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ExxonMobil Production - Baton Rouge Gas Plant

Parent Companies:
Exxon Mobil Corporation
EPA Facility ID:
100000085249
Other ID:
AR000061028
Facility DUNS:
0
Parent Company DUNS:
1213214

Location:

Address:
1601 Safe Energy Drive
Port Allen, LA 70767
County:
WEST BATON ROUGE
Lat / Long:
30.494, -91.224 (Get map)
Method:
Interpolation - Satellite
Description:
Plant Entrance (General)
Horizonal accuracy:
5 m
Horizontal reference datum:
World Geodetic System of 1984
Source map scale:

Owner/Operator:

Name:
ExxonMobil Production Company
Phone:
(713) 656-3636
Address:
222 Benmar
(CORP-MI-3023)
Houston, TX 77060
Foreign Address:

Person responsible for RMP implementation:

Name:
Title:
Operations Superintendent
Email:

Emergency contact:

Name:
Woodrow J Goodly
Title:
Plant Foreman
Phone:
(225) 344-2901
24-hour phone:
(337) 296-6161
Ext or PIN:

Other contacts:

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

Safety:

Local Emergency Planning Committee:
West Baton Rouge Parish LEPC
Full-Time Equivalent Employees:
6
Covered by OSHA PSM:
Yes
EPCRA section 302:
No
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
3120-00047-V4
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Jan. 15, 2008
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Natural Gas Plant
RMP ID:
79943
CBI claimed:
No
Program Level:
3
NAICS:
Natural Gas Liquid Extraction (211112)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
560,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
June 19, 2009
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
54801

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 Natural Gas Plant)
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 Natural Gas Plant)
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

Natural Gas Plant, Natural Gas Liquid Extraction (211112)
Prevention Program ID:
47174
Safety Review Date
March 4, 2009, since latest RMP submission
PHA Update Date
Nov. 20, 2008, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
  • Equipment failure
  • Cooling loss
  • Hurricanes
Process Controls
  • None
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
Training Type
  • None
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 16, 2012, since latest RMP submission
Training Review Date
Jan. 13, 2009, since latest RMP submission
Maintenance Review Date
Jan. 30, 2009, since latest RMP submission
Maintenance Inspection Date
March 4, 2009, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
March 31, 2009
Management of Change Review Date
Aug. 4, 2008
Pre-startup Review Date
March 31, 2009
Compliance Audit Date
April 19, 2012
Compliance Audit Change Completion Date
Dec. 31, 2012
Incident Investigation Date
March 2, 2009
Incident Invest. Change Completion Date
Dec. 31, 2009
Participation Plan Review Date
Feb. 18, 2009
Hot Work Review Date
March 2, 2009
Contractor Safety Review Date
Feb. 18, 2009, since latest RMP submission
Contractor Safety Eval. Date
May 22, 2008, since latest RMP submission

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:
No
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
No
Plan Review Date:
Response Training Date:
None
Local Response Agency:
Local Response Agency Phone:
(225) 346-5676
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

ExxonMobil Production Company - Baton Rouge Gas Plant
Risk Management Program Plan
Executive Summary

Accidental Release Prevention and Emergency Response Policies

The Baton Rouge 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 Baton Rouge Gas Plant, located about six miles north of the I-10 Port Allen exit on LA-1 and one mile south of the U.S. 190, consists of one Program Level 3 process that utilizes several operations (e.g., Separation, dehydration, compression, cryogenic) 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 of the regulated substance into and out of the facility is handled via pipelines. The adjacent tank farm operation handles condensate and lube oil (no regulated flammables) and is not considered part of the stationary source's covered process. The plant is surrounded by farmland and industry.

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 plant 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 range from updating/compiling technical information and drawings to participating on process hazard analysis (PHA) or incident investigation teams. 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 OIMS Technician for this plant is responsible for coordinating the PSI updates.

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 pro
cess controls and/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

This 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 Competency Assurance Standard (CAS) provides guidance and electronic tools to ensure the procedures are maintained. Revisions to procedures are made through the Management of Change (MOC) process.

Training

The Competency Assurance Standard (CAS) provides the framework to ensure operators and other employees achieve minimum required competencies to safely perform their work. The CAS system guides development and maintenance of written operating and maintenance procedures to provide a comprehensive training program to employees involved in operating and maintaining process equipment. 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 contractors 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 behavioral job safety analysis (BJSA) 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. The Management of Change (MOC) is used to steward assignment and completion of PSSRs.

Mechanical Integrity (MI)

ExxonMobil?s Facility Integrity Management System (FIMS) is designed to manage mechanical integrity. By incorporation of FIMS into its processes, this 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 this 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 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; hot work permit/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 behavioral job safety analyses (BJSAs) 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 co
uld 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 documented, 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 both facility and technical personnel 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 activitie
s 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 near gas turbines
- Hydrocarbon gas detectors and alarms near product shipping pumps

Release Containment/Control?.
- Pressure/thermal relief valves/rupture disks that discharge into the flare system for incineration
- Manual/automatic isolation valves
- Automated shutdown systems for specific process parameter
- Redundant equipment and instrumentation

Release Mitigation?.
- Fire extinguishing systems
- CO2 deluge system in the gas turbine enclosures
- Personal protective equipment

Five Year Accident History

This plant has had an excellent record for accident prevention over the past 5 years. In fact, there have not been any incidents, as defined in the regulation.

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 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., Material 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. Plant 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 West Baton Rouge Local Emergency Planning Committee (LEPC), the Port Allen and ExxonMobil Refinery Fire Departments, West Baton Rouge Parish 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 conducts periodic emergency action drills and provides periodic refreshers to the local emergency response organizations on the hazards associated with the plant operations.

Recent Changes to Improve Safety

Our Operations Integrity Management Systems form the cornerstone for continuous improvement in our safety-related systems. These systems are evergreen and are in a continuous state of improvement, usually through many small improvement steps. These improvement steps are tightly integrated with our training programs. This plant resolves findings from PHAs, incident investigations, and safety audits.

Examples of changes that were recently implemented to improve the safety of this operation are:

- Implementation of the ExxonMobil Competency Assurance Standard (CAS)
- Implementation of the ExxonMobil Facility Integrity Management System (FIMS)
- Implementation of the ExxonMobil Fundamentals of Safety (EMFOS) Training
- Implementation of the Safety in Motion? program