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Norco Chemical Plant - West Site

Parent Companies:
Shell Chemical LP
EPA Facility ID:
100000088157
Other ID:
LAR000042226
Facility DUNS:
18149687
Parent Company DUNS:
0

Location:

Address:
16122 River Road
Norco, LA 70079
County:
ST. CHARLES
Lat / Long:
29.999, -90.423 (Get map)
Method:
GPS Code Measurements (Psuedo Range) Precise Positioning Service
Description:
Plant Entrance (General)
Horizonal accuracy:
003 m
Horizontal reference datum:
World Geodetic System of 1984
Source map scale:

Owner/Operator:

Name:
Shell Chemical LP
Phone:
(504) 465-7222
Address:
P.O. Box 10
Norco, LA 70079 -0010
Foreign Address:

Person responsible for RMP implementation:

Name:
Raymond Woodfork
Title:
Health and Safety Manager

Emergency contact:

Name:
Brian Allen
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:
(504) 465-6837
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
St. Charles Parish LEPC
Full-Time Equivalent Employees:
139
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
2889-V
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Dec. 10, 2008
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Butylene Storage
RMP ID:
1000041887
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Butene
25167-67-3
11,692,800
No
Public OCA Chemical
0
No

RMP Preparer:

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

Phone:
(251) 706-8600

Latest RMP Submission:

Date:
Jan. 6, 2014
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000034278

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

None

3. Toxics: Alternative release

None

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 Butylene Storage)
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 Butylene Storage)
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

Butylene Storage, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000036478
Safety Review Date
Sept. 20, 2013, since latest RMP submission
PHA Update Date
Sept. 20, 2013, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Equipment failure
  • Cooling loss
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
Mitigation Systems
  • Deluge System
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Process Controls
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
April 1, 2013, since latest RMP submission
Training Review Date
June 1, 2013, since latest RMP submission
Maintenance Review Date
April 1, 2013, since latest RMP submission
Maintenance Inspection Date
Dec. 2, 2013, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Nov. 14, 2012
Management of Change Review Date
March 1, 2013
Pre-startup Review Date
Sept. 1, 2012
Compliance Audit Date
Aug. 1, 2012
Compliance Audit Change Completion Date
April 1, 2013
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
April 1, 2010
Hot Work Review Date
Oct. 1, 2011
Contractor Safety Review Date
June 1, 2012, since latest RMP submission
Contractor Safety Eval. Date
March 1, 2013, 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:
Dec. 1, 2013
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

Shell Chemical LP

Norco Chemical Plant - West Site

Risk Management Plan (RMP) - Executive Summary



Shell Chemical LP's Norco Chemical Plant (or NCP), West Site is located in Norco, LA. Butylene (butene) is the only RMP listed substance that is stored at the NCP - West Site in quantities above the RMP threshold quantity.



This document provides an overview of various RMP activities at NCP, 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



The Norco Chemical Plant (NCP) - West Site 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. For a detailed description of the RMP Prevention Program, refer to Section 7 of the Risk Management Plan submission.



RMP FIVE YEAR ACCIDENT HISTORY



No accidental releases of RMP covered substances held above their threshold quantity in a covered process that resulted in death, injuries, or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage were identified for the NCP - West Site for the last five years (40 CFR 68.12 and 68.42).



EMERGENCY RESPONSE



Emergency response is coordinated by the site with the St. Charles Parish Department o
f 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-Spe
cific 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 CONSEQUENCE ANALYSIS (OCA)



An off-site consequence analysis (OCA) was performed on the potential worst-case scenario (WCS) and alternative release scenario (ARS) involving flammable substances at the West Site. There are no toxic substances stored in quantities above the RMP thresholds listed in 40 CFR Part 68 , thus toxic WCS and ARS modeling is not required. The flammable 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 flammable ARS is considered a more realistic scenario and takes into account actual operating conditions.



The following are summaries of the flammable WCS and ARS modeling at NCP - West Site. All OCA release modeling was performed using the U.S. Environmental Protection Agency's (USEPA) RMP*Comp Version 1.07 off-site consequence analysis program. Population estimates, public receptors, and environmental receptors were analyzed using the U.S. Department of Commerce, Economics and Statistics Administration, BUREAU OF THE CENSUS LandView® VI Environmental Mapping Software (2003).



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 occ
ur. 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. Flammable Worst-Case Release Scenario - Butylene



The WCS for a flammable release assumes the catastrophic failure, instantaneous release, and vapor cloud explosion of 11,692,800 lbs of butylene. The butylene is actually held in two storage vessels that are in close enough proximity to be considered co-located. The WCS assumes that if one of the storage vessels catastrophically fails then it is likely that the structural integrity of the other sphere will also be compromised. The release calculation assumes urban topography due to structural and natural obstacles between the sphere and off-site receptors. No passive mitigation (i.e. containment) credit was applied to the release calculation. The maximum impact distance to a 1 PSI endpoint was calculated at 1.8 miles (2.9 kilometers). A population estimate of 3,588 people off-site, including residential, recreational, religious, school and commercial receptors could be potentially affected by the release. Bayou Trepagnier, a designated scenic stream adjacent to the northern side of the facility, may also be impacted.



2. Flammable Alternative Release Scenario - Butylene



The ARS for this facility assumes a one-half inch leak in an elbow in the 14 inch line to the feed pumps between one of the two butylene storage spheres and the first isolation valve. A release of butylene and a subsequent vapor cloud explosion occurs as a result of this equipment malfunction. Although the mixture is liquefied under pressure in this line, modeling was conducted based on a gas release because it produced a longer distance to endpoint and was a more conservative
approach. The release calculation assumes urban topography due to structural and natural obstacles between the sphere and off-site receptors. No passive mitigation (i.e. containment) credit was applied to the release calculation. The maximum impact distance to a 1 PSI endpoint was calculated at 0.3 miles (0.4 kilometers). A population estimate of 169 people off-site could be potentially affected by the release. Two schools were identified to be potentially impacted and Bayou Trepagnier could also be affected.