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Shell Chemical Company LP

Parent Companies:
Shell Oil Company
EPA Facility ID:
100000134419
Other ID:
70737SHLLCRIVER
Facility DUNS:
96039672
Parent Company DUNS:
184957348

Location:

Address:
7594 Highway 75
Geismar, LA 70734
County:
ASCENSION
Lat / Long:
30.183, -91.000 (Get map)
Method:
Interpolation - Digital map source (TIGER)
Description:
Plant Entrance (General)
Horizonal accuracy:
1 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
Shell Chemical Company
Phone:
(225) 201-6222
Address:
P.O. Box 500
Geismar, LA 70734
Foreign Address:

Person responsible for RMP implementation:

Name:
Rhoman Hardy
Title:
General Manager

Emergency contact:

Name:
Mark Kinchen
Title:
Fire Chief (Safety Specialist)
Phone:
(225) 201-6455
24-hour phone:
(225) 201-6537
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(225) 201-6222
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Ascension Parish LEPC
Full-Time Equivalent Employees:
675
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
more than one
OSHA Star/Merit Ranking
Yes
Last Safety Inspection Date:
May 27, 2014
Inspecting Agency:
State environmental agency
Using Predictive Filing:
Yes

Processes:

AO1
RMP ID:
1000080680
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
180,000
No
Public OCA Chemical
0
No
EOEG2
RMP ID:
1000080681
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
55,000
No
Ethylene oxide [Oxirane]
75-21-8
6,000,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
K2
RMP ID:
1000080682
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
13,000
No
Public OCA Chemical
0
No
Utilities
RMP ID:
1000080683
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
72,000
No
Public OCA Chemical
0
No
AO2
RMP ID:
1000080684
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
130,000
No
Public OCA Chemical
0
No
AO3
RMP ID:
1000080685
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
190,000
No
Public OCA Chemical
0
No
ID1
RMP ID:
1000080686
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
92,000
No
Public OCA Chemical
0
No
ID2
RMP ID:
1000080687
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
45,000
No
Flammable Mixture
00-11-11
4,800,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
K3
RMP ID:
1000080688
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
11,000
No
Public OCA Chemical
0
No
K4
RMP ID:
1000080689
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
11,000
No
Public OCA Chemical
0
No
K5
RMP ID:
1000080690
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
27,000
No
Public OCA Chemical
0
No
EOEG3
RMP ID:
1000080691
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ethylene oxide [Oxirane]
75-21-8
76,000
No
Flammable Mixture
00-11-11
35,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Logistics
RMP ID:
1000080692
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ethylene oxide [Oxirane]
75-21-8
160,000
No
Flammable Mixture
00-11-11
760,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Sarah Scott
Address:
775 North University Blvd.
Suite 280
Mobile, AL 36608
Foreign Address:

Phone:
(251) 706-8585

Latest RMP Submission:

Date:
Aug. 16, 2017
Type:
Resubmission
Reason:
Change in program level of covered process (40 CFR 68.190(b)(7))
Registered:
Yes
RMP ID:
1000064324

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 EOEG2)
CBI claimed:
No
Percent weight:
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 EOEG2)
CBI claimed:
No
Percent weight:
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:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in Utilities)
CBI claimed:
No
Percent weight:
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:
  • 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 ID2)
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

AO1, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000067899
Safety Review Date
Feb. 7, 2014, since latest RMP submission
PHA Update Date
Feb. 7, 2014, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Oct. 31, 2016, since latest RMP submission
Training Review Date
March 27, 2017, since latest RMP submission
Maintenance Review Date
April 1, 2017, since latest RMP submission
Maintenance Inspection Date
May 3, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 26, 2017
Management of Change Review Date
Nov. 1, 2016
Pre-startup Review Date
March 10, 2017
Compliance Audit Date
March 18, 2017
Compliance Audit Change Completion Date
April 16, 2017
Incident Investigation Date
Nov. 10, 2016
Incident Invest. Change Completion Date
March 9, 2017
Participation Plan Review Date
March 15, 2016
Hot Work Review Date
July 12, 2016
Contractor Safety Review Date
May 25, 2016, since latest RMP submission
Contractor Safety Eval. Date
May 25, 2016, since latest RMP submission
EOEG2, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000067900
Safety Review Date
May 22, 2014, since latest RMP submission
PHA Update Date
May 22, 2014, since latest RMP submission
PHA Techniques
  • 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
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Fire Walls
  • Blast Walls
  • Deluge System
  • Enclosure
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Feb. 1, 2017, since latest RMP submission
Training Review Date
Jan. 15, 2017, since latest RMP submission
Maintenance Review Date
April 1, 2017, since latest RMP submission
Maintenance Inspection Date
April 28, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
May 4, 2017
Management of Change Review Date
Nov. 1, 2016
Pre-startup Review Date
April 25, 2017
Compliance Audit Date
March 18, 2016
Compliance Audit Change Completion Date
April 16, 2017
Incident Investigation Date
Oct. 15, 2016
Incident Invest. Change Completion Date
Dec. 31, 2016
Participation Plan Review Date
March 15, 2016
Hot Work Review Date
July 12, 2016
Contractor Safety Review Date
May 25, 2016, since latest RMP submission
Contractor Safety Eval. Date
May 25, 2016, since latest RMP submission
K2, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000067901
Safety Review Date
Feb. 12, 2016, since latest RMP submission
PHA Update Date
Feb. 12, 2016, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Dikes
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Sept. 26, 2016, since latest RMP submission
Training Review Date
March 7, 2017, since latest RMP submission
Maintenance Review Date
April 1, 2017, since latest RMP submission
Maintenance Inspection Date
April 28, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
March 16, 2017
Management of Change Review Date
Nov. 1, 2016
Pre-startup Review Date
Jan. 27, 2017
Compliance Audit Date
March 18, 2016
Compliance Audit Change Completion Date
April 16, 2017
Incident Investigation Date
March 14, 2016
Incident Invest. Change Completion Date
July 19, 2016
Participation Plan Review Date
March 15, 2016
Hot Work Review Date
July 12, 2016
Contractor Safety Review Date
May 25, 2016, since latest RMP submission
Contractor Safety Eval. Date
May 25, 2016, since latest RMP submission
Utilities, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000067902
Safety Review Date
Sept. 24, 2013, since latest RMP submission
PHA Update Date
Sept. 24, 2013, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
  • Quench System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Dec. 29, 2016, since latest RMP submission
Training Review Date
Nov. 22, 2016, since latest RMP submission
Maintenance Review Date
April 1, 2017, since latest RMP submission
Maintenance Inspection Date
April 28, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
May 3, 2017
Management of Change Review Date
Nov. 1, 2016
Pre-startup Review Date
March 4, 2017
Compliance Audit Date
March 18, 2016
Compliance Audit Change Completion Date
April 16, 2017
Incident Investigation Date
April 26, 2017
Incident Invest. Change Completion Date
May 31, 2017
Participation Plan Review Date
March 15, 2016
Hot Work Review Date
July 12, 2016
Contractor Safety Review Date
May 25, 2016, since latest RMP submission
Contractor Safety Eval. Date
May 25, 2016, since latest RMP submission
AO2, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000067903
Safety Review Date
March 11, 2016, since latest RMP submission
PHA Update Date
March 11, 2016, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Dec. 1, 2016, since latest RMP submission
Training Review Date
Nov. 10, 2016, since latest RMP submission
Maintenance Review Date
April 1, 2017, since latest RMP submission
Maintenance Inspection Date
May 3, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 3, 2017
Management of Change Review Date
Nov. 1, 2016
Pre-startup Review Date
April 5, 2017
Compliance Audit Date
March 18, 2016
Compliance Audit Change Completion Date
April 16, 2017
Incident Investigation Date
Sept. 7, 2016
Incident Invest. Change Completion Date
April 30, 2017
Participation Plan Review Date
March 15, 2016
Hot Work Review Date
July 12, 2016
Contractor Safety Review Date
May 25, 2016, since latest RMP submission
Contractor Safety Eval. Date
May 25, 2016, since latest RMP submission
AO3, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000067904
Safety Review Date
Feb. 3, 2017, since latest RMP submission
PHA Update Date
Feb. 3, 2017, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Nov. 1, 2016, since latest RMP submission
Training Review Date
March 2, 2017, since latest RMP submission
Maintenance Review Date
April 1, 2017, since latest RMP submission
Maintenance Inspection Date
April 28, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
March 30, 2017
Management of Change Review Date
Nov. 1, 2016
Pre-startup Review Date
March 20, 2017
Compliance Audit Date
March 18, 2016
Compliance Audit Change Completion Date
April 16, 2017
Incident Investigation Date
March 7, 2016
Incident Invest. Change Completion Date
Jan. 2, 2017
Participation Plan Review Date
March 15, 2016
Hot Work Review Date
July 12, 2016
Contractor Safety Review Date
May 25, 2016, since latest RMP submission
Contractor Safety Eval. Date
May 25, 2016, since latest RMP submission
ID1, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000067905
Safety Review Date
Aug. 21, 2015, since latest RMP submission
PHA Update Date
Aug. 21, 2015, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Dikes
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Dec. 1, 2016, since latest RMP submission
Training Review Date
March 30, 2017, since latest RMP submission
Maintenance Review Date
April 1, 2017, since latest RMP submission
Maintenance Inspection Date
April 28, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 18, 2017
Management of Change Review Date
Nov. 1, 2016
Pre-startup Review Date
March 14, 2017
Compliance Audit Date
March 18, 2017
Compliance Audit Change Completion Date
April 16, 2017
Incident Investigation Date
Jan. 20, 2017
Incident Invest. Change Completion Date
July 31, 2017
Participation Plan Review Date
March 15, 2016
Hot Work Review Date
July 12, 2016
Contractor Safety Review Date
May 25, 2016, since latest RMP submission
Contractor Safety Eval. Date
May 25, 2016, since latest RMP submission
ID2, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000067906
Safety Review Date
March 10, 2017, since latest RMP submission
PHA Update Date
March 10, 2017, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • Increased Inventory
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Nov. 17, 2016, since latest RMP submission
Training Review Date
March 31, 2017, since latest RMP submission
Maintenance Review Date
April 1, 2017, since latest RMP submission
Maintenance Inspection Date
April 28, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
May 3, 2017
Management of Change Review Date
Nov. 1, 2016
Pre-startup Review Date
May 4, 2017
Compliance Audit Date
March 18, 2016
Compliance Audit Change Completion Date
April 16, 2017
Incident Investigation Date
April 27, 2017
Incident Invest. Change Completion Date
May 1, 2017
Participation Plan Review Date
March 15, 2016
Hot Work Review Date
July 12, 2016
Contractor Safety Review Date
May 25, 2016, since latest RMP submission
Contractor Safety Eval. Date
May 25, 2016, since latest RMP submission
K3, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000067907
Safety Review Date
Feb. 12, 2016, since latest RMP submission
PHA Update Date
Feb. 12, 2016, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Dikes
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
July 18, 2016, since latest RMP submission
Training Review Date
March 7, 2017, since latest RMP submission
Maintenance Review Date
April 1, 2017, since latest RMP submission
Maintenance Inspection Date
April 25, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
May 4, 2017
Management of Change Review Date
Nov. 1, 2016
Pre-startup Review Date
Jan. 27, 2017
Compliance Audit Date
March 18, 2016
Compliance Audit Change Completion Date
April 16, 2017
Incident Investigation Date
June 4, 2016
Incident Invest. Change Completion Date
Dec. 31, 2016
Participation Plan Review Date
March 15, 2016
Hot Work Review Date
July 12, 2016
Contractor Safety Review Date
May 25, 2016, since latest RMP submission
Contractor Safety Eval. Date
May 25, 2016, since latest RMP submission
K4, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000067908
Safety Review Date
Feb. 12, 2016, since latest RMP submission
PHA Update Date
Feb. 12, 2016, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Dikes
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
July 28, 2016, since latest RMP submission
Training Review Date
Sept. 26, 2016, since latest RMP submission
Maintenance Review Date
April 1, 2017, since latest RMP submission
Maintenance Inspection Date
April 1, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 3, 2017
Management of Change Review Date
Nov. 1, 2016
Pre-startup Review Date
Jan. 27, 2017
Compliance Audit Date
March 18, 2016
Compliance Audit Change Completion Date
April 16, 2017
Incident Investigation Date
July 29, 2015
Incident Invest. Change Completion Date
Dec. 10, 2015
Participation Plan Review Date
March 15, 2016
Hot Work Review Date
July 12, 2016
Contractor Safety Review Date
May 25, 2016, since latest RMP submission
Contractor Safety Eval. Date
May 25, 2016, since latest RMP submission
K5, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000067909
Safety Review Date
Feb. 12, 2016, since latest RMP submission
PHA Update Date
Feb. 12, 2016, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Dikes
  • Deluge System
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Dec. 1, 2016, since latest RMP submission
Training Review Date
Sept. 26, 2016, since latest RMP submission
Maintenance Review Date
April 1, 2017, since latest RMP submission
Maintenance Inspection Date
April 12, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
May 4, 2017
Management of Change Review Date
Nov. 1, 2016
Pre-startup Review Date
Jan. 27, 2017
Compliance Audit Date
March 18, 2016
Compliance Audit Change Completion Date
April 16, 2017
Incident Investigation Date
Dec. 5, 2013
Incident Invest. Change Completion Date
Jan. 10, 2014
Participation Plan Review Date
March 15, 2016
Hot Work Review Date
July 12, 2016
Contractor Safety Review Date
May 25, 2016, since latest RMP submission
Contractor Safety Eval. Date
May 25, 2016, since latest RMP submission
EOEG3, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000067910
Safety Review Date
Feb. 16, 2015, since latest RMP submission
PHA Update Date
Feb. 16, 2015, since latest RMP submission
PHA Techniques
  • 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
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Fire Walls
  • Blast Walls
  • Deluge System
  • Enclosure
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 14, 2017, since latest RMP submission
Training Review Date
March 1, 2017, since latest RMP submission
Maintenance Review Date
April 1, 2017, since latest RMP submission
Maintenance Inspection Date
April 28, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 27, 2017
Management of Change Review Date
Nov. 1, 2016
Pre-startup Review Date
April 12, 2017
Compliance Audit Date
March 18, 2016
Compliance Audit Change Completion Date
April 16, 2017
Incident Investigation Date
Feb. 20, 2016
Incident Invest. Change Completion Date
Feb. 28, 2017
Participation Plan Review Date
March 15, 2016
Hot Work Review Date
July 12, 2016
Contractor Safety Review Date
May 25, 2016, since latest RMP submission
Contractor Safety Eval. Date
May 25, 2016, since latest RMP submission
Logistics, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000067911
Safety Review Date
July 3, 2013, since latest RMP submission
PHA Update Date
July 3, 2013, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Floods
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
  • Water Curtain
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
April 18, 2016, since latest RMP submission
Training Review Date
April 5, 2017, since latest RMP submission
Maintenance Review Date
April 1, 2017, since latest RMP submission
Maintenance Inspection Date
April 28, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 27, 2017
Management of Change Review Date
Nov. 1, 2016
Pre-startup Review Date
March 16, 2017
Compliance Audit Date
March 18, 2016
Compliance Audit Change Completion Date
April 16, 2017
Incident Investigation Date
Oct. 5, 2016
Incident Invest. Change Completion Date
March 1, 2017
Participation Plan Review Date
March 15, 2016
Hot Work Review Date
July 12, 2016
Contractor Safety Review Date
May 25, 2016, since latest RMP submission
Contractor Safety Eval. Date
May 25, 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 17, 2017
Local Response Agency:
Local Response Agency Phone:
(225) 621-8360
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
No
Subject To - OPA:
No
Subject To - State EPCRA:
No
Subject To - Other:

Executive Summary

EXECUTIVE SUMMARY



The Shell Chemical Company, LP - Geismar Plant (the "facility") is located at 7594 Highway 75; Geismar, Ascension Parish, Louisiana 70734. The facility is committed to operating in a manner that is safe for the facility's workers, the public, and the environment. As part of this commitment, Shell Chemical Company has established systems to ensure safe operation of the facility. One part of this system is the Risk Management Program (RMP) that complies with the Environmental Protection Agency's (EPA's) regulation 40 CFR Part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). One of the requirements of the RMP rule is to submit a Risk Management Plan (RMPlan) describing the risk management program at Shell Chemical Company. This document is intended to satisfy the RMPlan requirements and to provide the public with a description of the risk management program at the facility in Geismar, Louisiana.

The Executive Summary includes an overview of the following elements:

- Accidental release prevention and emergency response policies;

- Facility and regulated substances;

- Accidental release prevention program and chemical-specific prevention steps;

- Five-year accident history;

- Emergency response program; and

- Planned changes to improve safety



1.1 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE



The facility implements reasonable controls to prevent foreseeable releases of hazardous substances. In the event of a significant accidental release, our trained personnel respond to control and contain such releases as appropriate. Each situation is evaluated individually and appropriate measures are taken to protect the employees and the community. Shell Chemical Company, the Local Emergency Planning Committee (LEPC), and neighboring industry have established a program to warn the community if an accident occurs that could threaten the community. A local siren warning system is in place an
d is tested routinely.



1.2 THE SHELL CHEMICAL COMPANY AND REGULATED SUBSTANCES

The Shell Chemical Company LP-Geismar Plant is a downstream chemicals manufacturing plant. The primary feedstock to the facility is ethylene, which is transported via pipeline from other Shell facilities. The facility manufactures a wide range of ethylene based industrial chemical products and these products can be transported via tank trucks, standard or pressurized rail cars, marine tankers, and tank barges to customers throughout the United States and some foreign countries.

The facility handles many substances regulated by the RMP rule in sufficient quantities to be covered by the RMP rule. The information below indicates the processes as defined by the rule and the regulated substances therein:

- AO1 - Alpha olefin production - Program 3: 1-butene, 2-butene-cis, 2-butene-trans, ethane, methane, and ethylene.

- AO2 - Alpha olefin production - Program 3: 1-butene, 2-butene-cis, 2-butene-trans, ethane, methane, and ethylene.

- AO3 - Alpha olefin production - Program 3: 1-butene, 2-butene-cis, 2-butene-trans, ethane, methane, and ethylene.

- ID1 - Internal olefin production - Program 3: 1-butene, 2-butene-cis, 2-butene-trans, 1-pentene, and propylene.

- ID2 - Internal olefin production - Program 3: 1-butene, 2-butene-cis, 2-butene-trans, 1-pentene, and propylene.

- EOEG2 - Ethylene oxide and ethylene glycol production - Program 3: methane, ethylene, and ethylene oxide.

- EOEG3 - Ethylene oxide and ethylene glycol production - Program 3: methane, ethylene, and ethylene oxide.

- K2 - Detergent range alcohol production - Program 3: hydrogen, methane, and carbon monoxide.

- K3 - Detergent range alcohol production - Program 3: hydrogen, methane, and carbon monoxide.

- K4 - Detergent range alcohol production - Program 3: hydrogen, methane, and carbon monoxide.

- K5 - Detergent range alcohol production - Program 3: hydrogen, methane, and carbon monoxide.

- Utilities - Ch
lorine and ammonia (anhydrous) used in water treatment processes in the Utilities System - Program 3: chlorine and ammonia (anhydrous).

- Logistics - Railcar loading and storage - Program 3: 1-butene, 2-butene-cis, 2-butene-trans, and ethylene oxide.



1.3 ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS



The following is a summary of the general accident prevention program in place for the Program 3 processes at the facility. Because the processes at the Shell Chemical Company Geismar Plant that are regulated by the EPA RMP rule are also subject to the Process Safety Management (PSM) standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program.

Process Safety Information - The facility keeps a variety of technical documents that are used to help maintain safe operation of the process. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Specific departments and individuals in the plant are assigned responsibility for maintaining up-to-date process safety information.

Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in the Safety Data Sheets (SDSs).

Process Hazard Analysis (PHA) - The facility has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each covered process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.

The Geismar facility primarily uses the hazard and operability (HAZOP) technique to perform these evaluations. This technique may be supplemented using the "What If", "Checklist" or "What If/Checklist" techniques. The analyses are conducted using a tea
m of people who have operating and maintenance experience as well as engineering expertise. The PHA team also includes one member who is knowledgeable in the specific PHA methodology being used. The team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary.

The PHA team findings are forwarded to facility management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. They ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete and are communicated to operations, maintenance and other employees whose work assignments are in the process and may be affected by the findings. The final resolution of each finding is documented and retained.

To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the facility periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every five years and will be conducted at the specified frequency until the process ceases to operate. The results and findings from these updates are documented and retained. Again, the team findings are forwarded to management for consideration and the final resolution of the findings is documented and retained.

Operating Procedures - The facility maintains written procedures that address various modes of process operation such as (1) initial startup of a new process, (2) startup following a turnaround, (3) startup after an emergency shutdown, (4) normal operations, (5) temporary operations, (6) emergency operations, (7) normal shutdown,
and (8) emergency shutdown. The facilities operating procedures also address operating limits, safety and health considerations, and safety systems and their functions. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. Procedures are periodically reviewed and certified annually as current and accurate by revising them as necessary to reflect changes made through the Management of Change (MOC) process.

Training - To complement the written procedures for process operations, the facility has implemented a training program for all employees involved in operating a process. To be qualified to perform a particular job, the Technician must complete initial training, including refresher training for that job at least every three years. Operating employees receive classroom and on the job training. The training includes an emphasis on specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the job. Operators must complete written and oral tests, as well as field demonstration and observation of skills as part of the qualification training. Initial and refresher training records for each employee involved in operating a covered process are maintained in the Shell Training and Recordkeeping System, which is maintained by the Training Section of the Human Resources Department. The records include the employee's name, date of training, copies of tests and other means used to verify that the employee . Contract employees are not involved in operating covered processes.

Contractors - The facility uses contractors regularly to supplement the facility's workforce during periods of high activity. Because some contractors work on or near process equipment, Shell Chemical Company has procedures in place to ensure contractors have the proper knowledge of and training on plant systems, procedures, and processes before they perform work
at the site. Safety performance constitutes a major factor in the overall evaluation of contractor performance and Shell performs periodic evaluations of contractor compliance with Shell and regulatory requirements.

Pre-Startup Safety Reviews (PSSR) - The facility conducts a PSSR for any new facility or facility modification that requires a change in process safety information. In addition, all major projects, major turnarounds, and minor turnarounds require a PSSR to be performed prior to completing mechanical work and prior to introducing highly hazardous chemicals to a process. The purpose of the PSSR is to confirm that (1) construction and equipment are in accordance with design specifications, (2) safety, operating, maintenance, and emergency procedures are in place and are adequate, and (3) training of each employee involved in operating the process has been completed. This review provides an additional check to make sure that all supporting systems are operationally ready. The PSSR review team creates an Expected State of Readiness Document, which is used to verify all aspects of the organization's readiness.

Mechanical Integrity - The facility has well-established practices and procedures to maintain the integrity of pressure vessels and storage tanks, piping systems, relief and vent systems, controls, pumps, and emergency shutdown systems. The basic aspects of the mechanical integrity program include (1) training for process maintenance activities, (2) inspection and testing of process equipment, (3) correction of identified equipment deficiencies as appropriate, and (4) quality assurance in construction, installation and spare parts.

Maintenance personnel are knowledgeable of the safety and health hazards of the work areas, applicable maintenance procedures, emergency response plans, and applicable safe work practices to help ensure they can perform their job in a safe manner. Inspections and tests are performed to help ensure that process equip
ment functions as intended, and to verify that this equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back in service, or the Mechanical Equipment Team (MET) or the Pressure Systems Team (PST) will review the use of equipment and determine what actions are necessary to ensure the safe operation of the equipment.

Employee Participation - The facility's written employee participation plan (EPP) will achieve its objectives by consulting with employees in several specific forums, including, but not limited to, the following: (1) weekly safety meetings, (2) shift team meetings, and (3) contractor safety meetings. Employee participation objectives are also achieved by consulting with employees on the conduct and development of PHAs, and on the development and implementation of other PSM elements in the rule.

All employees and contractors have access to PHAs and all other information required by the PSM standard, subject to trade secret/confidentiality procedures. Their concerns or suggestions are normally addressed as part of established meetings. However, special request are addressed individually by the appropriate manager.

Safe Work Practices - The facility has long-standing safe work practices in place to help ensure worker and process safety. Examples include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) procedures for the safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with the training of affected personnel, form a system to hel
p ensure that operations and maintenance activities are performed safely.

Management of Change (MOC) - The facility has a comprehensive system to manage changes to processes. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated to incorporate these changes. In addition, operating and maintenance personnel whose job tasks will be affected by a change in the process are provided with any necessary training on the change.

Incident Investigation - The facility promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, significant toxic gas release, major property damage, environmental loss or personal injury. 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 recurrence, and forwards these results to 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 contractors) who could be affected by the findings. Incident investigation reports are retained for at least five years so that the reports can be reviewed during future PHAs and PHA revalidations.

Compliance Audits - To help ensure that the accident prevention p
rogram is functioning properly, the facility conducts an audit to determine whether the procedures and practices required by the accident prevention program are in place. Compliance audits are conducted at least every three years. Both unit-level workers and management personnel participate in the audits, including at least one person who is knowledgeable in the process. The HSEGT Process Safety Committee is responsible for overseeing and periodically developing and conducting these audits in conjunction with the tri-annual PSM prevention program audits required by OSHA on the same frequency. The audit team develops findings that are forwarded to management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are maintained.

Chemical-Specific Prevention Steps - The processes at the facility have hazards that must be managed to ensure continued safe operation. The prevention program summarized previously is applied to all Program 3 EPA RMP covered processes at the plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failure and (2) human errors.

In addition to the accident prevention program activities, the facility has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in various processes.

Release detection

- Stationary ethylene oxide monitors with alarms

- Process alarms

- Personal exposure monitors

Release Containment/Control

- Process relief valves that discharge a flare to capture and incinerate episodic releases

- Scrubbers to neutralize/minimize chemical releases

- Valves to permit isolation of the process (manual or automated)

- Automated shutdown sy
stems for specific process parameters (e.g., high level, high temperature)

- Curbing or diking to contain liquid releases

- Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control systems, backup firewater pump)

- Atmospheric relief devices designed for safe dispersion of chemicals

Release Mitigation

- Fire suppression and extinguishing systems

- Deluge system for specific equipment

- Trained emergency response personnel on-site at all times

- Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus)

- Blast-resistant buildings to help protect personnel and control systems



1.4 FIVE-YEAR ACCIDENT HISTORY



The facility maintains a five-year accident history that fulfills the requirements of the RMP Rule. This history provides a useful record of accidental release prevention over the past five years. No releases of regulated substances have occurred from Shell Chemical Company Geismar Plant within the last five years that have resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage or environmental damage.



1.5 EMERGENCY RESPONSE PROGRAM INFORMATION



The facility maintains a written Emergency Response Plan (ERP), which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including incident command, proper first aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post-incident cleanup and decontamination requirements. In addition, the facility has procedures that ad
dress maintenance, inspection, and testing of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is updated when necessary based on modifications made to the plant processes or other plant facilities. The ERP changes are administered through the MOC process, which includes informing and/or training affected personnel in the changes.

The overall ERP for the Shell Chemical Company Geismar Plant is coordinated with the Ascension Parish Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee with local emergency response officials, local government officials, and industry representatives. The facility has around-the-clock communication capabilities with appropriate LEPC officials and emergency response organizations (e.g., local fire department). There is also a community siren warning system for public notification of a significant event. These systems provide a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, the facility conducts periodic emergency drills that involve the LEPC and emergency response organizations.



1.6 PLANNED CHANGES TO IMPROVE SAFETY



The facility strives to improve the safety of plant processes through periodic safety reviews, the Incident Investigation Program, proactive safety campaigns, and a safety meeting system for soliciting feedback from employees. Shell resolves all findings from PHAs, some of which result in modifications to the process to improve safety.