Blue Water Gas Plant
Morse, LA 70559
Dallas, TX 75201
Person responsible for RMP implementation:
Latest RMP Submission:
2. Toxics: Worst-case
3. Toxics: Alternative release
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:
- Names of the chemicals in the Off-Site Consequence Analysis
- Amount of chemical released
- Rate of chemical release
- Radius of affected area
- Vulnerable areas affected
- Count of affected population
- Maps or other optionally provided supplementary material
Instructions on how to make an EPA appointment can be found here.
- Blast walls
5. Flammables: Alternative release
6. Five-year accident history
7. Prevention: Program level 3
8. Prevention Program level 2
9. Emergency response
Accidental Release Prevention and Response Policies
The Crosstex Processing Services, LLC (Crosstex Processing Services) Blue Water 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 response organizations arrive. Additional details are included in the other section of this RMP Plan.
Description of the Stationary Source and Regulated Substances
The Blue Water Gas Plant, located 3 miles east of Morse, Louisiana, consists of one Program Level 1 process which 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. The facility could contain regulated flammables (e.g. mixtures containing methane, ethane, propane, butane, isobutane, pentane, and iso-pentane), but no regulated toxic inventories, in excess of the threshold quantities established in the regulation. All transportation of regulated flammables into and out of the facility is handled via pipelines. The adjacent tank farm operation handles condensate and lube oil and is not considered part of the stationary source??A?s covered process. The plant is located in a rural area and is surrounded by farmland.
Offsite Consequence Analysis Results
Worst Case Scenario (WCS) and Alternate Release Scenario (ARS)
Specifics concerning Offsite Consequence Analyses are contained in the RMP Plan Data Element Sections 4 and 5.
General Accidental Release Prevention Program
The following is a summary of t
he accident prevention program in place at the Blue Water Gas Plant. Because processes at the plant regulated by EPA??A?s Risk Management Program (RMP) regulation are also subject to OSHA??A?s Process Safety Management (PSM) standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program.
The plant provides for and encourages employees to participate in all aspects of 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 all information related to the accident prevention program. Specific ways that employees can be involved in the accident prevention program is detailed in an Employee Participation Plan that is maintained at the plant and addresses each program element. In addition, the 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)
The plant keeps a variety of technical documents that are used to help maintain safe operation of the facility. These documents address chemical properties and associated hazards, safe operating limits for key process parameters, specific chemical inventories, and equipment design basis/configuration information.
Chemical-specific information (including exposure hazards, emergency response, and exposure treatment considerations) is provided in material safety data sheets. For specific process areas, the plant has documented safety-related operating limits for process parameters (e.g. temperature, pressure, level) in the operating procedures. The 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).
The 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)
The 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 facility utilized a knowledge-based PHA Revalidation incorporating a What/If Checklist, an industry-accepted hazard evaluation technique for PSM-covered processes. The analyses are conducted using a team of Plant operating/maintenance personnel and 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 personnel, operations personnel, and management. Operating personnel are also involved in the evaluation of resolution options. Implementation of the resolutions is prioritized for accomplishment based on a relative risk. All resolution plans are tracked until completed. The final resolution of each finding is documented and retained.
To help ensure the process controls and/or hazards do not eventually deviate significantly from the original design, the p
lant 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??A?s finding are forwarded to management to coordinate further evaluation and resolution, and the final resolution of findings are documented and retained.
The 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. Procedures are maintained current/accurate by revising them as necessary to reflect changes made through the management of change process.
To complement the written operating procedures, the plant has implemented a comprehensive training program for all employees involved in operating process equipment. New employees receive basic training in plant operations (e.g., process overview, applicable procedure reviews, etc.). New operators are then paired with experienced operators (i.e., subject matter experts) 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 perfom the duties and tasks in a safe manner on their own, they are certified and allowed to work independently. In addition, all 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 for each emp
The plant uses contractors to supplement its workforce during periods of increased maintenance or construction activity. Because some contractors work on or near process equipment, the plant has procedures in place to help ensure contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in the workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow safety rules, (6) inform plant personnel of any hazards they find during their work. This is accomplished by providing contractors an orientation prior to their working in the plant which includes (1) process overview, (2) information about safety and health hazards, (3) applicable emergency provisions, and (4) information on safe work practices. Also, a job safety analysis is reviewed/updated or developed by the contractors (with plant 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/performance are evaluated during the initial selection process, and the plant supervisor conducts periodic evaluations of safety performance.
Pre-Startup Safety Reviews (PSSR)
The plant conducts a PSSR for any facility modification that requires a significant change 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 one additional check to make sure that construction is in accordance with the design specifications and all 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.
nical Integrity (MI)
The 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 (1) training, (2) written procedures, (3) inspection/tests, (4) correction of identified deficiencies, and (5) quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process. Maintenance personnel receive training on the (1) process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency plans, and (5) 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. The 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
The 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 equi
pment 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, job safety analyses 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)
The plant has a comprehensive system to manage changes. This system requires that changes to process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to ensure adequate controls are in place to manage any new hazards and 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 any necessary training related to the changes.
The plant promptly investigates all 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 action taken in response to the investigation team??A?s findings is tracked until completed. The final resolution of each finding is documented, and investiga
tion results are reviewed with all 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.
To help ensure that the accident prevention program is functioning properly, the Blue Water Gas plant periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. Both hourly and staff personnel participate as audit team members. The audit team develops findings that are forwarded to facility 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 the two most recent audit reports are retained.
Chemical-Specific Prevention Steps
The processes at the 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 (i.e., flammables) in the facility.
Universal Prevention Activities
The accident prevention program summarized previously is applied to the RMP-covered process at the plant. These prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors.
The Blue Water Gas Plant has safety features on many units to (1) quickly detect a release, (2) contain/control a release, and (3) reduce/mitigate the consequences of a release. The following types of safety features are used:
Hydrocarbon gas detectors near gas turbines
Hydrocarbon gas detectors/alarms near product shipping pumps
Hydrocarbon gas detectors/alarms near expander separator
UV fire detectors/shutdown near gas turbines/comp
Pressure/thermal relief valves and rupture disks that discharge into a flare system for incineration
Manual/automatic isolation valves
Automated shutdown systems for specific process parameter (e.g., pressure, high level, etc.)
Redundant equipment and instrumentation (e.g., dual relief valves, backup firewater pump, etc.)
Fire extinguishing systems (e.g., fire monitors/hoses, portable fire extinguishers)
Personal protective equipment
Five Year Accident History
The 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
The plant maintains a written emergency action program to protect the workers, public, and environment. The program consists of procedures for responding to releases of regulated substances (i.e., flammables) including the possibility of fires or explosions. The procedures address facility/equipment isolation and shutdown, proper first-aid and medical treatment for exposures (i.e., Material Safety Data Sheets information), evacuation plans for the plant and accounting for plant personnel after an evacuation, notification of local emergency response agencies, and post-incident cleanup/decontamination requirements. In addition, the plant has procedures that address the maintenance, inspection, and testing of emergency response equipment and alarms. Plant personnel receive training in these procedures as necessary to perform their specific emergency action duties.
The emergency action program is reviewed and updated when necessary. Changes required because of modifications to the plant facilities or emergency equipment are administered through the Management of Change process which includes informing and/or training affected personnel.
The overall emergency response program for the plant is coordinated with the Acadia Parish Local Emergency Planning C
ommittee (LEPC), Morse and Estherwood Fire Departments, Acadia Parish Sheriff??A?s Department and the local ambulance services. The plant has around the clock communications capability with these 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 assisting with the 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.