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Norco Chemical Plant - East Site

Parent Companies:
Shell Chemical LP
EPA Facility ID:
100000088282
Other ID:
LAR000011635
Facility DUNS:
18149687
Parent Company DUNS:
0

Location:

Address:
15136 River Road
Norco, LA 70079
County:
ST. CHARLES
Lat / Long:
29.996, -90.410 (Get map)
Method:
Interpolation - Satellite
Description:
Plant Entrance (General)
Horizonal accuracy:
1 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:
565
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
2520-V, 3047-V
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

BD-5 & GHT
RMP ID:
1000045604
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Acetylene [Ethyne]
74-86-2
240,000
No
Hydrogen
1333-74-0
10,000
No
Butene
25167-67-3
161,800
No
1,3-Butadiene
106-99-0
228,000
No
Flammable Mixture
00-11-11
1,000,000
No
Flammable Mixture
00-11-11
10,000
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
OL-5
RMP ID:
1000045605
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ethane
74-84-0
1,800,000
No
Flammable Mixture
00-11-11
8,000,000
No
Ethylene [Ethene]
74-85-1
5,325,000
No
1,3-Butadiene
106-99-0
2,880,000
No
Hydrogen
1333-74-0
10,000
No
Propylene [1-Propene]
115-07-1
1,156,000
No
Flammable Mixture
00-11-11
2,880,000
No
Methane
74-82-8
10,600
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
GO-1
RMP ID:
1000045606
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Methane
74-82-8
44,615
No
Propane
74-98-6
151,009
No
Propylene [1-Propene]
115-07-1
304,533
No
Ethane
74-84-0
199,372
No
Ethylene [Ethene]
74-85-1
152,311
No
Flammable Mixture
00-11-11
23,000
No
Flammable Mixture
00-11-11
2,880,000
No
Flammable Mixture
00-11-11
1,800,000
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
UTL-EAST
RMP ID:
1000045607
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Refineries (32411)
Chemical name
CAS#
Quantity (lbs.)
CBI
Cyclohexylamine [Cyclohexanamine]
108-91-8
35,000
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:
1000037236

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 UTL-EAST)
CBI claimed:
No
Percent weight:
50.0
Physical state:
Liquid
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 UTL-EAST)
CBI claimed:
No
Percent weight:
50.0
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:
  • 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

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 OL-5)
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 GO-1)
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

BD-5 & GHT, Petroleum Refineries (32411)
Prevention Program ID:
1000039756
Safety Review Date
Aug. 1, 2013, since latest RMP submission
PHA Update Date
Aug. 1, 2009, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • 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
  • Inhibitor Addition
  • Rupture Disks
Mitigation Systems
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • None
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. 31, 2013, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 1, 2013
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
Feb. 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
OL-5, Petroleum Refineries (32411)
Prevention Program ID:
1000039757
Safety Review Date
Oct. 1, 2013, since latest RMP submission
PHA Update Date
Nov. 1, 2010, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • Toxic release
  • 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
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • None
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. 31, 2013, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Sept. 1, 2013
Management of Change Review Date
March 1, 2013
Pre-startup Review Date
June 1, 2013
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
Feb. 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
GO-1, Petroleum Refineries (32411)
Prevention Program ID:
1000039758
Safety Review Date
Oct. 1, 2013, since latest RMP submission
PHA Update Date
Aug. 1, 2013, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Runaway reaction
  • Corrosion
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
July 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. 31, 2013, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Oct. 1, 2013
Management of Change Review Date
March 1, 2013
Pre-startup Review Date
Oct. 1, 2013
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
Feb. 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
UTL-EAST, Petroleum Refineries (32411)
Prevention Program ID:
1000039759
Safety Review Date
July 1, 2013, since latest RMP submission
PHA Update Date
Jan. 1, 2012, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • Toxic release
Process Controls
  • Vents
  • Check Valves
  • Flares
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • Reduced Inventory
Training Type
  • Classrom
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
Procedure Review Date
May 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. 31, 2013, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Feb. 1, 2013
Management of Change Review Date
March 1, 2013
Pre-startup Review Date
None
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
Feb. 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:
Nov. 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 - East Site

Risk Management Plan (RMP) - Executive Summary



Shell Chemical LP's Norco Chemical Plant (or NCP), East Site is located in Norco, LA. The following is a list of RMP toxic and flammable substances stored at the NCP - East Site:



Flammables:

- Acetylene;

- Hydrogen;

- Butene;

- 1,3 Butadiene;

- Ethane;

- Ethylene;

- Propylene;

- Propane;

- Multiple Flammable Mixtures;



Toxics:

- Cyclohexylamine.



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) - East 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 - East Site for the la
st five years (40 CFR 68.12 and 68.42).



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 re
sponse 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 CONSEQUENCE 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 the East Site. 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 NCP - East 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 occu
r. 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 - Cyclohexylamine



The only regulated toxic substance located at the facility stored both in quantities and concentrations greater than the respective threshold quantity is cyclohexylamine, which is contained in the BW-8192 boiler water treatment mixture at the Utilities - East storage area. An estimated maximum of 70,000 pounds of BW-8192 is in various containers within the area of which 50% by weight is cyclohexylamine, resulting in a total of 35,000 pounds of cyclohexylamine that could potentially be discharged in the event of a catastrophic accidental release within this area. The scenario results in a toxic endpoint distance of 1.4 miles (2.3 kilometers).



This worst-case scenario has the potential to impact an estimated population of 3,639 people (1,444) 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.



2. Toxic Alternative Release Scenario - Cyclohexylamine



As mentioned, the toxic substance cyclohexylamine is also contained in quantities and concentrations above its respective RMP thresholds in several boiler water treatment mixtures including BW-8192 in the Utilities - East storage area. An estimated maximum of 21,000 pounds of BW-8192 is contained in a single container of which 50% by weight is cyclohexylamine, resulting in a total of 10,500 pounds of cyclohexylamine that
could potentially be discharged in the event of an accidental release from this largest storage vessel. A probable alternative release scenario for cyclohexylamine is a rupture at a piping connection where the BW-8192 is pumped into the boiler water for treatment resulting in the entire 21,000 pounds of BW-8192 (10,500 pounds of cyclohexylamine) to be released over an estimated 20-minute time period. The rupture (cyclohexylamine toxic alternative-case scenario) results in a toxic endpoint distance of 0.2 miles (0.3 kilometers).



This alternative-case scenario has the potential to impact a minimal population in general. Landview 6 does not indicate any offsite receptors that will be impacted; however, it does not take into account that the facility also encompasses the MNR and Shell Norco Chemical Plant - West Site (SNCP-ES) and employees at each of these facilities could be impacted. No schools or hospitals should be affected by this release.



3. Flammable Worst-Case Release Scenario - Flammable Mixture



The worst-case scenario for a flammable release assumes the instantaneous failure, release, and vapor cloud explosion of 8,000,000 lbs of a flammable mixture (butane, 1,3-butadiene, isopentane, and pentane) from a process vessel in the OL-5 process. Although the vessel normally operates with liquid filled to 50% capacity, there are no procedures to regulate inventory. Therefore, the vessel was assumed full per the RMP requirements for WCS analysis. No passive (i.e. containment) mitigation credit was applied to the release model calculations. The release calculation also assumes urban topography due to the close proximity of congested process areas. The maximum impact distance to a 1 PSI endpoint was calculated at 1.6 miles (2.6 kilometers). A population estimate of 4,420 people off-site, including residential, recreational, religious, school and commercial receptors could be potentially affected by the release. Bayou Trepagnier, a designated sceni
c stream adjacent to the northern side of the facility, may also be impacted.



4. Flammable Alternative Release Scenario - Propylene



The alternative flammable scenario involves the release of 40,000 lbs of propylene and a subsequent vapor cloud explosion resulting from a valve stem blowout on a 48 inch power assisted check valve downstream of a propylene compressor. The release calculation assumes urban topography due to the close proximity of congested process areas. The modeling scenario also assumes a 5 minute release duration before the explosion occurs. This scenario was selected because of a 1997 incident in the industry involving a similar event in an identical process. It is assumed that release detection would be immediate due to the noise generated by a high pressure release. Operator intervention is assumed to deactivate the compressor to stop the flow of propylene, as well as activate area firewater monitors to contain any fire and cool equipment. The maximum impact distance to a 1 PSI endpoint was calculated at 0.3 miles (0.4 kilometers). This alternative-case scenario has the potential to impact approximately 33 people (13 residences). No schools or hospitals should be affected by this release.