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Mermentau Facility

Parent Companies:
EnLink Midstream Operating, LP
EPA Facility ID:
100000122422
Other ID:
Facility DUNS:
0
Parent Company DUNS:
29514077

Location:

Address:
11265 Cambell Wells Road
Jennings, LA 70546
County:
JEFFERSON DAVIS
Lat / Long:
30.204, -92.595 (Get map)
Method:
Interpolation - Photo
Description:
Center of Facility
Horizonal accuracy:
25 m
Horizontal reference datum:
World Geodetic System of 1984
Source map scale:
24000

Owner/Operator:

Name:
EnLink Processing Services, LLC
Phone:
(214) 953-9500
Address:
1722 Routh St Suite 1300
Dallas, TX 75201
Foreign Address:

Person responsible for RMP implementation:

Name:
Don Nguyen
Title:
PSM Manager

Emergency contact:

Name:
Sean Manuel
Title:
Plant Superintendent
Phone:
(214) 721-3749
24-hour phone:
(337) 580-2458
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(214) 721-9271
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Jefferson Davis Parish LEPC
Full-Time Equivalent Employees:
0
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
March 26, 2014
Inspecting Agency:
U.S. Coast Guard
Using Predictive Filing:
No

Processes:

Nat. Gas Product Storage
RMP ID:
1000048619
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Bulk Stations and Terminals (42471)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
7,100,000
No
Flammable Mixture
00-11-11
7,100,000
No
Flammable Mixture
00-11-11
23,000,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Nick Kellam
Address:
1722 Ruth St Suite 1300
Suite 100
Dallas, TX 75201
Foreign Address:

Phone:
(469) 644-8662

Latest RMP Submission:

Date:
April 25, 2014
Type:
Resubmission
Reason:
Revised OCA due to change (40 CFR 68.190(b)(6))
Registered:
Yes
RMP ID:
1000039528

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 Nat. Gas 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 Nat. Gas 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

Nat. Gas Product Storage, Petroleum Bulk Stations and Terminals (42471)
Prevention Program ID:
1000042123
Safety Review Date
Dec. 12, 2012, since latest RMP submission
PHA Update Date
Dec. 12, 2012, since latest RMP submission
PHA Techniques
  • Checklist
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Earthquake
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Nov. 25, 2013, since latest RMP submission
Training Review Date
Dec. 1, 2013, since latest RMP submission
Maintenance Review Date
Dec. 1, 2013, since latest RMP submission
Maintenance Inspection Date
July 23, 2013, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 6, 2013
Management of Change Review Date
Feb. 21, 2014
Pre-startup Review Date
Dec. 6, 2013
Compliance Audit Date
Feb. 21, 2014
Compliance Audit Change Completion Date
March 15, 2015
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Feb. 21, 2014
Hot Work Review Date
Feb. 21, 2014
Contractor Safety Review Date
Feb. 21, 2014, since latest RMP submission
Contractor Safety Eval. Date
Feb. 21, 2014, 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:
Oct. 9, 2013
Local Response Agency:
Local Response Agency Phone:
(337) 821-5508
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
No
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

The EnLink Midstream Operating, LP (EnLink) Mermentau Facility (the Facility) utilizes more than the threshold quantity of a "regulated flammable substance (10,000 pounds)" in the storage and loading of natural gas, where natural gasoline and butanes are received via pipeline and off-loaded via barge. 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 Mermentau Facility 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 Mermentau Facility is subject to Preventative 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 Mermentau Facility 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 Mermentau Facility does not have permanent full-time employees on-site.



The Mermentau Facility was taken out of service in 2008 and placed back into service in March 2010. The most recent RMP reinstatement and recertification was completed in June 2012. The Facility added an additional natural gasoline tank, which increased the Facility storage capacity and triggered this RMP revision. A Process Hazard Analysis was completed for the process revisions in December 2012, and the new tank was brought online in December 20
13. The following information serves as a complete RMP 5-year recertification.



ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES



The Mermentau Facility maintains a policy of safe natural gasoline and butane handling operations, reducing to the greatest extent possible hazards associated with the handling of flammable materials, and reducing subsequent risk to the surrounding community, employees, and the environment.



The Mermentau Facility has procedures in place, including both on-site activities and coordination with off-site responders that are to be followed in the event of a butane or natural gasoline release.



DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES



The Mermentau Facility receives natural gasoline, n-Butane and isobutane via pipeline for storage and subsequent off-loading via barge. Although the current facility Material Safety Data Sheet for natural gasoline lists it as a National Fire Protection Agency (NFPA) Class 3 flammable; subsequent testing completed by EnLink demonstrates that the mixture would, at times, be considered an NFPA Class 4 flammable based upon the flash point and boiling point of the mixture. As such, EnLink has chosen to include natural gasoline in the RMP-regulated inventory at the Facility. Natural gasoline may include the following RMP-regulated flammable substances: isopentane and n-pentane. The maximum inventory of natural gasoline at the Facility at any given time is 4,252,500 gallons (23,067,452 lbs). The largest vessel that stores natural gasoline has a capacity of 2,520,000 gallons (13,669,601 lbs).



The Mermentau Facility also receives n-butane and/or isobutane, which are regulated flammable mixtures. N-Butane is a flammable mixture that contains n-butane, pentane and isobutane; and isobutene is a flammable mixture that contains isobutane, n-butane and propane. N-butane and/or isobutane are stored interchangeably in one of three pressurized vessels. The maximum inventory of n-
butane or isobutane at the Facility at any given time is 1,417,500 gallons (7,111,873 lbs). The largest vessel containing either n-butane or isobutane at the Facility has a capacity of 472,500 gallons (2,370,624 lbs).



GENERAL ACCIDENT RELEASE PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS



The Mermentau Facility maintains a consistent accidental release prevention program to eliminate or minimize releases of n-butane, isobutane and natural gasoline. As previously indicated, the Prevention Program required under 40 CFR 68 is identical to the prevention program required under OSHA's PSM. The Mermentau Facility's 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;

? Process Safety Information;

? Process Hazard Analysis;

? Operating Procedures;

? Training;

? Contractors;

? Pre-startup Review;

? Mechanical Integrity;

? Hot Work Permits;

? Management of Change;

? Incident Investigation; and

? Compliance Audits.



FIVE YEAR ACCIDENT HISTORY



The Mermentau Facility has had no accidental releases of flammable materials regulated under the RMP program that resulted in deaths, injuries, 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 April 2014.



EMERGENCY RESPONSE PROGRAM INFORMATION



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:



? Public and emergency response agency notification procedures;

? Proper first aid and emergency medical treatment;

? Emergency response measures;

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

? Employee training; and

? Program review procedures.



The Mermentau Facility maintains an Emergency Response Plan (ERP) as described in 40 CFR 68.95 that provides guidance for emergencies expected at the Facility. 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 ERP with the Jefferson Davis Parish Local Emergency Planning Committee (LEPC) and the Jennings Fire Department. The Jennings Fire Department is designated as the first responder in the event of n-butane, isobutane and/or natural gasoline release.



A site map, MSDSs, and a list of chemicals kept on-site are maintained at the Facility. Complete details on the Emergency Response Program required under the PSM rule are included in the Mermentau Facility's PSM Plan, which is kept on-site as a separate document.



SAFETY IMPROVEMENTS



EnLink has a continued commitment to update equipment and improve safety pertaining to the covered process when necessary. The most recent PHA for the Facility was completed on December 12, 2012 at which time several safety improvements were recommended including updating inspection procedures, improved labeling of propane tanks, upgrades to transfer hoses, and updates to Piping and Instrumentation Diagrams (P&IDs). The process for which this PHA was completed was brought online in December 2013.