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Neale Gas Processing Facility

Parent Companies:
Texas Petroleum Investment Company
EPA Facility ID:
100000087951
Other ID:
Facility DUNS:
0
Parent Company DUNS:
619010770

Location:

Address:
1088 Arco Road
Merryville, LA 70653
County:
BEAUREGARD
Lat / Long:
30.772, -93.469 (Get map)
Method:
GPS - Unspecified
Description:
Storage Tank
Horizonal accuracy:
15 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
Texas Petroleum Investment Company
Phone:
(337) 232-1702
Address:
207 Town Center Parkway
Suite 150
Lafayette, LA 70506
Foreign Address:

Person responsible for RMP implementation:

Name:
Brandon Lege'
Title:
Health & Safety Coordinator

Emergency contact:

Name:
Dallas Colligan
Title:
Superintendent
Phone:
(337) 232-1702
24-hour phone:
(337) 316-1806
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(337) 232-1702
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Beauregard Parish LEPC
Full-Time Equivalent Employees:
0
Covered by OSHA PSM:
No
EPCRA section 302:
No
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
April 17, 2003
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

NGL Storage Tank
RMP ID:
1000067705
CBI claimed:
No
Program Level:
2
NAICS:
Natural Gas Liquid Extraction (211112)
Chemical name
CAS#
Quantity (lbs.)
CBI
Butane
106-97-8
156,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Joseph Derigo
Address:
P.O. Box 52805
Lafayette, LA 70505
Foreign Address:

Phone:
(337) 839-1075

Latest RMP Submission:

Date:
March 18, 2016
Type:
Resubmission
Reason:
Voluntary update (not described by any of the above reasons)
Registered:
Yes
RMP ID:
1000053977

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 NGL Storage Tank)
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 NGL Storage Tank)
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

No Prevention Program level 3

8. Prevention Program level 2

NGL Storage Tank, Natural Gas Liquid Extraction (211112)
Prevention Program ID:
1000042449
Safety Review Date
March 1, 2016, since latest RMP submission
PHA Update Date
, since latest RMP submission
Safety Regulations
  • None
Hazards Identified
  • None
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
  • Keyed Bypass
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Excess Flow Device
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • Process Controls
Training Type
  • None
Competency Testing
  • Observation
Procedure Review Date
Dec. 1, 2015, since latest RMP submission
Training Review Date
March 1, 2016, since latest RMP submission
Maintenance Review Date
Dec. 1, 2015, since latest RMP submission
Maintenance Inspection Date
Dec. 1, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Management of Change Review Date
Pre-startup Review Date
Compliance Audit Date
May 18, 2004
Compliance Audit Change Completion Date
Nov. 30, 2004
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Hot Work Review Date
Contractor Safety Review Date
, since latest RMP submission
Contractor Safety Eval. Date
, since latest RMP submission

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:
March 1, 2016
Local Response Agency:
Local Response Agency Phone:
(337) 463-3281
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

Neale Gas Processing Facility, Merryville, LA 70653



Texas Petroleum Investment Company (TPIC)

Neale Gas Processing Facility

Risk Management Plan

Executive Summary



ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES

TPIC is strongly committed to employee, public and environmental safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the operation and maintenance of our facility's processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, TPIC will utilize trained contract response personnel for emergency response and recovery operations and/or may rely upon local fire department capabilities as well as mutual aid from other local agencies.



DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES

The Neale Gas Processing facility is an unmanned gas processing plant located in Beauregard Parish, near the city of Merryville, Louisiana, off highway 110 on Arco Rd. The plant consists of one Program Level 2 process, which utilizes several operations (e.g., gravity separation, dehydration, compression, cryogenic separation) to extract a natural gas liquid mixture (primarily liquid butane) from produced natural gas. The plant has the capacity to store up to 48,000 gallons of regulated NGL, a regulated flammable substance, in two separate pressure tanks at a maximum pressure of 275 psi. The Neale Gas Processing Facility is classified as a Program 2 process.





GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM

The following is a summary of the accident release prevention program in place at the plant. This summary addresses each of the RMP Program 2 Prevention Program elements and describes the management system in place to implement the program.

Safety information

TPIC keeps a variety of technical documents that are used to help maintain safe operation of the gas p
lant. These documents address chemical properties and associated hazards, limits for key process properties and specific chemical inventories, and equipment design basis/configuration information, including exposure hazards and emergency response/exposure treatment consideration, as provided in safety data sheets (SDSs).

The gas plant also maintains numerous technical documents that provide information about the design and construction of process equipment. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities.

Hazard Review

The hazard review helps TPIC to determine whether we are meeting applicable codes and standards, identify and evaluate the types of potential failures, and focuses our emergency response planning efforts.

Operating Procedures

TPIC maintains written procedures that address various modes of process operations, such as; (1) start-up, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial start-up of a new process. These procedures provide guidance for experienced operators and also provide the basis for training new operators. The information is regularly reviewed and is accessible to operators involved in the processes.

Training

TPIC 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 once every three years, and more frequently as required by regulations.

Contractor services are periodically utilized during periods of increased maintenance or construction activities. Because contractors work on or near process equipment, the gas plant has procedures in place to ensure the contractors (1) perform their work in a safe manner, (2) have appropriate knowledge and skills, (3) are aware of the hazards of their workplace, (4) unders
tand what they should do in the event of an emergency, (5) understand and follow site specific safety rules, and (6) inform gas plant personnel of any hazards that they find during there work. All contractors participate in a comprehensive Contractor Safety and Environmental Management Process that TPIC has implemented and a site-specific orientation provide by TPIC personnel to verify the above. Contract personnel are given a copy of the HSE Field Operations Handbook before starting work. In addition, a job safety analysis is reviewed and or updated or developed by the contractors prior to each maintenance/construction task.

Maintenance

TPIC has well-established practices and procedures for maintaining process equipment. The basic aspects of this program include (1) training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting equipment deficiencies, when identified, and (5) applying quality assurance measures. Qualified personnel carry out maintenance operations with previous training in maintenance practices. Any equipment deficiencies identified by the maintenance checks or hazard analyses are corrected in a safe and timely manner.

Incident Investigations

Note: There have been no offsite releases in the last five years. TPIC has well-established procedures for conducting incident investigations. TPIC will investigate every incident that results in or could reasonably have resulted in a catastrophic release. The goal of the investigation is to determine the facts and develop corrective actions to prevent recurrence of the incident or a similar incident. The investigation team will document its findings, develop recommendations to prevent recurrence, and forward these results to corporate management for resolution. All corrective actions will be tracked to closure and communicated to all applicable employees. Incident investigation reports will be retained for at least five years so that the reports can be revie
wed during future HAs and HA re-validations.



Compliance Audits

To help ensure that the accident prevention program is functioning properly, the Neale Gas Processing facility is periodically audited to determine whether the procedures and practices required by the accident prevention program are being implemented. It is TPIC's policy that an audit should be conducted at the plant on a periodic basis. Both plant operators and management participate as audit team members and forward their findings for resolution. The corrective actions taken in response to the audit team's findings are tracked until they 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 the Neale Gas Processing Facility have hazards that must be managed to ensure continued safe operation. The prevention program summarized previously is applied to all RMP-covered processes at the Neale Gas Processing Facility. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors.

In addition, to the accident prevention program activities, TPIC has safety features on many units to help contain/control a release, quickly detect the release, and reduce the consequences of (mitigate) a release. The following types of safety features are used in various processes.



Release Containment/Control

1. Process relief values that discharge to a flare to capture and incinerate episodic releases.

2. Valves to permit isolation of the process (manual or automated)

3. Automated shutdown systems for specific process parameters (e.g., high temperature)

4. Curbing or diking to contain liquid releases

5. Redundant equipment and instrumentation

6. Atmospheric relief devices



Release Mitigation

1. Fire extinguishing systems

2. Personnel trained in emergency procedures

3. Personal protective equipmen
t



FIVE-YEAR ACCIDENT HISTORY

The Neale Gas Processing Facility has an excellent record of accident prevention. Over the past 5 years there have been no offsite releases, as defined in the regulation.



EMERGENCY RESPONSE PROGRAM INFORMATION

The Neale Gas Processing Facility maintains a written emergency program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address facility/equipment isolation and shutdown, initial first-aid and medical treatment for exposures (i.e., SDS information), evacuation plans for the plant, accounting for plant personnel after an evacuation, notification of local emergency response agencies, and post-incident cleanup/decontamination requirements. Plant personnel receive training in 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 modification to the Plant facilities or emergency equipment are administered through the management of change (MOC) process, which includes informing and/or retraining affected personnel.

The overall emergency response program for the Plant is coordinated with the Beauregard Parish Local Emergency Planning Committee (LEPC), City of Merryville Fire Department. The plant has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations. This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. The plant conducts periodic emergency action drills and provides periodic refreshers to the local emergency response organizations on the hazards associated with the Plant's operations.