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Super High Activity Catalyst (SHAC) Plant

Parent Companies:
W.R. Grace & Co. - Conn.
W.R. Grace & Co.
EPA Facility ID:
100000139824
Other ID:
70079CYPRS16122
Facility DUNS:
79414149
Parent Company #1 DUNS:
1367846
Parent Company #2 DUNS:
1367846

Location:

Address:
16122 River Road
Norco, LA 70079
County:
ST. CHARLES
Lat / Long:
30.002, -90.425 (Get map)
Method:
Interpolation - Satellite
Description:
Process Unit
Horizonal accuracy:
40 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
W.R Grace & Co. - Conn.
Phone:
(410) 531-4000
Address:
7500 Grace Drive
Columbia, MD 21044
Foreign Address:

Person responsible for RMP implementation:

Name:
Wei Deng
Title:
Plant Manager

Emergency contact:

Name:
Kevin Servat
Title:
EH&S Manager
Phone:
(985) 725-4009
24-hour phone:
(985) 722-5442
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(985) 725-4009
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
St. Charles Parish LEPC
Full-Time Equivalent Employees:
35
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
April 8, 2014
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Catalyst Production
RMP ID:
1000052484
CBI claimed:
No
Program Level:
3
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Chemical name
CAS#
Quantity (lbs.)
CBI
Isopentane [Butane, 2-methyl-]
78-78-4
250,000
No
Titanium tetrachloride [Titanium chloride (TiCl4) (T-4)-]
7550-45-0
700,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
ENVIRON International Corporation
Address:
8235 YMCA Plaza Drive
Baton Rouge, LA 70810
Foreign Address:

Phone:
(225) 408-2696

Latest RMP Submission:

Date:
June 11, 2014
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000042569

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 Catalyst Production)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
9999.90
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
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 Catalyst Production)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
not considered:
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Sprinkler systems
  • Deluge systems
  • Scrubbers
not considered:
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • 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 Catalyst Production)
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 Catalyst Production)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • Dikes
not considered:
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Water curtain
  • Excess flow valve

6. Five-year accident history

April 13, 2010 at 03:55
ID:
1000033782
NAICS:
Petrochemical Manufacturing (32511)
Duration:
40 minutes
Chemicals involved:
  • Titanium tetrachloride [Titanium chloride (TiCl4) (T-4)-]
Release events:
Liquid spills/evaporation
Weather conditions at time of event
Wind speed:
6.19999981 miles/h NE
Temperature:
66.00 ℉
Atmospheric stability:
E
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
0
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$0
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
125
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Equipment failure
  • Maintenance activity/inactivity
  • Inadequate understanding of incident command structure resulting in delayed vapor supression response.
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Revised maintenance
  • Revised training
  • Revised operating procedures
  • Revised emergency response plan
  • Reviewed and clarified incident command structure with co-tenants.

7. Prevention: Program level 3

Catalyst Production, Other Basic Inorganic Chemical Manufacturing (32518)
Prevention Program ID:
1000044255
Safety Review Date
July 19, 2010, since latest RMP submission
PHA Update Date
Nov. 27, 2012, since latest RMP submission
PHA Techniques
  • None
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 Power
  • Grounding Equipment
  • Rupture Disks
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • Perimeter Monitoring
  • Mitigation Systems
Training Type
  • None
Competency Testing
  • Written Test
  • Demonstration
Procedure Review Date
Jan. 30, 2014, since latest RMP submission
Training Review Date
Feb. 25, 2013, since latest RMP submission
Maintenance Review Date
Jan. 14, 2014, since latest RMP submission
Maintenance Inspection Date
Dec. 2, 2013, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Feb. 17, 2014
Management of Change Review Date
March 9, 2011
Pre-startup Review Date
Feb. 17, 2014
Compliance Audit Date
June 18, 2012
Compliance Audit Change Completion Date
June 9, 2013
Incident Investigation Date
Oct. 30, 2013
Incident Invest. Change Completion Date
Dec. 30, 2013
Participation Plan Review Date
May 28, 2014
Hot Work Review Date
Dec. 8, 2008
Contractor Safety Review Date
May 8, 2014, since latest RMP submission
Contractor Safety Eval. Date
March 26, 2014, 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. 19, 2012
Local Response Agency:
Local Response Agency Phone:
(985) 783-5050
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:
Yes
Subject To - Other:

Executive Summary

1. Accidental Release Prevention and Emergency Response Policies

The W. R. Grace & Co. - Conn. (Grace) Super High Activity Catalyst (SHAC) Plant in Norco, LA is strongly committed to employee, public and environmental safety. This commitment is demonstrated by a comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training. It is company and site policy to implement appropriate controls to prevent possible releases of regulated substances. If such an unforeseeable release does occur, the site has HazWoper trained individuals on site to control and mitigate the effects of releases. Furthermore, the SHAC Plant is located inside of the Momentive Chemical Site Facility, on land owned by Shell Chemical LP. Emergency response services for the manufacturing complex, including the SHAC Plant is provided by Shell.



2. The Stationary Source and the Regulated Substances Handled

Grace purchased the Norco SHAC Plant from the Dow Chemical Company in December 2013. The facility's primary activity is catalyst manufacturing. The facility annually produces more than 800,000 pounds of catalyst. The material produced at this facility is sold to customers in the United States and abroad. The catalyst is used by our customers primarily in the manufacturing of polypropylene resin. The site has one RMP-regulated toxic substance - titanium tetrachloride (TiCl4) and one RMP-regulated flammable substance - isopentane. The maximum inventory present at our facility is 700,000 pounds of TiCl4 and 250,000 pounds of isopentane. Both substances are located within the manufacturing process area and contained in tankage.



3. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps

Our facility has taken necessary steps to comply with the accidental release prevention requirements set out under the U.S. Environmental Protection Agency's Accidental Release Pr
evention Program regulations (40 CFR 68). This facility was designed and constructed with reference to various industry codes including: American Petroleum Institute (API), American Society for Mechanical Engineers (ASME), National Fire Protection Association (NFPA), and Good Engineering Practices. The facility is subject to the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) standard ( 29 CFR 1910.119). The facility is also subject to the Emergency Planning and Community Right-to-Know Act (EPCRA) Section 302 notification requirements. The following sections briefly describe the elements of the release prevention program that is in place at the SHAC Plant.



Process Safety Information

Grace's SHAC Plant maintains a detailed record of safety information that describes the chemical hazards, process technology, and equipment information. This information is documented, maintained up to date, and available for operating personnel associated with the facility.



Process Hazard Analysis

Process Hazard Analyses are conducted or revalidated at least every five years to identify major process hazard scenarios and to recommend corrective actions needed to prevent their occurrence.



Operating Procedures

Grace's SHAC Plant maintains written operating procedures for the purposes of safely conducting activities within the covered processes. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes.



Training

Grace's SHAC Plant has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every three years.



Mechanical Integrity

Gr
ace's SHAC Plant carries out highly documented maintenance checks on facility equipment to ensure proper operations. Equipment examined by these checks include; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls, and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.



Management of Change

A management of change (MOC) process is in place at Grace's SHAC Plant to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and provided training addressing the modification.



Pre-startup Reviews

Pre-start up safety reviews related to new processes or to modifications to the facility are conducted as a regular practice at Grace's SHAC Plant. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation.



Compliance Audits

Grace's SHAC Plant conducts audits on a regular basis to determine whether the provisions set out under regulatory rules are being implemented. These audits are carried out at least every 3 years and corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Third party audits are also utilized to provide independent assessment of site regulatory compliance programs.



Incident Investigation

Grace's SHAC Plant promptly investigates incidents that result in, or could reasonably result in, a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as
well as corrective actions to prevent the release from reoccurring. Reports are retained for a minimum of 5 years.



Employee Participation

For Grace's SHAC Plant, process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. There is a site procedure for Employee Participation and a Plant Safety Committee has been established with monthly meetings.



Contractors

Our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Grace's SHAC Plant has a strict policy of informing the contractors of known potential hazards related the contractor's work and the facility. Contractors are also informed of the procedures for emergency response should an accidental release of a regulated substance occur.



4. Five-year Accident History

Grace's SHAC Plant has had an excellent record of preventing accidental releases.

There has been one accidental release during the previous 5-year period that met the reporting criteria under the RMP rule: a release on 4/13/2010 involving an RMP chemical resulted in off-site evacuation.



5. Emergency Response Plan

Grace's SHAC Plant maintains a written emergency response plan to protect worker and public safety as well as the environment. The plan consists of procedures for responding to releases of hazardous substances, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response including:

*Proper first aid and medical treatment for exposures

*Evacuation plans and acc
ounting for personnel after an evacuation

*Post incident cleanup and decontamination requirements, and

*Inspecting, testing, maintaining, and using emergency response equipment.

The emergency response plan is updated when necessary based on modifications made to facility processes.



The SHAC Plant is located within the Momentive Chemical Site Facility, on land owned by Shell Chemical LP. Emergency response for the manufacturing complex, including the SHAC Plant, is provided by Shell. The Shell Chemical Plant maintains a trained emergency squad to handle fires, explosions, toxic vapor and releases, spills, and medical emergencies. The plant squad trains and drills with local emergency responders to enhance their skills and tactics for responding to an accidental chemical release. Critiques are held on drills and actual events. In addition to the plant emergency squad, St. Charles Parish Emergency Operations Center (EOC) is notified immediately when an incident occurs. The EOC determines the community impact and takes the appropriate action to protect the community. Additional resources are also available through mutual aid organizations if needed.



The emergency response program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Detailed emergency response plans are developed and coordinated with the St. Charles Parish EOC and the community.



6. Planned Changes to Improve Safety

On-going programs, such as process hazard analysis reevaluations, continually aim to improve process safety. The following is a list of specific improvements that we are planning to implement at the Norco SHAC Plant to help prevent and/or better respond to accidental chemical releases:

-Conduct periodic process hazard analyses for all processes and implement resulting recommendations for improvements to safety equipment and procedures.

-Conduct New Leader Reviews so that newly assigned pro
duction leaders have all of the process

safety and reactive chemicals information necessary for their new jobs.

-All new projects are designed around principles of inherent safety so that process safety is integrated

directly into the design.

-Changes to new or revised systems seek to minimize the quantities of hazardous materials.

-Improve Lock-out Tag-out program with new software and utilizing locks instead of hard hasp tags.