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Toca Natural Gas Processing Plant

Parent Companies:
Western Gas Resources, Inc.
EPA Facility ID:
100000130324
Other ID:
1434 - LDEQ
Facility DUNS:
0
Parent Company DUNS:
606413052

Location:

Address:
2404 Bayou Road
St. Bernard, LA 70085
County:
ST. BERNARD
Lat / Long:
29.863, -89.829 (Get map)
Method:
Interpolation - Map
Description:
Administrative Building
Horizonal accuracy:
m
Horizontal reference datum:
Source map scale:

Owner/Operator:

Name:
Western Gas Resources, Inc.
Phone:
(303) 452-5603
Address:
12200 N. Pecos Street
Denver, CO 80234
Foreign Address:

Person responsible for RMP implementation:

Name:
Title:
Senior Vice President of Operations
Email:

Emergency contact:

Name:
Tom Kelly
Title:
Plant Manager
Phone:
(504) 682-3809
24-hour phone:
(504) 682-3809
Ext or PIN:
Email:

Other contacts:

Facility (or company) email:
Facility phone:
(504) 682-3809
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
St. Bernard Parish LEPC
Full-Time Equivalent Employees:
21
Covered by OSHA PSM:
Yes
EPCRA section 302:
No
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
2500-00003-V3
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
June 10, 1997
Inspecting Agency:
Fire Department
Using Predictive Filing:
No

Processes:

Natural Gas Liquids
RMP ID:
16316
CBI claimed:
No
Program Level:
3
NAICS:
Natural Gas Liquid Extraction (211112)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
14,000,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
June 23, 1999
Type:
First-time submission
Reason:
Registered:
No
RMP ID:
12208

Deregistration:

Date:
Effective Date:
Reason:
Other
Other Reason:
Facility was sold - De-registration was sent in earlier - This is a confirmation

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 Liquids)
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 Liquids)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • Dikes
not considered:
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Water curtain

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

Natural Gas Liquids, Natural Gas Liquid Extraction (211112)
Prevention Program ID:
8507
Safety Review Date
Dec. 3, 1998, since latest RMP submission
PHA Update Date
Dec. 3, 1998, since latest RMP submission
PHA Techniques
  • None
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
  • Overfilling
  • Equipment failure
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • 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
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
May 21, 1999, since latest RMP submission
Training Review Date
May 18, 1999, since latest RMP submission
Maintenance Review Date
May 21, 1999, since latest RMP submission
Maintenance Inspection Date
June 8, 1999, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Jan. 12, 1999
Management of Change Review Date
May 20, 1998
Pre-startup Review Date
April 7, 1999
Compliance Audit Date
Oct. 15, 1997
Compliance Audit Change Completion Date
Dec. 18, 1997
Incident Investigation Date
May 21, 1999
Incident Invest. Change Completion Date
May 21, 1999
Participation Plan Review Date
Nov. 14, 1998
Hot Work Review Date
Nov. 14, 1998
Contractor Safety Review Date
Nov. 14, 1998, since latest RMP submission
Contractor Safety Eval. Date
Jan. 15, 1999, 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. 21, 1998
Local Response Agency:
Local Response Agency Phone:
(504) 278-4225
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

1434 LDEQ Facility ID Number

Risk Management Plan
Executive Summary for the Toca Gas Processing Facility

Accidental Release Prevention and Response Policies
The Toca Gas Plant has a longstanding commitment to worker and public safety. This commitment is supported by the resources invested in accident prevention, personnel training and the consideration of safety issues in the design, construction, operation and maintenance of our facilities. Our policy is to implement reasonable controls to provide a safe operation and prevent foreseeable releases of regulated substances. However, if a release does occur, trained gas plant personnel will respond to control and contain the release.

Description of the Stationary Source and Regulated Substances
The Toca gas plant is located about 15 miles east of New Orleans, Louisiana. The facility includes compression, dehydration, a lean oil liquids recovery system, liquids fractionation, and electrical power generation. The plant produces a lean, dry residue gas stream, propane, iso-butane, normal butane and a gasoline/condensate stream. The liquid products contain ethane, propane, butanes, pentanes and heavier components. The plant handles regulated flammables including ethane, propane, mixed butanes and mixed pentanes. The plant does not handle any materials classified as toxic.

Offsite Consequence Analysis Results
There are no toxic release scenarios to consider at the Toca gas plant.

The worst-case scenario (WCS) at the Toca facility is the release of flammable substances from a butane storage tank. This scenario pertains to a vapor cloud explosion (VCE) involving the full inventory of the largest storage tank containing propane. The contents of this tank amount to about 531,500 pounds of material which form an unconfined vapor cloud explosion. This amount of material is presumed to release, vaporize and ignite resulting in the VCE. Using the RMP Comp. software, the maximum distance to the 1.0 pound per squar
e inch endpoint for this WCS was calculated to be 0.7 miles. This distance does include some residences and therefore has caused Toca to be a program level 3 facility. Although we have numerous controls to prevent such a release and to manage their consequences, no credit for passive mitigation measures was taken here. It should be noted that this tank rarely operates full, though this volume is used in the WCS calculations.

The alternative release scenario (ARS) of flammable substances at the plant is a VCE resulting from the release of a natural gas liquids stream from a ruptured propane truck loading connection. This release was assumed to last for 10 minutes and result in the release of 25,900 pounds of material. Using the RMP Comp. software, the maximum distance to the 1.0 pound per square inch endpoint for this ARS was calculated to be 0.1 miles. This event was selected as being a possible scenario for use in emergency planning and response. There are no residences or offices within the ACS 1.0 psi pressure radius.

General Accidental Release Prevention Program
The following is a summary of the accident prevention program in place at the plant. The processes at the plant are regulated by the Environmental Protection Agency=s (EPA=s) Risk Management Program (RMP) and the Occupational Safety and Health Administration=s (OSHA=s) process safety management (PSM) standard. The following summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program.

Employee Participation
The Toca Gas Plant requires employees to participate in all facets of process management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team. Employees have access to all information created as part of the gas plant accident prevention program. Specific
ways that employees are involved in the accident prevention program are documented in an employee participation plan that is maintained at the gas plant and addresses each accident prevention program element. In addition the gas plant has a number of initiatives under way that address process and employee safety issues. These include development of standardized operating procedures, incident investigation, management of change, safe work practices and participation in flowsheet reviews.

Process Safety Information
The Toca gas plant keeps a variety of technical documents that are used to help maintain safe operation of the process. These documents address chemical properties and associated hazards, limits for key process parameters, and equipment design basis/configuration information. The Operations group has been assigned responsibility for maintaining up-to-date process safety information. The location of these documents is readily available to help employees locate any necessary process safety information.

Chemical specific information, including exposure hazards and emergency response/exposure treatment consideration, is provided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For specific process areas, the gas plant has documented safety related limits for specific process parameters in operating manuals. The gas plant ensures that the process is maintained within these limits using process controls and monitoring instruments, trained personnel and protective instrument systems (e.g., automated shutdown systems).

The Toca gas plant maintains numerous 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 inf
ormation in combination with written procedures 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
The Toca gas plant has a comprehensive program to 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 Toca gas plant uses the process hazards analysis technique to perform these evaluations. These reviews 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. The team makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary.

If necessary the PHA team findings are forwarded to local and corporate management for resolution. 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.

To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the plant periodically updates and revalidate the hazard analysis results. These periodic reviews are conducted at least every 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.

Operating Procedures
The Toca gas plant maintains written procedures that address various modes of process operations, such as unit startup, normal
operations, emergency shutdown and normal shutdown. 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 to ensure they are current and accurate. The procedures are also kept current and accurate by revising them as necessary to reflect changes made through the management of change process.

Training
To complement the written process operating procedures, the Toca gas plant has a comprehensive training program for all employees involved in operating a process. New employees receive basic training in gas plant 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 the 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. All training is documented for each operator, including the means used to verify the operators understanding of the training.

Contractors
The Toca gas plant uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the gas plant has procedures in place to ensure that contractors 1) perform their work in a safe manner, 2) have the appropriate knowledge and skills, 3) are aware of the hazards in their workplace, 4) understand what they should do in the event of an emergency, 5) understand and follow site safety rules, and 6) inform gas plant personnel of any hazards that they find during their work. This is accomplished by providing contractors with 1) p
rocess overview, 2) information about safety and health hazards, 3) emergency response plan requirements, 4) safe work practices prior to their beginning work, 5) safe and hot work permits as required. In addition the Toca gas plant evaluates contractor safety programs and performance during the selection of a contractor.

Pre-startup Safety Reviews (PSSRs)
The Toca gas plant 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 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 construction in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves as a quality assurance mechanism by verifiying that the accident prevention program requirements are properly implemented.

Mechanical Integrity
The Toca gas plant has well established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps, heat exchangers, compressors and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: 1) conducting training, 2) developing written procedures, 3) performing inspections and tests, 4) correcting identified deficiencies, and 5) applying quality assurance measures. 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 response plans, and 5) applicable safe work practices to help ensure that they can perform their jobs in a safe manner. Written procedures help
ensure that work is performed in a consistent manner and provides a basis for training. Inspections and tests are performed to verify that equipment parameters are within acceptable limits. For a vessel, the parameter being monitored would typically be wall thickness. If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible) or a management of change team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment.

Safe Work Practices
The Toca gas 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 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 ensure that adequate precautions are in place before entry into a confined space. These procedures along with training of affected personnel form a system to help ensure that operations and maintenance activities are performed safely.

Management of Change
The Toca gas plant has a comprehensive system to manage changes to all covered processes. This system requires that changes to items such as process equipment, chemicals, technology, 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, 2) verify that existing controls have not been compromised by the change, and 3) ensure that changes do not introduce an unknown hazard to the process. Affected chemical hazard information, process operating limits and equipment information, as well as proced
ures is updated to incorporate these changes. In addition, operating and maintenance personnel are provided necessary training on the change.

Incident Investigation
The Toca gas plant promptly investigates all incidents that resulted in, or reasonably could have resulted in a fire/explosion, major property damage, environmental loss or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents it findings, develops recommendations to prevent a recurrence and forwards these results to gas plant management for resolution. The final resolution of each finding or recommendation is documented and the investigation results reviewed with all employees who could be affected by the findings. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs.

Compliance Audits
To guarantee that the accident prevention program is functioning properly, the Toca gas plant audits to determine that 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 gas plant management for resolution.

Chemical -Specific Prevention Steps
The processes at the Toca gas plant have hazards that must be manage to ensure continued safe operation. The following is a description of existing safety features applicable to prevention of accidental releases of regulates substances in the facility.

Universal Prevention Activities
The accident prevention program summarized previously is applied to all RMP covered processes at the Toca gas plant. Collectively these prevention program activities help prevent potential accident scenarios that could be caused by equipment failure and human
errors.

Specialized Safety Features
The Toca gas plant has safety features on many units to help 1) contain/control a release, 2) quickly detect a release and, and 3) reduce the consequence of a release. The following types of safety features are used in the covered processes:

Release Detection- Flame detectors with alarms
Release Containment/Control- Process relief valves that discharge to a flare which will capture and incinerate episodic releases
- Valves to permit isolation of portions or the entire process
- Automated shutdown systems for specific process parameters
- Curbing or diking to contain liquid releases
- Redundant equipment and instrumentation (e.g. UPS system)
- Atmospheric relief devices
- Overall Plant and local area ESDs
Release Mitigation- Manually operated fire extinguishing systems including dry chemical, deluge and foam
- Trained emergency response personnel
- Personnel protective equipment (e.g. self contained breathing equipment)

Five Year Accident History
In the last five years there have not been any hydrocarbon releases whose quantities approached those described in the RMP release events.

Emergency Response Program Information
The Toca gas plant maintains a written emergency response program, which is in place to protect worker and public safety and the environment. The program consists of procedure for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidently released. The procedures address all aspects of emergency response, 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 the public if a release occurs, and post incident cleanup. In addition the plant has procedures that address maintenance, inspection and testing of emergency equipment. Employees receive training in these procedures as neces
sary to perform their specific emergency response duties. The emergency response program is updated when necessary based on modifications made to the plant. The emergency response program changes are administered through the MOC process, which includes informing and/or training affected personnel in the changes.

The overall emergency response program of the Toca gas plant is coordinate with the "Superman Group" and the St. Bernard fire department. This coordination includes periodic meeting of the committee, which includes local emergency response officials, local government officials and industry representatives. The Toca gas plant has around the clock communications capability with appropriate LEPC officials and emergency response organizations. This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to emergency situations. The Toca gas plant conducts periodic emergency drills that involve the local emergency response organizations and the gas plant provides annual refresher training to local emergency responder regarding the hazards of regulated substances in the gas plant.

Planned Changes to Improve Safety
There will be more frequent and more interactive emergency response drills in future. A company wide year 2000 compliance program helps assure safety issues.