The W. R. Grace, Lake Charles facility is an inorganic chemical plant that manufactures synthetic fluid cracking and hydrotreating catalyst products. These product lines have evolved since the plant was built in 1953 to meet the needs of crude oil refining. The facility processes only one chemical (aqua ammonia-conc. 20% or greater) in quantities high enough to be regulated by the 112(r) rule. This chemical is used in the plant to wash catalysts and control NOx emissions. The maximum amount of aqua ammonia that can be stored on the plant site is 580,000 pounds.

FIVE YEAR ACCIDENT HISTORY

Over the past 5 years there have been no releases of aqua ammonia that have caused enough adverse consequences to meet the criteria for historical reporting.

GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS

Because the aqua ammonia process at the facility is regulated by the EPA RMP rule as a Program 3 process, the process is also subject to OSHA PSM. Thus, under both EPA and OSHA, the aqua ammonia process is subject to an accident prevention program. The following is a summary of the Program 3 elements contained in the general accident prevention program in place at the Lake Charles facility.

EMPLOYEE PARTICIPATION:

The W. R. Grace facility encourages employees to participate in all of the programs in the prevention program. Employee participation is evident in accident investigation, Process Hazard Analysis (PHA), training
programs, emergency response teams (ERT), operating procedure review, and process safety information. The VPP certification effort now in progress involves many employees that serve on key committees. This open participation for employees is documented in the facility accident prevention, or Process Safety Management (PSM), program.

PROCESS SAFETY INFORMATION:

The W. R. Grace facility creates and maintains documents related to maintaining a safe operation of the aqua ammonia process. These documents contain information that addresses chemical properties, chemical hazards, limits for key process parameters, tank inventories, equipment design basis, materials of construction, design pressure, and temerpature rating. Other information on aqua ammonia, including exposure hazards and emergency response guidelines, is found on the Material Safety Data Sheets. This information on aqua ammonia is maintained current to provide a basis for establishing inspections and maintenance activities, as well as being utilized during PHAs.

PROCESS HAZARD ANALYSIS (PHA):

The W. R. Grace facility has a comprehensive program for reviewing the aqua ammonia process. The program is a systematic examination of the process, which will identify hazards and ensure that adequate controls are in place to manage those hazards.

A team of individuals representing safety, environmental, operations, maintenance, and engineering are assembled to conduct the analysis. The team utilizes the "What If" and "HAZOP" techniques to evaluate the hazards and risks, and makes recommendations concerning specific findings. The findings from PHAs are assigned to team members for final resulution. The final resulution of each finding is documented and retained. A PHA is done on the ammonia system every 5 years, or whenever the system is significantly altered or changed.

OPERATING PROCEDURES:

The W. R. Grace facility maintains written procedures that address various modes of operation of the aqua ammon
ia process. These modes include normal startup; normal operation; temporary operation; emergency shutdown; normal shutdown; and initial startup of the process with new or modified equipment. These procedures are periodically reviewed and certified as current and accurate.

TRAINING:

All employees operating and maintaining the aqua ammonia process are trained on a regular basis about the operating proedures and other aspects of the process. New operators are classroom trained and then work with experienced operators to receive on-the-job training. After new operators have demonstrated the necessary skills to safely operate the process they are allowed to operate independently.

CONTRACTORS:

The W. R. Grace facility uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the facility has procedures in place to ensure that contractors receive training. This training is accomplished by providing contractors with a process overview; information about safety and health hazards; emergency response plan requirements; and safe work practices prior to their beginning work. In addition, the facility evaluates contactor safety programs and performance during the slection of a contractor. Facility personnel periodically monitor contractor performance to ensue that contractors are following the necessary procedures.

PRE-STARTUP SAFETY REVIEWS:

Any time there is a significant change to the aqua ammonia process itself, or the process safety information associated with the aqua ammonia process, a pre-startup safety review (PSSR) is conducted. This review will assure that the process and its personnel are prepared to start up. Items reviewed include confirmation that construction is in accordance with design; operating procedures are developed; PHAs completed; management of change followed; and training conducted. The final segment of the pre-startup rev
iew is a walk-through inspection of the process.

MECHANICAL INTEGRITY:

The W. R. Grace facility has practices and procedures to maintain the integrity of the aqua ammonia process equipment to minimize the potential for an ammonia release to the environment. The basic program includes maintenance training; written maintenance procedures; periodic inspections and tests of equipment; and correction of deficiencies found. Equipment found to be deficient must be repaired before placing the equipment back in service.

To achieve quality assurance in equipment maintenance for the aqua ammonia process a quality assurance program is incorporated into the purchase, repair, and warehousing of spare parts.

SAFE WORK PRACTICES--HOT WORK PERMIT:

W. R. Grace has incorporated many safe work practices in the daily execution of business. Examples include the lockout/tagout procedures, the confined space entry procedures, and the hot work permit procedures. The hot work permit is used to control welding, cutting, brazing, and burning work in the aqua ammonia process area. The hot work permit assures that a supervisor has checked the aqua ammonia process area for combustibles prior to hot work.

MANAGEMENT OF CHANGE:

The W. R. Grace facility has a management of change (MOC) procedure that applies to all processes, including the aqua ammonia process. The MOC procedure manages chemical, equipment, and procedural changes to the process to assure that any proposed change will not result in an undetected, unsafe condition. The proper level of authority assures the change is safe and that a review of the changes's effect on health, safety, and the environment is completed. Training of all affected presonnel is accomplished prior to the change occurring.

INCIDENT INVESTIGATION:

The W. R. Grace facility has policy and procedures in place that call for a prompt investigation of all underlying causes (root causes) that may have resulted in an aqua ammonia spill. The goal of each
investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident, or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to facility management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contarctors) who could be affected by the findings. Incident investigation reports are ratained for at least 5 years so that the reports can be reviewed during future PHAs.

COMPLIANCE AUDITS:

Compliance audits are performed on the aqua ammonia process risk management plan to determine how well the policies and procedures satisfy the requirements of the Risk Management Plan rule. The audits are conducted at least every three years. The audit findings are documented and forwarded to management for reivew. All corrective actions required are tracked until completion. Documentation of the audit procedures and the last two audits are maintained as part of the compliance audit program. An agency audit of the RMP/PSM management plan was conducted in 2001, with no findings or violations noted.

CHEMICAL SPECIFIC PREVENTION STEPS

The processes at the W. R. Grace facility have many hazards that must be managed to ensure continued safe operation. The prevention program summarized previously is applied to the aqua ammonia process. This prevention program helps prevent potential ammonia releases, which could be caused by equipment failure and human errors.

In addition to the prevention program, the W. R. Grace facility has safety features on the aqua ammonia process which help control the process and mitigate the consequences of a release.

Process Controls

1) Scrubber
2) Automatic shutoff valves
3)
Manual shutoff valves

Administrative Controls

1) Tank inventory
2) Computer control system

Release Minimization

1) Water dilution system
2) Emergency response teams
3) Dikes and sumps

EMERGENCY RESPONSE PROGRAM INFORMATION

The W. R. Grace facility maintains a written emergency response program for the purpose of protecting all workers, the public, and the environment should a chemical emergency occur. The program includes procedures for responding to spills of aqua ammonia liquid and releases of ammonia gas. The procedures include aspects of emergency response such a proper first aid, command structure, alarm system, evacuation plans, personnel accounting, notification of appropriate agencies, requests for assistance, and post incident activities. Plant personnnel are trained and drilled on the emergency program so they know their individual responsibilities during an emergency.

The overall emergency response program for W. R. Grace is coordinated with the Calcasieu Parish Local Emergency Planning Committee (LEPC), and the local hospital, police, and fire departments. In addition, W. R. Grace is a member of the following organizations: 1) Mutual Aid Association of Southwest Louisiana, which shares equipment and personnel for emergency response; 2) the Community Awareness Emergency Response Group (CAER), which assists in emergency training programs such as drills and has provided may of the emergency alerting systems in the area; and 3) the Lake Area Industry Alliance (LAIA), which communicates with area residents and businesses about mutual interests. This parish-wide emergency response system was successfully drilled in early 2004.

The W. R. Grace facility has emergency response team (ERT) members always on site, with 9 to 10 team members per shift. The teams train on a regular basis and training includes response to ammonia releases. The teams use equipment appropriate for ammonia emergencies, including respiratory equipment and full body pr
otective suits. The facililty is equipped with a unit and plant wide alarm system, an in-plant radio system with emrgency channels, and a radio system to other facilities.

In summary, W. R. Grace has a fully integrated emergency response program capable of responding to any emergency releases of ammonia.