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King Ranch Gas Plant

Parent Companies:
LaGrange Acquisitions, LP
EPA Facility ID:
100000081243
Other ID:
TXD000779116
Facility DUNS:
879095032
Parent Company DUNS:
0

Location:

Address:
7 miles W of Kingsville on Hwy 141
Kingsville, TX 78363
County:
KLEBERG
Lat / Long:
27.468, -98.056 (Get map)
Method:
Interpolation - Digital map source (TIGER)
Description:
Center of Facility
Horizonal accuracy:
10 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
Energy Transfer Partners
Phone:
(713) 989-7000
Address:
1300 Main Street
Houston, TX 77002
Foreign Address:

Person responsible for RMP implementation:

Name:
Title:
Operations Manager
Email:

Emergency contact:

Name:
Armando Villarreal
Title:
Operations Manager
Phone:
(361) 595-9227
24-hour phone:
(361) 595-9214
Ext or PIN:

Other contacts:

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

Safety:

Local Emergency Planning Committee:
Kleberg County LEPC
Full-Time Equivalent Employees:
80
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
O-00568
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Nov. 20, 2013
Inspecting Agency:
OSHA
Using Predictive Filing:
No

Processes:

Flammable Gas Mixture
RMP ID:
1000050686
CBI claimed:
No
Program Level:
3
NAICS:
Natural Gas Liquid Extraction (211112)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
38,000,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
May 29, 2014
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000041193

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

None

3. Toxics: Alternative release

None

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 Flammable Gas Mixture)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • Dike
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 Flammable Gas Mixture)
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. 18, 2013 at 00:45
ID:
1000033266
NAICS:
Natural Gas Liquid Extraction (211112)
Duration:
45 hours and 15 minutes
Chemicals involved:
  • Flammable Mixture
Release events:
Fire
Weather conditions at time of event
Wind speed:
None
Temperature:
None ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
Yes
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:
$47000000
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Equipment failure
  • Human error
  • Improper procedure
  • Upset condition
  • By-pass condition
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Revised training
  • Revised operating procedures
  • New process controls

7. Prevention: Program level 3

Flammable Gas Mixture, Natural Gas Liquid Extraction (211112)
Prevention Program ID:
1000044183
Safety Review Date
May 16, 2014
PHA Update Date
April 26, 2013
PHA Techniques
  • None
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
  • Overfilling
  • Equipment failure
  • Cooling loss
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Purge System
Mitigation Systems
  • Dikes
  • Deluge System
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
  • Process Detection
  • Mitigation Systems
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
May 8, 2015
Training Review Date
May 1, 2014
Maintenance Review Date
May 14, 2014
Maintenance Inspection Date
May 15, 2014
Equipment Tested
Yes
Management of Change Most Recent Date
May 3, 2014
Management of Change Review Date
May 1, 2010
Pre-startup Review Date
Jan. 31, 2014
Compliance Audit Date
March 22, 2013
Compliance Audit Change Completion Date
Sept. 30, 2013
Incident Investigation Date
Nov. 18, 2013
Incident Invest. Change Completion Date
Jan. 1, 2015
Participation Plan Review Date
April 11, 2014
Hot Work Review Date
Oct. 31, 2013
Contractor Safety Review Date
None
Contractor Safety Eval. Date
Dec. 31, 2013

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
No
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:
April 22, 2014
Local Response Agency:
Local Response Agency Phone:
(361) 595-8527
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

Energy Transfer Partners - King Ranch Gas Plant

Risk Management Program Plan

Executive Summary



Accidental Release Prevention and Emergency Response Policies



The King Ranch Gas Plant has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention (e.g., training of personnel, considering safety in the design, installation, operation, and maintenance of the facility, etc.). Our approach is to implement reasonable controls to prevent foreseeable releases of regulated substances as well as other substances. If a release does occur, our trained personnel will take steps to control and contain it, until local emergency organizations arrive. Additional details are included in the other sections of this plan.



Description of the Stationary Source and Regulated Substances



The King Ranch Gas Plant, located about 14 miles southwest of Kingsville, TX, consists of one Program Level 3 process that utilizes several operations (e.g., separation, dehydration, compression, refrigeration) to produce petroleum products (e.g., natural gas liquid mixture, methane) from a naturally occurring hydrocarbon gas mixture.



This plant could contain regulated flammables, but no regulated toxic inventories, in excess of threshold quantities established in the regulation. Transportation into the facility is handled via pipelines and out of the facility via pipelines and trucking. This plant is surrounded by unoccupied ranch land.



Offsite Consequence Analysis Results



In accordance with special security guidance provided by the USEPA, data addressing the facility's Offsite Consequence Analyses (Worst Case Scenarios and Alternate Release Scenarios) are not detailed in this section. Refer to Data Element Sections 4 and 5 of this plan.



General Accidental Release Prevention Program



The following is a summary of the accident prevention program in place at this facility. Processes at this pl
ant regulated by EPA's Risk Management Program (RMP) are also subject to OSHA's Process Safety Management (PSM) standard. This summary addresses each of the EPA RMP elements and describes the management systems in place to implement the accident prevention program.



Employee Participation



This plant provides for and encourages employees to participate in process safety management and accident prevention. Examples of employee participation include plant employees compiling and updating technical information and drawings, participating in Process Hazard Analysis (PHA), initiating a Management of Change (MOC), participating in Pre-Startup Safety Reviews (PSSR),and participating in incident investigations. Employees have access to information related to the accident prevention program. Specific ways that employees can be involved in the accident prevention program are detailed in an Employee Participation Plan that is maintained at this plant and addresses each program element. In addition, this plant has other initiatives that address process and employee safety issues (e.g., hazard reporting/resolution process and numerous safety meetings [daily, monthly, pre-job], etc.).



Process Safety Information (PSI)



This plant 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, safe operating limits for key process parameters, specific chemical inventories, and equipment design basis/configuration information. The Plant's PSM Coordinator is responsible for ensuring plant personnel maintain and update accurate PSI.



Chemical-specific information (including exposure hazards, emergency response, and exposure treatment considerations) is provided in material safety data sheets. For specific process areas, this plant has documented safety-related operating limits for process parameters (e.g., temperature, pressure, level) in the operating procedures
. This plant ensures processes are maintained within these limits using process controls/monitoring equipment, trained personnel, and protective instrument systems (e.g., automated shutdown systems, pressure relief valves).



This plant also maintains numerous technical documents that provide information about the design and construction of the process equipment. This information includes the materials of construction, design pressure, temperature ratings, and electrical rating of equipment. This information, in combination with written procedures and trained personnel, provides a basis for inspection/maintenance activities and the evaluation of proposed process or facility changes.



Process Hazard Analysis (PHA)



This plant has a comprehensive program to help ensure hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure adequate controls are in place to manage these hazards.



In the most recent PHA cycle, the plant utilized a PHA delta revalidation process, an industry-accepted hazard evaluation technique for RMP and PSM-covered processes. The analyses are conducted using a team of facility operations/maintenance personnel, facility engineers, and technical consultants (as necessary). This team identifies and evaluates hazards of the processes as well as the accident prevention and mitigation measures.



The PHA team findings are forwarded to management to coordinate further evaluation and resolution. This process involves field level business teams, which include engineering, operations personnel, and management. Operations personnel are also involved in the evaluation of resolution options. Implementation of the resolutions is prioritized for accomplishment based on relative risk. Resolution plans are tracked until completed. The final resolution of each finding is documented and retained.



To help ensure the process controls an
d/or hazards do not deviate significantly from the original design, this plant updates and revalidates the process hazard analysis at least every 5 years. The results of these updates are also documented and retained. Similarly, the team's findings are forwarded to management to coordinate further evaluation and resolution, and the final resolution of findings are documented and retained.



Operating Procedures



The King Ranch Gas Plant maintains written procedures that address the various modes of process operations (e.g., startup, normal, temporary, emergency shutdown, normal shutdown) and provide guidance on how to respond to upper/lower limit exceedances for specific equipment or process parameters. Procedures are readily available to operators and other personnel to use as necessary to safely perform their job tasks. These procedures provide a consistent basis for training new operators and are annually reviewed and validated. The Operating Procedures are revalidated annually and endorsed by the plant's Operations Manager for accuracy verification. Revisions to Operating Procedures are made through the Management of Change (MOC) process.



Training



New employees receive basic training in facility operations (e.g., process overview, applicable procedure reviews, etc.). New operators are then paired with experienced operators to learn process-specific duties and tasks. After the new operators demonstrate (e.g., written tests, hands-on skills demonstration) that they have adequate knowledge to perform the duties and tasks in a safe manner on their own, they are certified and allowed to work independently. In addition, personnel who operate process equipment receive refresher training at least every 3 years on the applicable procedures to help ensure their skills and knowledge are maintained at an acceptable level. This training and the means used to verify that the employee understood the training is documented.



Contractors



This plant uses c
ontractors to supplement its workforce for routine maintenance or construction. Because some contractors work on or near process equipment, procedures are in place to help ensure contractors: perform their work in a safe manner, have the appropriate knowledge and skills, are aware of the hazards in the workplace, understand what they should do in the event of an emergency, understand and follow safety rules, and inform plant personnel of any hazards they find during their work. This is accomplished by providing contractors an orientation prior to working in this plant which includes: a process overview, information about safety and health hazards, applicable emergency action plan provisions, and information on safe work practices. Also, a job safety analysis (JSA) is reviewed/updated or developed by the contractors (with facility personnel assistance as needed) prior to maintenance/construction tasks.



Plant personnel routinely monitor contractor job performance to help ensure they are fulfilling their safety obligations. Contractor safety programs and performance are evaluated during the initial selection process, and the plant supervisor conducts periodic evaluations of safety performance.



Pre-Startup Safety Reviews (PSSR)



This plant conducts PSSRs for facility modifications that require significant changes in the process safety information. The purpose of the PSSR is to ensure safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides an additional check to make sure that construction is in accordance with the design specifications and supporting systems are operationally ready. A PSSR involves field verification of the construction and serves a quality function by verifying that the requirements of this accident prevention program are properly implemented.



Mechanical Integrity (MI)



The King Ranch Gas Plant has well-established practices and
procedures to maintain pressure vessels, piping systems, relief/vent systems, controls, pumps, compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of the MI program include: training, written procedures, inspections/tests, correction of identified deficiencies, and quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process. Maintenance personnel receive training on the process, safety and health hazards, applicable maintenance procedures, emergency procedures, and applicable safe work practices to help ensure they perform their jobs in a safe manner. Written maintenance procedures and equipment manuals help ensure work is performed in a consistent manner and provide a basis for training.



Inspections/tests and preventive maintenance are performed on a scheduled basis to help ensure equipment and safety devices function as intended and to verify that equipment is within acceptable limits (e.g., adequate wall thickness, etc.). If a deficiency is identified, employees correct the deficiency before placing the equipment back into service or a group of experts (e.g., engineers, etc.) review the use of the equipment and determine what actions are necessary to ensure safe operation of the equipment until the deficiency can be corrected.



Another integral part of the MI program is quality assurance. This plant incorporates quality assurance measures into equipment purchases and repairs to help ensure new equipment is suitable for its intended use and proper materials/spare parts are used for repairs.



Hot Work and Other Safe Work Practices



This plant has long-standing safe work practices in place to help ensure worker and process safety. These include orientations for visitors/contractors; control of the entry/presence/exit of support personnel; energy isolation for equipment being worked on; procedures for the safe removal of hazardous materials
before opening of process piping/equipment; permit to work/procedure to safely manage spark-producing activities; vehicle entry into process area; confined space entry permit/procedure to help ensure precautions are taken before entering confined spaces; safety and security device bypass expectations; simultaneous operations guidance; and job safety analyses (JSAs) to identify and mitigate hazards associated with maintenance tasks. These practices, along with related procedures and training of affected personnel, form a system to help ensure operations and maintenance activities are performed safely.



Management of Change (MOC)



This facility has a comprehensive system to manage changes to process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes. The MOC facilitates appropriate review and authorization before a change is implemented. Changes are reviewed to ensure adequate controls are in place to manage any new hazards and to verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, equipment information, drawings, and procedures are updated for these changes. In addition, operating and maintenance personnel are provided the necessary training related to the change.



Incident Investigation



This plant promptly investigates incidents that resulted in (or could have reasonably resulted in) a fire, explosion, release, major equipment/property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations, and forwards these results to management for resolution. Corrective actions taken in response to the investigation team's findings are tracked until completed. The final resolution of each finding is documen
ted, and investigation results are reviewed with employees (including contractors) who could be affected. Incident investigation reports are retained for at least 5 years so that reports can be reviewed during the next PHA revalidation.



Compliance Audits



To help ensure the accident prevention program is functioning properly, an audit is conducted at the plant at least once every 3 years to determine whether the program's procedures and practices are being implemented. An audit team consisting of ETP's qualified and PSM Auditors evaluate the implementation/effectiveness of the processes in this accident prevention program and develop findings that are documented and forwarded to management to coordinate resolution. Corrective actions are taken in response to the audit team's findings, and resolution status is tracked until actions are completed. The final resolution of each finding is documented and the two most recent audit reports are retained.



Chemical-Specific Prevention Steps



The processes at this plant have hazards that are managed to help ensure continued safe operation. The following is a description of existing safety features applicable to the prevention of accidental releases of the specific regulated substances.



Universal Prevention Activities



The accident prevention program previously summarized is applied to the RMP-covered process at this plant. These prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human error.



Specialized Features



This plant has safety features on many units to: quickly detect a release, contain/control a release, and reduce/mitigate the consequences of a release. The following types of safety features are used:



Release Detection

- Hydrocarbon gas detectors and alarms on the compressors

- Hydrocarbon gas detectors and alarms near the product shipping pumps

- Hydrocarbon gas detectors and alarms near process pumps

- High-Low le
vel alarms on storage facilities

- Hydrogen sulfide detection alarm in the amine area



Release Containment/Control

- Pressure/thermal relief valves that discharge into a flare system for incineration

- Manual/automatic isolation valves

- Automated shutdown systems for specific process parameter

- Redundant equipment and instrumentation



Release Mitigation

- Fire extinguishing systems

- Personal protective equipment

- Secondary containment around storage tanks.

- Trained personnel



Five Year Accident History



This plant has had one incident resulting in the primary loss of containment over the past 5 years.



Emergency Response Program Information



This plant maintains a written action program to protect the workers, public, and environment. The program consists of procedures for handling releases of regulated regulated substances (i.e., flammables) including the possibility of fires or explosions. The procedures address: facility/equipment isolation and shutdown, initial first aid and medical treatment for exposures (i.e., Safety Data Sheet information), evacuation plans for this plant, accounting for plant personnel after an evacuation, notification of local emergency response agencies and post-incident cleanup/decontamination requirements. In addition, this facility has procedures that address the maintenance, inspection, and testing of emergency equipment and alarms. Facility personnel receive training on these procedures, as necessary, to perform their specific duties.



The emergency action program is reviewed annually and updated when necessary. Plan changes required because of modifications to this facility or emergency response equipment are administered through the management of change process, which includes informing and/or training affected personnel.



The overall emergency program for this plant is coordinated with the Kleberg County Local Emergency Planning Committee (LEPC), Kingsville Fire Department, Kleberg County
Sheriff's Department, and local ambulance services. This plant has around-the-clock communications capability with the emergency response organizations. These organizations are responsible (if necessary) for notifying the public, coordinating the community response (e.g., blocking off roads, evacuation, etc.), and providing onsite response (e.g., fire fighting, medical treatment, etc.). The plant works closely with the King Ranch Security Department who will assist in coordinating with external agencies should an emergency occur. This plant conducts periodic emergency action drills and provides periodic refreshers to the local emergency response organizations on the hazards associated with the plant operations.