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Pelican Gas Plant

Parent Companies:
EnLink Midstream Operating, LP
EPA Facility ID:
100000101212
Other ID:
Facility DUNS:
0
Parent Company DUNS:
878636729

Location:

Address:
3609 Highway 90, Lot No. 1
Patterson, LA 70392
County:
ST. MARY
Lat / Long:
29.692, -91.343 (Get map)
Method:
Interpolation - Photo
Description:
Center of Facility
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1927
Source map scale:
24000

Owner/Operator:

Name:
EnLink Pelican, LLC
Phone:
(214) 953-9500
Address:
1722 Routh Street
Dallas, TX 75201
Foreign Address:

Person responsible for RMP implementation:

Name:
Don Nguyen
Title:
PSM Manager

Emergency contact:

Name:
Richard Calhoun
Title:
Midstream Operations Manager
Phone:
(985) 395-4561
24-hour phone:
(985) 395-4561
Ext or PIN:

Other contacts:

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

Safety:

Local Emergency Planning Committee:
St. Mary Parish LEPC
Full-Time Equivalent Employees:
14
Covered by OSHA PSM:
Yes
EPCRA section 302:
No
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
2660-00072-V2
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Oct. 17, 2011
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Natural Gas Processing
RMP ID:
1000078434
CBI claimed:
No
Program Level:
3
NAICS:
Natural Gas Liquid Extraction (211112)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
510,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Andreu Vivas-Hunt
Address:
415 CR 3502
Bridgeport, TX 76426
Foreign Address:

Phone:
(940) 683-1142

Latest RMP Submission:

Date:
March 13, 2017
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000062523

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 Processing)
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 Processing)
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 Processing, Natural Gas Liquid Extraction (211112)
Prevention Program ID:
1000065899
Safety Review Date
March 24, 2015, since latest RMP submission
PHA Update Date
July 28, 2014, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • Explosion
  • Overpressurization
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • Dikes
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Parameters
  • Process Controls
Training Type
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
Dec. 1, 2016, since latest RMP submission
Training Review Date
March 24, 2015, since latest RMP submission
Maintenance Review Date
March 24, 2015, since latest RMP submission
Maintenance Inspection Date
Dec. 19, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 17, 2016
Management of Change Review Date
March 24, 2015
Pre-startup Review Date
Dec. 5, 2016
Compliance Audit Date
March 24, 2015
Compliance Audit Change Completion Date
July 24, 2015
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
March 24, 2015
Hot Work Review Date
March 24, 2015
Contractor Safety Review Date
March 24, 2015, since latest RMP submission
Contractor Safety Eval. Date
March 24, 2015, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
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:
(985) 395-6161
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
No
Subject To - CWA:
No
Subject To - RCRA:
No
Subject To - OPA:
No
Subject To - State EPCRA:
No
Subject To - Other:

Executive Summary



Executive Summary



The Pelican Gas Plant ("Pelican Plant" or "Facility") utilizes more than the threshold quantity of a "regulated

flammable substance (10,000 pounds)" in the processing of natural gas, where natural gas liquids (NGL) or raw

make are extracted from the inlet gas using cryogenic gas cooling and liquid separation. Therefore, this Facility

is subject to the Risk Management Plan (RMP) requirements codified in Title 40 of the Code of Federal

Regulations Part 68 (40 CFR 68) administered by the U.S. Environmental Protection Agency (EPA).

The Pelican Plant is also subject to Occupational Safety and Health Administration's (OSHA's) Process Safety

Management (PSM) standard (29 CFR 1910.119) and public receptors are located within the worst-case release

scenario for the plant. Therefore, the Pelican Plant is subject to Program 3 requirements as stated in 40 CFR

68.10. OSHA's PSM standard closely parallels requirements outlined in USEPA's RMP Rule. All elements

required by USEPA's 40 CFR 68 - Program 3 Prevention Program are also required by OSHA's PSM.

The Pelican Plant has not had an accidental release of a regulated substance where exposure to the substance, its

reaction products, overpressure generated by an explosion involving the substance, or radiant heat generated by

a fire involving the substance led to any off-site death, injury, or response or restoration activities for an

exposure of an environmental receptor.

The Pelican Plant employs 14 full-time employees on-site who ensure the proper operation and maintenance of

the Facility.

EnLink Midstream Operating, L.P. (EnLink) last submitted a complete RMP 5-year update to the United States

Environmental Protection Agency (USEPA) in February 2012 for the Pelican Plant. The current RMP includes

administrative updates associated with Pelican Plant.



1.1 68.155(a) Accidental Release Prevention and Emergency Response Policies

The Pelican Plant maintains a policy of safe NGL extraction
operations, reducing to the greatest extent possible

hazards associated with the extraction processes, and reducing subsequent risk to the surrounding community,

employees, and the environment.

The Pelican Plant has procedures in place, including both on-site activities and coordination with off-site

responders that are to be followed in the event of an NGL release.



1.2 68.155(b) Stationary Source and Regulated Substances Handled

The Pelican Plant processes NGL in various aboveground vessels and associated piping and valves. NGL is a

regulated flammable mixture that is an aliphatic and aromatic hydrocarbon mixture. The regulated flammable

chemicals contained in the NGL mixture include methane, ethane, propane, isobutane, N-butane, isopentane,

and N-pentane. The maximum inventory of NGL at the Facility at any given time is 130,304 gallons (510,766

Ibs). The largest vessel containing NGL at the Facility is 68,000 gallons (266,546 Ibs).

1.3 68.155(d) General Accidental Release Prevention Program and Chemical-specific Prevention Steps

The Pelican Plant maintains a consistent accidental release prevention program to eliminate or minimize releases

of NGL or propane. As previously indicated, the Prevention Program required under 40 CFR 68 is identical to

the prevention program required under OSHA's PSM. The Pelican Plants Prevention Program 3 elements, as

required under 40 CFR 68 Subpart D, are included in the Facility's PSM Plan, which is kept on-site as a separate

document. Required elements include:

Employee Participation

?h Process Safety Information

?h Process Hazard Analysis

?h Operating Procedures

?h Training

?h Contractors

?h Pre-startup Review

?h Mechanical Integrity

?h Hot Work Permits

?h Management of Change

?h Incident Investigation

?h Compliance Audits



1.4 68.155(e) Five-Year Accident History

The Pelican Plant has had no accidental releases of flammable materials regulated under the RMP program that

resulted in deaths, inj
uries, or significant property damage on-site, or off-site deaths, injuries, evacuations,

sheltering in place, property damage or any environmental impact for the period of five (5) years prior to

February 2017.



1.5 68.155(f) Emergency Response Program

The Emergency Response Program requirements for Program 3 Facilities are very similar to those required

under the PSM rule. The Emergency Response Program required under the RMP and PSM Rules must be site specific

and comprehensive, including the following elements:

?h Public and emergency response agency notification procedures

?h Proper first aid and emergency medical treatment

?h Emergency response measures

?h Procedures for inspecting, testing, and maintaining emergency response equipment

?h Employee training

?h Program review procedures

The Pelican Plant maintains written Emergency Shutdown and Startup Procedures (ESSP) that provide guidance

for emergencies expected at the Facility. Further safety information is also detailed in the ESSP. In addition,

operating procedures and equipment design codes and standards associated with the operations at the Facility

are maintained. Furthermore, the Facility has coordinated the emergency response plan with the St. Mary Parish

Local Emergency Planning Committee (LEPC) and the Patterson Fire Department. The Patterson Fire

Department is designated as the first responder in the event of NGL release. For these reasons, the Pelican Plant

meets the exceptions listed in 40 CFR 68.90(b). Note that Pelican plant is "non-responding" facility.

A site map and SDSs for the chemicals kept on-site are maintained on the company's intranet. Complete details

on the Emergency Response Program required under the PSM Rules are included in the Pelican Plant's PSM

Plan, which is kept on-site as a separate document.



68.155(g) Safety Improvements

EnLink has a continued commitment to update equipment and improve safety pertaining to the covered process

when necessary. T
he most recent Process Hazard Analysis for the Facility was completed on July 28, 2014, at

which time several safety improvements were recommended. EnLink completed these recommendations on

January 1, 2015.