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Sabine Pass Plant

Parent Companies:
Sabine Pass Plant Facility Joint Venture
EPA Facility ID:
100000122538
Other ID:
Facility DUNS:
878636729
Parent Company DUNS:
0

Location:

Address:
5579 Gulf Beach Hwy
Johnsons Bayou, LA 70631
County:
CAMERON
Lat / Long:
29.756, -93.645 (Get map)
Method:
Interpolation - Map
Description:
Center of Facility
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1927
Source map scale:
24000

Owner/Operator:

Name:
Crosstex Sabine Pass Plant Facility
Phone:
(214) 953-9500
Address:
2501 Cedar Springs Road, Suite 100
Dallas, TX 75201
Foreign Address:

Person responsible for RMP implementation:

Name:
Edwin Cormier
Title:
Plant Supervisor

Emergency contact:

Name:
Edwin Cormier
Title:
Plant Supervisor
Phone:
(337) 432-6881
24-hour phone:
(337) 432-6881
Ext or PIN:
270

Other contacts:

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

Safety:

Local Emergency Planning Committee:
Cameron Parish LEPC
Full-Time Equivalent Employees:
7
Covered by OSHA PSM:
Yes
EPCRA section 302:
No
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
0560-00043-V3
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
April 15, 2005
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Unspecified process
RMP ID:
1000009130
CBI claimed:
No
Program Level:
3
NAICS:
Natural Gas Liquid Extraction (211112)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
120,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
June 18, 2009
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
No
RMP ID:
1000007899

Deregistration:

Date:
Effective Date:
Reason:
Source terminated operations
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 Unspecified process)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
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 Unspecified process)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
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 Liquid Extraction (211112)
Prevention Program ID:
1000007443
Safety Review Date
Sept. 21, 2006, since latest RMP submission
PHA Update Date
Feb. 25, 2008, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Floods
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Grounding Equipment
  • Rupture Disks
Mitigation Systems
  • Dikes
  • Enclosure
Monitoring Systems
  • Process Area
Changes since PHA
  • None Recommended
Training Type
  • Classrom
Competency Testing
  • Written Test
Procedure Review Date
Dec. 15, 2008, since latest RMP submission
Training Review Date
Dec. 15, 2008, since latest RMP submission
Maintenance Review Date
Dec. 15, 2008, since latest RMP submission
Maintenance Inspection Date
April 15, 2009, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Sept. 1, 2008
Management of Change Review Date
March 14, 2007
Pre-startup Review Date
Dec. 15, 2008
Compliance Audit Date
July 9, 2008
Compliance Audit Change Completion Date
July 31, 2009
Incident Investigation Date
April 14, 2008
Incident Invest. Change Completion Date
July 15, 2008
Participation Plan Review Date
May 26, 2009
Hot Work Review Date
April 30, 2009
Contractor Safety Review Date
Feb. 20, 2009, since latest RMP submission
Contractor Safety Eval. Date
May 13, 2009, 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:
Nov. 15, 2008
Local Response Agency:
Local Response Agency Phone:
(318) 496-4451
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
No
Subject To - Other:

Executive Summary

ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES

The Sabine Pass Natural Gas Demethanizer Plant (the Plant), located near the town of Cameron in Cameron Parish, Louisiana, has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as personnel training and safe design, installation, operation, and maintenance of facilityA?s processes. The Company policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release should occur, trained personnel will respond to, control and contain the release.

DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES

Natural gas entering the plant via pipelines is separated from any free liquids, dehydrated by molecular sieves and cooled in the gas-to-gas heat exchanger (Stationary Source). Inlet gas is further cooled through the turbo expander and fed to the demethanizer (Stationary Source). The resulting natural gas liquid extracted from the inlet gas referred to as A?Y-gradeA? (Regulated Substance) is pumped from the surge tank (Stationary Source) and is shipped from the plant via a transmission pipeline. The methane (referred to as residue gas) is shipped from the plant via a transmission pipeline as well. Transmission pipelines are not stationary sources for purposes of the RMP.

The substances handled at the Plant were evaluated for toxic characteristics and it was determined that there are no toxic substances exceeding the threshold quantity handled at the Plant.

The Y-grade is a flammable substance is present at the Plant in excess of the threshold quantity and, therefore, is subject to the RMP requirements. Based on the worst-case analysis, the distance to the endpoint exceeds the distance to public receptors; therefore, the Plant is classified as Program level 3 under the RMP.

OFF-SITE CONSEQUENCE ANALYSIS RESULTS

Flammable Substances Worst-Case Scenario

The endp
oint for worst-case release of flammable substances is 1-psi overpressure (i.e., 15.7 psia), resulting from a vapor cloud explosion assuming an instantaneous release. A yield factor of 10% of the available energy released in the explosion is used to determine the distance to the explosion endpoint. Since the worst-case release scenario for a flammable substance is based on the assumption that the entire quantity of the substance forms a vapor cloud, passive mitigation systems are not applicable. In case of the Plant, Y-grade would be the worst-case flammable release with 0.39-mile distance to the endpoint.

Flammable Substances Alternative-Case Scenario

There are no other substances that can be considered in the alternative-case scenario.

Toxic Substances

There are no toxic substances held above the threshold quantity; therefore, analysis of worst-case or alternative-case release scenarios for toxic substances is not required for this Plant.

GENERAL ACCIDENT RELEASE PROGRAM

The following is a summary of the accident prevention program implemented at the Plant. Because the processes at the Plant that are regulated by the Environmental Protection Agency (EPA) Risk Management Program (RMP) regulation are also subject to the Occupational Safety and Health Administration (OSHA) 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.

Employee Participation

Active employee participation and involvement in the development and implementation of the PSM program at the Plant is an important step toward achieving the objective to prevent and/or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. Employee involvement will help to ensure that all perspectives regarding PSM are considered and that the best ideas are implemented. Open communications are encouraged between supervisors an
d employees regarding all safety and health issues.

The Plant strongly promotes employee involvement in safety issues through existing programs. These programs include safety committees (which are made up of a cross-section of employees and supervisors), regularly scheduled safety meetings, tail-gate safety meetings, near-miss reporting, and special training programs (emergency response training, first aid, hazcom, etc.). Employees are encouraged to discuss accident prevention with their supervisors if they have questions, comments, or suggestions.

Process Safety Information

Complete and accurate written Process Safety Information (PSI) concerning process chemicals, process technology, and process equipment is essential to effective PSM and RMP programs and to completing and maintaining a process hazard analysis (PHA). The PSI is useful to the operators, team performing PHAs, those in charge of employee training, contractors and third-party vendors, those conducting pre-startup safety reviews, and those in charge of updating the emergency preparedness plans and emergency action plans. PSI is incorporated into the PSM Manual and is readily available to all employees.

The Plant keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemicals properties and associated hazards, limits for key process parameters and specific chemical inventories, 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 (MSDSs).

The Plant also maintains numerous technical documents that provide information about the design and construction of the process equipment. This information includes materials of construction, design pressure and temperature ratings, and electrical rating of equipment. This information, in combination with the written procedure
s and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised.

Process Hazard Analysis (PHA)

The Plant has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.

The Plant primarily uses the hazard and operability (HAZOP) and What-if-Checklist method analysis technique to perform these evaluations. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and the team makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary.

Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options in response to PHA team findings are tracked until they are completed. The final resolution of each finding is documented and retained.

To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the hazard analysis results are updated and revalidated periodically. These periodic reviews are conducted at least every five (5) years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and retained in the PlantA?s files. Once again, the team findings are forwarded to manag
ement for consideration, and the final resolution of the findings is documented and retained.

Operating Procedures

The Plant maintains written procedures that address various modes of process operations, such as: (1) startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures provide guidance for experienced operators and also provide the basis for training new operators. Operating procedures are periodically reviewed and annually certified as current and accurate. The review and certification process involves both operators and technical staff.

The intent of the operating procedures is to provide workable, useful, and clearly written instructions for conducting activities. To have effective operating procedures, the task and procedures directly and indirectly related to the covered process must be appropriate, clear, consistent, and most importantly, communicated to employees. Operating procedures are specific instructions or details on what steps are taken or followed in carrying out the stated procedures. The specific instructions include the applicable safety precautions and appropriate information on safety implications.

Training

In addition to training on operating procedures, the Plant has a comprehensive training program for all employees involved in operating the process. New employees receive basic training in gas operations. 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. The refresher training is conducted at least every three (3) years. All of this training is documented for each operator including the means used to verify that the operator understood the training.

Contractors

The Plant uses contractors during periods of increased maintenance or construction activities. Because some contractors work on or near
process equipment, the Plant has procedures in place to ensure that 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) understand what they should do in the event of an emergency, (5) understand and follow site specific safety rules, and (6) inform Plant personnel of any hazards that they find during their work. This is accomplished by providing contractors with an orientation session that covers: (1) a process overview, (2) information about safety and health, (3) emergency response plan requirements, and (4) safe work practices prior to beginning their work. In addition, the Plant evaluates contractor safety programs and performance during the selection of a contractor. The Plant personnel periodically monitor contract performance to ensure that contractors are fulfilling their safety obligations.

Pre-startup Safety Review

The Plant conducts a PSSR on any new facility or facility modification that requires a change in process safety information. The purpose of the PSSR is to ensure 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 to make sure construction is in accordance with design specification and that all supporting systems is operationally ready. The PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented.

Mechanical Integrity

The Plant 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. In combination, these activities form a s
ystem 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 response plans, and (5) applicable safe work practices to help ensure that they can perform their jobs in a safe manner.

Another integral part of the mechanical integrity program is quality assurance. The Plant incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made.

Safe Work Practices

The Plant has long standing safe work practices in place to help ensure worker and process safety. Examples of these include: (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous substances before process piping and equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to ensure 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 ensure that operations and maintenance activities are performed safely.

Management of Change

The Plant has a comprehensive system to manage changes to all covered processes. This system requires that changes to items such as process equipment, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure 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, and equipment information, as well as procedures are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change.

Incident Investigation

The Plant promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury or fatality. The goal of each investigation is to gather the facts, determine the root cause, and develop corrective action to prevent the reoccurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendation to prevent a recurrence, and forwards these results to the business management team for resolution.

Compliance Audits

To help ensure that the accident prevention program is functioning properly, the 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 three (3) years. Both hourly and staff personnel participate as audit team members. The audit team develops findings that are forwarded to Plant management for resolution. Corrective actions taken in response to the audit team 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 must be managed to ensure continued safe operation. The following is a description of existing safety features applicable to prevention of accidental releases of regulated substances in the facility.

Universal Prevention Activities

The accident prevention program summarized previously is applied to all RMP-covered processes at the Plant. Collectively, these prevention program activities help prevent potential accident scenario
s that could be caused by equipment failures and/or human errors.

Specialized Safety Features

The Plant has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in the covered processes:

Release Detection:
1. Hydrocarbon detectors with alarms

Release Containment/Control :
1. Process relief valves 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 (e.g., uninterruptible power supply for process control system, backup firewater pump)
6. Atmospheric relief devices

Release Mitigation:
1. Fire suppression and extinguishing systems
2. Deluge system for specific equipment
3. Personnel trained in emergency procedures
4. Personal protective equipment (e.g., chemical protective clothing, self-contained breathing apparatus)

Five-Year Accident History

The Plant has an excellent record of accident prevention. Over the past five (5) years there have been no accidental releases.

EMERGENCY PROCEDURE INFORMATION

The Plant maintains a written emergency procedure, which is in place to protect worker and public safety as well as the environment in the event of a fire or explosion if a flammable substance is accidentally released. The procedure addresses notification of federal, state and local emergency response agencies as appropriate and post incident cleanup and decontamination requirements. Employees receive training in emergency procedures. The emergency procedure is updated when necessary based on modifications made to the Plant facilities. The emergency procedure changes are administered through the Management of Change (MOC) process, which includes infor
ming and/or training affected personnel in the changes.

The overall emergency procedure program for the Plant is coordinated with the Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The Plant has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, the Plant conducts periodic emergency drills that involve the LEPC and emergency response organizations, and the Plant provides periodic refresher training to local emergency responders regarding the hazards of regulated substances in the Plant.