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Hexion Inc. Norco Facility

Parent Companies:
Hexion LLC
EPA Facility ID:
100000177523
Other ID:
70079RSLTN16122
Facility DUNS:
1338797
Parent Company DUNS:
166495924

Location:

Address:
16122 River Road
Norco, LA 70079
County:
ST. CHARLES
Lat / Long:
30.002, -90.423 (Get map)
Method:
Interpolation - Satellite
Description:
Center of Facility
Horizonal accuracy:
40 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
Hexion Inc.
Phone:
(504) 472-6588
Address:
16122 River Road
Norco, LA 70079
Foreign Address:

Person responsible for RMP implementation:

Name:
Holly Stratton
Title:
Site Manager

Emergency contact:

Name:
Holly Stratton
Title:
Site Manager
Phone:
(504) 472-6588
24-hour phone:
(504) 382-0650
Ext or PIN:

Other contacts:

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

Safety:

Local Emergency Planning Committee:
St. Charles Parish LEPC
Full-Time Equivalent Employees:
69
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
2869-V7
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Nov. 18, 2014
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Petrochemical Manufacture
RMP ID:
1000069151
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Butane
106-97-8
68,000
No
Chlorine
7782-50-5
270,000
No
Epichlorohydrin [Oxirane, (chloromethyl)-]
106-89-8
1,600,000
No
Propylene [1-Propene]
115-07-1
370,000
No
Hydrochloric acid (conc 37% or greater)
7647-01-0
5,600,000
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

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
April 13, 2016
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
No
RMP ID:
1000055262

Deregistration:

Date:
Effective Date:
Reason:
Source terminated operations
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 Petrochemical Manufacture)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
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 Petrochemical Manufacture)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
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 Petrochemical Manufacture)
CBI claimed:
No
Percent weight:
Physical state:
Liquid
Model used:
EPA's OCA Guidance Reference Tables or Equations
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
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 Petrochemical Manufacture)
CBI claimed:
No
Percent weight:
37.0
Physical state:
Liquid
Model used:
EPA's OCA Guidance Reference Tables or Equations
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
not considered:
  • 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 Petrochemical Manufacture)
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 Petrochemical Manufacture)
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

Nov. 3, 2014 at 21:10
ID:
1000042537
NAICS:
Petrochemical Manufacturing (32511)
Duration:
20 minutes
Chemicals involved:
  • Chlorine
Release events:
Gas release
Weather conditions at time of event
Wind speed:
5.0 miles/h SSE
Temperature:
65.00 ℉
Atmospheric stability:
F
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:
3
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$76854
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Human Error
Contributing factors:
  • Human error
  • Overpressurization
  • Maintenance activity/inactivity
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

7. Prevention: Program level 3

Petrochemical Manufacture, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000057818
Safety Review Date
March 16, 2016, since latest RMP submission
PHA Update Date
March 26, 2015, since latest RMP submission
PHA Techniques
  • What if
  • 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
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Excess Flow Device
  • Quench System
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Fire Walls
  • Neutralization
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 22, 2016, since latest RMP submission
Training Review Date
Oct. 6, 2015, since latest RMP submission
Maintenance Review Date
Oct. 12, 2015, since latest RMP submission
Maintenance Inspection Date
March 1, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
March 9, 2016
Management of Change Review Date
April 1, 2015
Pre-startup Review Date
March 9, 2016
Compliance Audit Date
Feb. 5, 2016
Compliance Audit Change Completion Date
April 7, 2016
Incident Investigation Date
Nov. 4, 2014
Incident Invest. Change Completion Date
Jan. 13, 2016
Participation Plan Review Date
March 24, 2015
Hot Work Review Date
April 7, 2016
Contractor Safety Review Date
April 7, 2016, since latest RMP submission
Contractor Safety Eval. Date
March 31, 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:
Dec. 31, 2015
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:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

Hexion Inc.

Norco Facility

Norco, Louisiana

(EPA ID: 1000 0017 7523)

(LDEQ Facility ID: 19275)



EXECUTIVE SUMMARY

FOR

THE RISK MANAGEMENT PLAN



Introduction and Policies



Hexion Inc. (Hexion) is committed to the continuous improvement of chemical safety management. Hexion maintains Environmental, Health, and Safety (EHS) management systems to ensure the safe operation of its facilities. As part of this commitment, Hexion invests resources in various areas of accident prevention, such as:

? Safety in process design;

? Safe operating policies and procedures;

? A comprehensive mechanical integrity program;

? Management of process changes;

? Training;

? Incident investigation and auditing; and

? Emergency response participation.



This document provides an overview of the risk management activities at Hexion, including:

? A description of the facility and substances regulated by the EPA RMP rule;

? A summary of potential release scenarios and potential off-site consequences;

? An overview of the Prevention Program to prevent accidental chemical releases;

? A five-year history of accidental releases of chemicals regulated by EPA's RMP rule;

? An overview of the emergency response program; and

? Planned changes to improve safety.



FACILITY DESCRIPTION AND REGULATED SUBSTANCES



Hexion operates three (3) units with regulated substances in sufficient quantities to be covered under the Risk Management Program (RMP) regulation. The facility is classified as Program Level 3 under the RMP regulation. These three units, the C-unit, the Resins Unit, and the Shipping Unit, store or process RMP toxic and flammable substances as follows:



1. C-Unit

This unit produces and/or stores intermediate feedstocks used in the production of epoxy resins and calcium chloride. RMP regulated substances stored or processed in this unit include 37% Hydrochloric Acid, Chlorine, Epichlorohydrin, Propylene, and Butane.



2. Resins Unit

This unit produces fin
ished epoxy resin products. Epichlorohydrin is the only RMP regulated substance stored or processed in amounts greater than threshold quantity in the Resins Unit.



3. Shipping Unit

This unit receives and stores feedstocks used in resins production. Epichlorohydrin is the only RMP regulated substance stored or processed in amounts greater than threshold quantity in the Shipping/Loading area.



ACCIDENT PREVENTION PROGRAM



Hexion's constant emphasis on safety ,ongoing analysis of the potential hazards of our process, and detailed training of our employees allow us to operate safely. Part of the Accident Prevention Program also involves identifying and taking steps to avoid potential accidental chemical releases. This is accomplished through Process Hazard Analyses and periodic review of policies and procedures. Additionally, the site has various safety features to detect, contain and control, and mitigate the consequences of a release that include:



1. Release detection

? Process alarms

? Operator surveillance

? Portable hydrocarbon monitoring equipment

? Perimeter chlorine detection system



2. Release containment and control

? Relief systems designed to prevent equipment overpressurization (i.e. relief valves and flare)

? Dikes to contain liquid releases

? Redundant equipment (i.e. back-up firewater pump)

? Automatic control valves to allow rapid isolation of the process

? Chlorine emergency containment system



3. Release Mitigation

? Area firewater monitors

? Mobile emergency response equipment

? Trained emergency response personnel



FIVE YEAR ACCIDENT HISTORY



One incident meeting the definition of 40 CFR 68.42(a) caused by a covered RMP process has occurred at Hexion within the last five years. The details of this event are included in section 6 of the RMP.



EMERGENCY RESPONSE PROGRAM



The overall emergency response program for the Hexion Norco facility is coordinated with the St. Charles Parish Department of Emergency Prepar
edness (DEP), and Shell Chemical Company LLC (Shell). This coordination includes periodic committee meetings with or communications to local emergency response officials, local government officials, community members, and industry representatives. Shell and Hexion maintain trained and fully equipped firefighting, HAZMAT, and medical/rescue teams capable of managing a broad range of emergency incidents. Hexion also maintains a 24 hr. communications capability with St. Charles Parish 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, Hexion is also a member of the St. Charles Parish Industrial Mutual Aid Association. Periodic emergency drills are held with the St. Charles Parish DEP, Mutual Aid Organization members, and local emergency response organizations. Refresher training is also provided to local emergency response organizations on the hazards of regulated substances at the site.

The St. Charles Parish 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 who 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.



Hexion (through Shell) maintains a written emergency response program designed to protect workers, public safety, and the environment. This program consists of policies and procedures for responding to releases, including actions to be taken in the event of a fire, explosion, or chemical release. These procedu
res address all aspects of emergency response, including first aid and medical treatment, evacuation, personnel accountability plans, notification requirements to St. Charles Parish DEP and the public in the event of a release, post-incident cleanup and area decontamination requirements. In addition, there are procedures that address maintenance, inspection, testing, and use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific response duties. The emergency response program is updated as needed to address changes to Resins processes. The Management of Change process is used to trigger updates to the emergency response plan, including notification and training of personnel affected by the change. All the above actions of the emergency response program are undertaken by Hexion through a service agreement with Shell.



PLANNED CHANGES TO IMPROVE SAFETY



Diligent compliance with our RMP Prevention Program forms the framework on which we will continue to improve the level of safety at the facility. Some of the key components of the safety improvements we expect to achieve are as follows:



1. The Management of Change provisions ensure that we consider the potential safety and health impacts of any change we make to process chemicals, technology, equipment or procedures.



2. The Process Hazard Analysis (PHA) provisions serve as a tool to ensure continual evaluation of potential hazards, thereby leading to continual improvements in our safety standards.



3. The Mechanical Integrity provisions ensure that process equipment and instrumentation are designed, constructed, installed and maintained to minimize the risk of hazardous releases, thereby serving as an integral part of our safety program.



4. Internal and third party compliance audits will ensure we maintain and increase our level of safety protection.



5. An ongoing dialogue with the St. Charles Parish Emergency Management Director or
his designate will ensure a constant state of readiness to respond to any potential emergencies, as well as a means to implement improvements as the need develops. In this way, we shall bolster our strong commitment to the safety of our workers and the community.