Norco Chemical Plant - St. Rose Site - Executive Summary |
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3462 LDEQ Facility ID Number Shell Chemical Company Norco Chemical Plant - St. Rose Site Risk Management Plan - Executive Summary The St. Rose Site is one of three Shell Chemical Company facilities operated by Shell's Norco Chemical Plant (NCP). Shell Chemical Company is a signatory to Responsible Care., a Chemical Manufacturers Association (CMA) program committed to the continuous improvement of chemical safety management. In accordance with Responsible Care., the Norco Chemical Plant maintains Health, Safety, and Environmental (HSE) management systems to ensure the safe operation of its facilities. As part of this commitment, NCP 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 - Emergency response. This document provides an overview of the risk management activiti es at the Norco Chemical Plant - St. Rose Site, 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 Accident 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 - Existing and planned improvements to prevent accidental chemical releases. FACILITY DESCRIPTION AND REGULATED SUBSTANCES The St. Rose Site produces quality olefins feedstocks from crude oil. These feedstocks are used to manufacture ethylene and propylene at the Shell Norco Chemical Plant-East Site. St. Rose consists of one process which produces two (2) flammable feedstock products containing butane, ethane, methane, and propane in sufficient quantities to be covered under RMP. OFFSITE CONSEQUENCE ANALYSIS (OCA) SCENARIOS An offsite conseque nce analysis (OCA) was performed on the potential worst-case scenario (WCS) and alternative release scenario (ARS) involving flammable mixtures at the St. Rose Site. The WCS is considered to be unrealistic because it does not reflect actual operating conditions nor allow credit for all mitigations in-place. On the other hand, the ARS is a more realistic scenario which takes into account actual operating conditions and applicable mitigations. The following are brief summaries of the Worst-Case and Alternative Release scenarios at St. Rose, including information on mitigation control measures to reduce potential offsite impact. All OCA release modeling was performed using the ABS Group, Inc. RMPlanner 2.0 software tool. This tool is based on the 1996 EPA OCA Guidance Tables. 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. III Environmen tal Mapping Software (1997). 1. Worst-Case Flammable Scenario - St. Rose Light Product This scenario assumes the catastrophic failure, instantaneous release, and vapor cloud explosion of 2,600,000 lbs. of St. Rose Light Product from a liquid full storage tank. The release calculation assumes an urban topography due to the number of co-located tanks and process area congestion between the tank and the nearest public receptor. Although the tank is located within a 50,500 cubic foot containment dike, the modeling program did not give credit for the containment. In addition, active (mechanical) mitigations can not be considered for worst-case scenarios under the RMP rule. The maximum impact distance to a 1 PSI endpoint was calculated at 1.10 miles (5,860 ft.). A population estimate of 2,000 people offsite, including residential, religious, and commercial receptors could be potentially affected by the release. No offsite environmental receptors were identified. 2. Alternative R elease Flammable Scenario - St. Rose Light Product This scenario involves the overfill of 75,000 lbs. of St. Rose Light Product from a storage tank and assumes the vapor from a liquid pool reaches an ignition source, creating a pool fire. This scenario was selected due to a previous incident (see 5 year Accident History) involving a tank overfill and liquid pooling, but no fire. The release calculation assumes urban topography due to the amount of process congestion in close proximity. Passive mitigation consists of a 50,500 cubic foot containment dike. Active mitigation consists of operator detection and intervention. Operator response includes shutting down feed pumps to stop flow to the tank and activation of the area firewater monitors to disperse vapors from the liquid pool. Radio communication is used activate the Norco Emergency Response Team (ERT) who could respond in 15-20 minutes. Once on-site, the foam would be applied to extinguish the fire. The maximum impact dist ance to a 5 kW/m2 for 40 sec (potential for 2nd degree burn) endpoint was calculated at 0.15 miles (770 ft.). A population estimate of 60 people offsite, including residential and commercial receptors could be potentially affected by the release. No offsite environmental receptors were identified. ACCIDENT PREVENTION PROGRAM - MANAGEMENT SYSTEM The following is a summary of the Norco Chemical Plant (NCP) management system on accident prevention used at the St. Rose facility. Each of the NCP sites contain processes that are also regulated under the OSHA Process Safety Management (PSM) standard. This Accident Prevention Program description is applicable to all NCP sites and summarizes the general management system according to each of the RMP/PSM prevention elements. Employee Participation NCP encourages employee participation in all phases of its accident prevention management system. There is an NCP Employee Participation policy that addresses participation requirements of va rious teams and committees, including Health & Safety Committees, Process Hazards Analysis (PHA) teams, and various safety awareness teams. Participants include employees from Operations, Maintenance, Engineering & Technical Support and Management. Process Safety Information (PSI) The Norco Chemical Plant maintains a variety of technical documents to ensure the safe operation of its processes. The Process Safety Management policy requires operating departments maintain and update PSI applicable to their processes. Chemical-specific information is contained in material safety data sheets (MSDS'), including properties, exposure hazards, emergency response, and exposure treatment considerations. Other PSI documents include, but are not limited to process drawings, descriptions of safe operating parameters and limits, chemical inventories, basis for process design, safeguarding, protective instrument and equipment construction information. Many of the documents, including MSDS' are electronically available to all NCP employees and Contractors. The Process Safety Management policy also includes a summary table to assist employees in locating process safety information documents and drawings. Process Hazards Analysis (PHAs) The Norco Chemical Plant maintains a comprehensive Process Hazards Analysis (PHA) program to identify and control hazards associated with its processes. These include processes covered under one or a combination of: (1) RMP Program 3, (2) OSHA PSM, and (3) Shell internal criteria. NCP uses the hazard and operability (HAZOP) PHA methodology to conduct process unit PHAs. PHA team members must include experienced employees with operating, maintenance, and engineering backgrounds who are familiar with the affected process. The PHA team is chartered to identify the safety hazards in the process, evaluate the adequacy of existing safeguards in-place, determine the risk of the event occurring, and recommend additional accident prevention miti gations when the team believes such measures are necessary to reduce event risk. All safety related PHA findings are risk ranked to ensure mitigation measures receive timely attention based on their risk priority. All PHA findings are forwarded to local Management for review and resolution. Safety related mitigations approved by Management begin immediately after Management review, starting with the highest risk scenarios. When a final mitigation can not be implemented within a reasonable time (e.g. hardware change scheduled to a unit maintenance turnaround), interim solutions such as administrative controls (i.e. operating and work practice changes) must be implemented to mitigate the risk. PHA mitigations are tracked on a quarterly basis until resolved. Process unit PHA's are revalidated every 5 years for the life of the process. Written PHA reports are also retained for the life of the process. Operating Procedures Norco Chemical Plant operating departments maintain writte n procedures to address a variety of operating modes such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures provide a reference to experience operators, as well as serve as a training tool for new operators. Each PSM covered operating department must annually certify their procedures as current and accurate. The management of change process is also used to ensure operating procedures are updated as necessary to reflect changes in the process unit. Operating procedures are accessible to all NCP employees either electronically or in hard copy. Training The Norco Chemical Plant implements a comprehensive training program for all operating, maintenance, and technical personnel. New operating employees receive classroom training on basic operating principles and the operating procedures of their process. In addition to classroom training, on-the-job training is accomplished by working with experienced operating personnel. Along with routine operating practices, the training places a significant emphasis on unit specific safety and health hazards, and emergency operating conditions (including shutdown). Employees involved in operating a process must be qualified to perform the job on that process. Operators must re-qualify on their jobs every three (3) years and work a predesignated number of hours by job to maintain qualification. Competency is assessed through a combination of methods such as written and oral tests, and demonstrating skills in the field. The training program complements the written operating procedures to ensure operating employees are properly qualified for their job. All training is documented and managed by the NCP Training Department. Contractors The Norco Chemical Plant routinely uses contractors to supplement its maintenance and technical workforce, particularly during periods of increased maintenance or cons truction activities. Since contractors may work on or near process equipment, NCP has procedures in place to ensure that contractors have the proper knowledge, skills, and training to perform their work in a safe manner prior to working on-site. Contractor safety programs and performance are primary factors influencing the Contractor selection process. Contractors are routinely monitored by a Contract Coordinator to ensure compliance with regulatory and Shell requirements. Contractor safety performance is also part of NCP weekly safety statistics communications to employees and contractors. Pre-Startup Safety Review (PSSR) The Norco Chemical Plant conducts a PSSR for any new facility or facility modification that requires a change in process safety information. In addition, major projects and maintenance turnarounds require a PSSR to be completed. The purpose of the PSSR is to ensure that safety features such as P&ID and other process drawings, operating and/or maintenance pro cedures, training and equipment are up to date and appropriately prepared for startup prior to placing the equipment in-service. This review provides an additional check to ensure construction is in accordance with design specifications, that all supporting systems are operationally ready, and personnel are appropriately trained on the modification. Mechanical Integrity The Norco Chemical Plant has well-established practices and procedures to maintain the integrity of pressure vessels, storage tanks, piping systems, relief and vent systems, process controls, pumps, and critical instrument systems. The basic aspects of the mechanical integrity program include (1) training for process maintenance activities, (2) ongoing 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 trained on the safety and health hazards in their 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 ensure that the process equipment functions as intended and that the equipment is within acceptable limits (e.g. acceptable wall thickness for pressure vessels). If a deficiency is identified, the operating department must correct the deficiency before placing the equipment back in service. The appropriate mechanical integrity support group (i.e. Inspection and Pressure Equipment, Mechanical, Electrical, or Instrumentation) review equipment use and determine any necessary actions to ensure the safe operation of the equipment. Safe Work Practices and Permitting The Norco Chemical plant has long-standing safe work practices in place to help ensure worker and process safety. Examples include: (1) the control of entry and exit of support personnel in a process area, (2) equipment locko ut and tagout procedures to ensure isolation of energy sources for equipment undergoing maintenance, (3) procedures for the safe removal of hazardous materials before opening process piping or equipment, (4) a permit process to control hot work, and (5) a policy and permit process to ensure adequate precautions are in place before entry into a confined space. These safe work practices, along with training of affected personnel, form a system to ensure operations and maintenance activities are performed safely. Management of Change The Norco Chemical Plant has a comprehensive system to manage changes to its processes. This system requires that changes to equipment hardware, chemicals, operating variables (including critical process operating conditions), procedures, operating staff and any other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to ensure that adequate controls are in place to manage any new hazards and verify that e xisting controls have not been compromised by the change. Affected chemical hazard information, process operating limits, equipment information, and procedures are updated to incorporate these changes. In addition, all personnel affected by a change must be provided the necessary notification and training. Incident Investigation The Norco Chemical Plant promptly investigates incidents resulting in, or could have reasonably resulted in fire, explosion, significant toxic gas release, major property damage, environmental loss, or personal injury affecting site personnel or the community. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to NCP Management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until t hey are complete. The final resolution of each finding or recommendation is documented and the investigation results are reviewed with all potentially affected employees and contractors. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during PHA revalidations. Compliance Audits The Norco Chemical Plant maintains a comprehensive audit program to ensure accident prevention policies and procedures are in place and functioning properly. Compliance audits consist of: (1) OSHA PSM compliance audits conducted every three years at each NCP site, (2) external compliance audits by Shell's Corporate Office on a three year cycle, and (3) internal management system audits conducted annually to evaluate the accident prevention system for each unit. Employees ranging from hourly, engineering and technical, and management personnel participate as audit team members in the internal audit process. The audit team(s) develop findings that are fo rwarded to NCP 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 audit findings are retained for six (6) years. Site-Specific Prevention Steps The Norco Chemical Plant's accident prevention program is applied to the NCP - St. Rose Site due to potential hazards that must be managed to ensure continued safe operation. These prevention steps help to prevent potential accident scenarios that could be caused by (1) equipment failures and (2) human error. The St. Rose site has various safety features to: (1) detect, (2) contain and control, and (3) mitigate the consequences of a release that include: 1. Release detection - Process alarms - Operator surveillance - Portable hydrocarbon monitoring equipment 2. Release containment and control - Relief systems designed to prevent equipment overpressurization (i.e. relief valves and flare) - Dikes to cont ain liquid releases - Redundant equipment (i.e. back-up firewater pump) - Control valves to allow isolation of the process 3. Release Mitigation - Area firewater monitors - Mobile emergency response equipment - Trained emergency response personnel FIVE YEAR ACCIDENT HISTORY Over the last five (5) years, there have been no releases of RMP regulated substances from the St. Rose Site that have resulted in offsite consequences. Since the purchase of the St. Rose facility by Shell Chemical Company in 1996, there has been only one release incident involving an RMP regulated substance. This involved the overfill and release of 75,000 lbs. of St. Rose Light Product from a storage tank during barge unloading operations. The release was isolated and the product fully contained in the dike around the storage tank. Area firewater monitors were used to suppress and dilute any vapor release until foam could be applied to the liquid pool in the dike. There were no personnel injuries and n o off-site protective measures were required. This was considered an RMP reportable accident since the storage tank sustained structural damage from the incident. EMERGENCY RESPONSE PROGRAM The overall emergency response program for the Norco Chemical Plant is coordinated with the St. Charles Parish Department of Emergency Preparedness (DEP), MOTIVA ENTERPRISES LLC - Norco Refining Company 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. NCP and Norco Refining Company maintain trained and fully equipped firefighting, HAZMAT, and medical/rescue teams capable of managing a broad range of emergency incidents. NCP also maintains a 24 hr. communications capability with St. Charles Parish DEP officials, as well as area emergency response organizations (i.e. local fire departm ents, Sheriff's department, State Police, etc.). In addition to established lines of communication with area emergency response organizations, NCP 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 training is also provided to local emergency response organizations on the hazards of regulated substances at NCP facilities. The St. Charles Parish Department of Emergency Preparedness (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. NCP 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 procedures 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 need ed to address changes to NCP 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. CONTINUAL IMPROVEMENTS TO PROCESS SAFETY, RELIABILITY AND LOSS CONTROL The Norco Chemical Plant strives for continuous improvement in the areas of process safety, operations and equipment reliability, maintenance effectiveness and control systems. Changes to enhance the safety of the process are identified through the Management of Change process, the PHA program, mechanical integrity program, incident investigation findings, audit findings and communications dialogue with NCP employees and community stakeholders. |