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Henry Gas Processing Complex

Parent Companies:
Texaco Pipelines LLC
ChevronTexaco Inc
EPA Facility ID:
100000109866
Other ID:
LAD062639596
Facility DUNS:
957883960
Parent Company #1 DUNS:
128287328
Parent Company #2 DUNS:
1382555

Location:

Address:
5624 Aristide Road
Erath, LA 70533
County:
VERMILION
Lat / Long:
29.898, -92.066 (Get map)
Method:
Interpolation - Photo
Description:
Administrative Building
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Texaco Pipelines LLC
Phone:
(337) 937-5846
Address:
5624 Aristide Road
Erath, LA 70533 -5930
Foreign Address:

Person responsible for RMP implementation:

Name:
William Wied
Title:
Team Leader - Henry Complex
Email:

Emergency contact:

Name:
William Wied
Title:
Team Leader - Henry Complex
Phone:
(337) 937-3351
24-hour phone:
(337) 319-6972
Ext or PIN:

Other contacts:

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

Safety:

Local Emergency Planning Committee:
Vermilion Parish LEPC
Full-Time Equivalent Employees:
26
Covered by OSHA PSM:
Yes
EPCRA section 302:
No
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
2940-00011-V0
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Nov. 19, 2003
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Henry Product Storage
RMP ID:
51965
CBI claimed:
No
Program Level:
3
NAICS:
Natural Gas Liquid Extraction (211112)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
4,221,108
No
Public OCA Chemical
0
No
Henry Gas Processing Area
RMP ID:
51966
CBI claimed:
No
Program Level:
3
NAICS:
Natural Gas Liquid Extraction (211112)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
363,207
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
June 22, 2004
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
No
RMP ID:
36053

Deregistration:

Date:
Effective Date:
Reason:
Source reduced inventory of all regulated substances below TQs
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 Henry Product Storage)
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 Henry Product Storage)
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

Henry Product Storage, Natural Gas Liquid Extraction (211112)
Prevention Program ID:
29914
Safety Review Date
Sept. 25, 2003, since latest RMP submission
PHA Update Date
Aug. 18, 2003, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Equipment failure
  • Cooling loss
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Backup Pump
  • Grounding Equipment
  • Excess Flow Device
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • None
Procedure Review Date
Sept. 25, 2003, since latest RMP submission
Training Review Date
Sept. 25, 2003, since latest RMP submission
Maintenance Review Date
Sept. 25, 2003, since latest RMP submission
Maintenance Inspection Date
Nov. 21, 2003, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
March 2, 2004
Management of Change Review Date
Nov. 3, 2003
Pre-startup Review Date
March 2, 2004
Compliance Audit Date
Sept. 25, 2003
Compliance Audit Change Completion Date
Oct. 5, 2004
Incident Investigation Date
May 21, 1997
Incident Invest. Change Completion Date
Jan. 1, 1998
Participation Plan Review Date
Sept. 25, 2003
Hot Work Review Date
Sept. 25, 2003
Contractor Safety Review Date
Sept. 25, 2003, since latest RMP submission
Contractor Safety Eval. Date
Sept. 10, 2003, 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:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
July 29, 2003
Local Response Agency:
Local Response Agency Phone:
(377) 893-1234
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

Executive Summary

LaDEQ Henry Gas Processing Complex ID No. 615

ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES

The Henry Complex has a long-standing commitment to worker and public safety. This commitment is demonstrated by our efforts in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, Henry Complex trained personnel will evaluate the situation, take actions within the capabilities of the Henry Complex, and/or notify the necessary outside agencies.

DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES

The Henry Complex consists of two processes, Henry Processing / Natural Gas Liquid (NGL) Fractionation Area and Henry Product Storage Area. The Complex location is 5624 Aristide Road near Henry, Louisiana.

In it?s current modes of operation the Henry Processing / NGL Fractionation Area is no longer processing gas and/or NGL fractionation, and the Henry Product Storage Area is being used for limited propane product storage. There are no immediate plans to return either of these processes to their original full operational service. In its current state, the Henry Processing / NGL Fractionation Area provides (1) condensate/free liquid removal and dehydration of natural gas prior to re-delivery to transmission pipeline systems, and (2) Y-grade NGL product handling and delivery services into NGL transmission pipeline systems. Additional equipment in these processes are either completely empty or under a methane gas blanket.

GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM

The following is a summary of the accident prevention program in place at the Henry Complex. The above referenced processes at the Henry Complex are regulated by both the Environmental Protection Agency's (EPA's) risk managemen
t program (RMP) rule and the Occupational Safety and Health Administration's (OSHA's) process safety management (PSM) standard. Because RMP accident prevention requirements for these processes are essentially the same as PSM, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program at the Henry Complex.

Employee Participation

The Henry Complex encourages employees to participate in all facets of process safety management and accident prevention, including process hazard analyses, incident investigations, and the development of operating and maintenance procedures. Employees also participate in safety meetings, resolving certain safety concerns, and updating and compiling technical documents and chemical information pertaining to the process and critical equipment.

Employees have access to all information created as part of the Henry Complex's accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in a written employee participation plan that is maintained at the Henry Complex. This employee participation plan addresses each accident prevention program element.

In addition, the Henry Complex has a number of initiatives under way which address process safety and employee safety issues. These initiatives include forming teams to promote both process and personal safety. The teams typically have members from various areas of the Henry Complex, including operations, maintenance, engineering, and Henry Complex management.

The Henry Complex also utilizes a Behavior Based Safety and Loss Prevention System that provides for observation and critique of job task to modify any unsafe behaviors prior to incidents occurring. The Henry Complex also uses this system to develop and document Job Safety Analyses (JSA) for various job tasks and to track and communicate near loss and actual loss re
lated to personnel losses, operational losses and financial losses.

Process Safety Information

The Henry Complex keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address: chemical properties and associated hazards; limits for key process parameters and specific inventories; safety interlocks; suppression systems; vent and relief studies; and equipment design basis/configuration information.

Chemical-specific information, including exposure hazards and emergency response/ exposure treatment considerations, is provided in material safety data sheets (MSDS). For specific process areas, the Henry Complex has documented safety-related limits for specific process parameters (e.g., temperature, level, flow, composition) in the equipment specifications and operating procedures. The Henry Complex maintains the process within these limits by using process controls and monitoring instruments, trained personnel, and protective instrument systems (e.g., automated shutdown systems).

The Henry Complex also maintains technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, and electrical rating of equipment. This information, in combination with procedures and equipment operating history, provides a basis for inspection and maintenance activities, as well as for evaluating proposed process and facility changes so safety features in the process are not compromised.

Process Hazard Analysis (PHA)

The Henry Complex has a comprehensive program to identify and control hazards associated with the various processes that are identified and controlled. Within this program, each process is systematically examined to identify potential hazards and controls in place to manage these hazards, and recommend additional controls, as appropriate.

The He
nry Complex uses a variety and combination of applicable methodologies to conduct PHAs. These PHAs address (1) facility siting, (2) human factors, (3) qualitative evaluation of a range of the possible safety and health effects of failure of controls on personnel, and (4) one or more of the following methodologies appropriate to determine and evaluate the hazards of the process, (a) What-if, (b) Checklist, ? Hazard and Operability (HAZOP), (d) Failure Mode and Effects Analysis (FMEA), (e) Fault Tree Analysis, and/or (f) an appropriate equivalent methodology.

PHAs are conducted using a team of people who have the appropriate operating and maintenance experience for the process, as well as engineering expertise. This PHA team identifies and evaluates potential hazards of the process, as well as accident prevention and mitigation measures, and then makes recommendations for additional prevention and/or mitigation measures.

The PHA team recommendations are forwarded to local management for resolution. Implementation of additional prevention and/or mitigation options in response to PHA recommendations is based on a relative priority ranking assigned by the PHA team. The approved mitigation options in response to PHA team recommendations are tracked until they are completed. The final resolution of each recommendation is documented and retained.

The Henry Complex periodically revalidates these PHAs. These PHAs are revalidated at least every 5 years, and will be conducted at this frequency until the process no longer contains hazardous chemicals above the threshold quantities. The recommendations from these revalidated PHAs are also forwarded to management for consideration, and the final resolution of each revalidated PHA recommendation is documented and retained.

Operating Procedures

The Henry Complex maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) tem
porary operations, (4) emergency shutdown, (5) normal shutdown, (6) out of service (shutdown) mode, and (7) initial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. These procedures are periodically reviewed and annually certified as current and accurate. In addition, the Henry Complex maintains information on how to respond to upper or lower limit exceedances for specific process or equipment parameters. This information, along with written operating procedures, is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks.

Training

To complement the written procedures for process operations, the Henry Complex has implemented a comprehensive training program for employees involved in operating a process. New operational employees receive training on the Henry Complex's Operating Procedures, and basic training in process operations if they are not already familiar with such operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every 3 years, or more frequently upon request. All of this training is documented for each operator, including skills demonstration used to verify that the operator understood the training. Process maintenance personnel are trained in their perspective duties for maintaining the mechanical integrity of critical process equipment and systems. Operational and maintenance personnel also receive training o
n the procedures for conducting hot work permitting; lockout/tagout, management of change; and other appropriate safe work practices.

Contractors

The Henry Complex uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the Henry Complex has procedures in place to verify that contractors perform their work in a safe manner. These contractor safety procedures include steps to verify contractors (1) have the appropriate knowledge and skills to perform their jobs safely, (2) are aware of the hazards in their workplace, (3) understand what they should do in the event of an emergency, (4) understand and follow site safety rules and (5) inform facility personnel of any potential hazards that they introduce or find during their work. Contractors working within the Henry Complex are provided with (1) a process overview, (2) information about safety and health hazards, (3) emergency procedure requirements, and (4) site-specific applicable safe work practices prior to their beginning work. In addition, the Henry Complex evaluates contractor safety programs and performance prior to selection of a contractor. Henry Complex personnel periodically monitor contractor performance with respect to their safety obligations, and provide contractors with applicable safety performance feedback.

Pre-startup Safety Reviews (PSSRs)

The Henry Complex conducts a PSSR for any new facility or facility modification that requires a change in the process safety information. The purpose of the PSSR is to see that safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check that construction is in accordance with the design specifications and required safety systems are operationally ready. A PSSR also verifies that appropriate safety, opera
tional and maintenance procedures are in place, and adequate training has been provided to the appropriate personnel. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. When new facilities are commissioned, a PHA is included in the PSSR.

Mechanical Integrity

The Henry Complex has established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) utilization of appropriately trained maintenance personnel, (2) developing written procedures, and (3) performing inspections and tests, and correcting identified deficiencies. In combination, these activities form a system that maintains the mechanical integrity of the process.

Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency procedures, and (5) applicable safe work practices to help ensure that they can perform their jobs in a safe manner. Written inspection, testing and maintenance procedures provide that work is performed in a consistent manner, and serve as a basis for training maintenance personnel in their relative assigned duties. Inspections and tests are performed to help verify equipment functions as intended and that equipment is within acceptable limits. If a deficiency is identified that presents an immediate safety concern, Henry Complex personnel will correct the defect before placing the equipment back into service.

Safe Work Practices

The Henry Complex has long-standing safe work practices in place to help provide worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout
procedure to isolate energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous substances before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to verify that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help perform operations and maintenance activities safely.

Management of Change

The Henry Complex has a comprehensive system to manage changes to all covered processes. This system requires that changes to items such as process equipment, chemicals, technology (including operating conditions of the process), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) determine that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, equipment information, and operating procedures are updated prior to incorporating these changes. In addition, operating and maintenance personnel and affected contractors are provided any necessary training on the change.

Incident Investigation

The Henry Complex promptly investigates all incidents related to a covered process that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the factors that may have led to the incident, and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its recommendations to prevent a recurrence, and forwards these results to Henry Complex management for resolution. Corrective actions taken in res
ponse to the investigation team's recommendations are tracked until they are complete. The final resolution of each recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the recommendations. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future and revalidated PHAs.

Compliance Audits

To help determine that the accident prevention program is functioning properly, the Henry Complex 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. Personnel familiar with the facility and Process Safety Management participate in these audits. The audit team develops findings that are forwarded to Henry Complex 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 Henry Complex have potential hazards that are managed for continued safe operation. The following is a description of current safety features applicable to prevention of accidental releases of regulated substances in the facility.

Universal Prevention Activities

Henry Complex's previously summarized accident prevention program is applied to RMP-covered processes at the Henry Complex. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors.

Specialized Safety Features

The Henry Complex has safety features to provide a means of containing /controlling a release, detecting a release, and reducing the consequences of (mitigate) a release. The following types of s
afety features are used in the covered processes:

Monitoring and detection systems include (1) Hydrocarbon gas detectors to detect the presence of hydrocarbons, (2) Operations personnel on site 24 hours per day providing routine surveillance, (3) Camera surveillance of the process areas from the Control Room, and camera surveillance to the Complex perimeter from an on site security monitoring center. (4) Audible and visual warning alarms, and (5) Distributed Control System (DCS) on some processes providing real-time monitoring and control.

Containment and process controls include (1) Relief devices to avoid overpressure of process equipment, (2) Flare system to capture and incinerate episodic releases, (3) Valves to permit process control or isolation (manual or automated), (4) Interlocks and automated shutdown systems for specific process parameters (e.g., high temperature, pressure, level, etc.), (5) Curbing or diking for spill prevention and control, and (6) Redundant equipment and instrumentation (e.g., uninterruptible power supply for DCS).

Active and passive mitigation systems include (1) Fire suppression and extinguishing systems, (2) Emergency procedures to react to emergencies, (3) The Henry Complex has completed several steps to improve the security at the facility, by implementing an integrated site security plan covering these areas:
A) Upgraded access control features
B) Taken step to decrease the attractiveness to criminals
C) Enhanced liaison activities with law enforcement agencies
D) Improved employee security awareness
E) Evaluated resistance to criminal intrusion, and (4) Communications link with local emergency planning committee (LEPC).

Release mitigation systems include (1) Fire suppression and extinguishing, (2) Coordination with emergency response personnel, and (3) Personal protective equipment (e.g., fire retardant clothing).

FIVE-YEAR ACCIDENT HISTORY

The Henry Complex has an excellent record of acci
dent prevention over the past 5 years. The following table is a summary showing we have had no RMP incidents that have occurred during the past 5 years.

1999 2000 2001 2002 2003
Number of RMP Events with Onsite Effects 0 0 0 0 0
Number of RMP Events with Offsite Effects 0 0 0 0 0


EMERGENCY RESPONSE PROGRAM INFORMATION

The Henry Complex maintains a written emergency response and action plan, which is in place to help protect worker and public safety as well as the environment. The plan identifies steps to be taken in case of an accidental release including: proper first aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies, and responding to small fires and other emergencies. Employees receive training in these procedures as necessary to perform their specific emergency duties. This plan is updated when necessary based on modifications made to the Henry Complex.

The overall emergency response program for the Henry Complex has been coordinated with the Henry Volunteer Fire Department. The Henry Complex is manned 24 hours a day and has around-the-clock communications capability with the Henry Volunteer Fire Department, the Vermilion Parish Office of Emergency Preparedness, the Vermilion Parish Sheriff Department, and the Louisiana State Police. This interface provides the means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident.

PLANNED CHANGES TO IMPROVE SAFETY

The Henry Complex has completed all of the planned changes for the improvement of safety as indicated in our initial submission, these changes included: (1) Significantly reducing total inventories of flammable chemicals, (2) Installation of a 5
0,000 barrel fire water storage tank, (3) Replacement of the existing firewater pumps with pressure demand auto-start diesel driven firewater pumps, (4) Replacement of the plant air compressors to increase instrument air pressure and capacity, (5) Replacement of flood-pit pumps, (6) Demolition and removal of steam boilers, sponge oil furnace and associated piping containing hazardous materials, (7) Installation of concrete containment systems around pumps, equipment and storage vessels to contain potential hazardous liquid spills, and (8) Installation of flare stack continuous monitoring system.