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Dubach Gas Plant

Parent Companies:
La Grange Acquisitions, LLC
EPA Facility ID:
100000132787
Other ID:
LAD985210194
Facility DUNS:
790145114
Parent Company DUNS:
0

Location:

Address:
201 Oak Street
Dubach, LA 71235
County:
LINCOLN
Lat / Long:
32.690, -92.662 (Get map)
Method:
GPS - Unspecified
Description:
Center of Facility
Horizonal accuracy:
12.2 m
Horizontal reference datum:
World Geodetic System of 1984
Source map scale:

Owner/Operator:

Name:
La Grange Acquisitions, LLC
Phone:
(201) 403-7300
Address:
800 E. Sonterra Blvd
Suite 400
San Antonio, TX 78258 -3941
Foreign Address:

Person responsible for RMP implementation:

Name:
Bruce Kelpe
Title:
Operations Manager

Emergency contact:

Name:
Todd McKee
Title:
Operations Director
Phone:
(318) 371-1978
24-hour phone:
(318) 375-4831
Ext or PIN:

Other contacts:

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

Safety:

Local Emergency Planning Committee:
Full-Time Equivalent Employees:
16
Covered by OSHA PSM:
Yes
EPCRA section 302:
No
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
1720-00005-V5
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
May 26, 2015
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Unspecified process
RMP ID:
1000070796
CBI claimed:
No
Program Level:
3
NAICS:
Natural Gas Liquid Extraction (211112)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
675,395
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Rodrick Nunez
Address:
8100 Big Lake Rd
Lake Charles, LA 70605
Foreign Address:

Phone:
(337) 475-4392

Latest RMP Submission:

Date:
April 12, 2016
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000056705

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 Unspecified process)
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 Unspecified process)
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 Liquid Extraction (211112)
Prevention Program ID:
1000059258
Safety Review Date
Feb. 24, 2016, since latest RMP submission
PHA Update Date
Oct. 23, 2014, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
Process Controls
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
Mitigation Systems
  • Fire Walls
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Process Controls
  • Process Detection
Training Type
  • Classrom
Competency Testing
  • None
Procedure Review Date
March 15, 2016, since latest RMP submission
Training Review Date
June 30, 2015, since latest RMP submission
Maintenance Review Date
Aug. 5, 2015, since latest RMP submission
Maintenance Inspection Date
March 24, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Oct. 14, 2015
Management of Change Review Date
April 1, 2015
Pre-startup Review Date
Dec. 15, 2015
Compliance Audit Date
Oct. 6, 2015
Compliance Audit Change Completion Date
Oct. 31, 2016
Incident Investigation Date
Feb. 2, 2015
Incident Invest. Change Completion Date
Aug. 31, 2015
Participation Plan Review Date
March 24, 2015
Hot Work Review Date
Dec. 9, 2015
Contractor Safety Review Date
Nov. 18, 2015, since latest RMP submission
Contractor Safety Eval. Date
March 18, 2016, 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:
April 8, 2015
Local Response Agency:
Local Response Agency Phone:
(318) 255-1055
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:
Yes
Subject To - Other:

Executive Summary

ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES



The Dubach Gas Plant has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of the facility's processes. The Energy Transfer policy is to implement reasonable controls to prevent foreseeable releases of substances.



DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCE

Energy Transfer operates the Dubach Gas Plant located in Lincoln Parish, Louisiana. The Dubach Gas Plant is a cryogenic natural gas processing plant designed for the extraction of liquid Y-grade product from a gas stream. The cryogenic extraction plant recovers methane, ethane, propane, butane, and pentane from the inlet gas. As evidenced in the ensuing text and based on criteria outlined in the Accidental Release Prevention Program (ARP), the Dubach Plant is a Program 3 process.



The Dubach Gas Plant was evaluated to determine if any regulated flammable or toxic substances were present in the process and if they exceeded the threshold quantity. All equipment and vessels are considered to be connected and/or co-located; consequently, for the purposes of the ARP Program, all equipment and vessels are part of a single process. The identification of even a single vessel exceeding threshold quantities of a regulated flammable or toxic substance would subject a process to threshold determination for offsite consequence analysis.



It was determined that a single vessel of flammable mixture (Y Grade) exceeded threshold quantity. The identification of this exceedance indicates that the Dubach Gas Plant is a covered process with regulated substances subject to threshold determination for offsite consequence analysis.



FIVE YEAR ACCIDENT HISTORY



The Dubach Gas Plant has not had any accidental releases during the past five years that meet
the criteria for an accidental release as discussed in 40 CFR 68.42.



LOCAL EMERGENCY RESPONSE COORDINATION



The Dubach Gas Plant has coordinated its emergency response activities with the local fire department. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM



The following is a summary of the accident prevention program in place at the Dubach Gas Plant. Because plant processes are subject to EPA's RMP regulations and to OSHA's PSM standards, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program.



Employee Participation



Energy Transfer and the Dubach Gas Plant actively encourage all levels of employees and contract employees to participate in creating a safe work environment. This participation begins with well-established mechanisms of communication with all employees regarding covered process information. Employees are involved in maintaining PSM rule compliance based on their knowledge, skill, job responsibilities, and experience. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that is maintained at the plant.



Process Safety Information



The Dubach Gas Plant maintains written information intended to provide a foundation for identifying and understanding the process hazards. This information addresses chemical properties, inventories, and associated hazards, as well as for key process parameter limits and equipment design basis/configuration information. Specific departments within the plant are assigned responsibility for maintaining up-to
-date process safety information.



Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in the material safety data sheets (MSDSs). This information is supplemented, when required, by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. In addition, the plant has documented safety-related limits for specific process parameters and ensures limit maintenance by using highly trained personnel, process controls, and monitoring and protective instrument systems.



The plant also maintains documentation that provides information about the design and construction of process equipment. Equipment information includes construction materials, design pressure, and temperature and electrical ratings. This information 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 Dubach Gas 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 Dubach Gas Plant primarily uses the HAZOP method to perform these evaluations. This technique provides a highly structured approach where process parameters such as flow and temperature are examined for deviations from their intended design. Deviation effects are considered in order to determine resulting potential hazards while preliminary recommendations for improvement are proposed.



The PHA team findings are promptly and systematically addressed. The Dubach Gas Plant assures that the recommendations are documented and resolved in a timely manner. This documen
tation includes the actions to be taken and a written schedule of completion dates. The plant also provides proof of communication with operating, maintenance, and other employees whose work assignments are in the process and who may be affected by the recommendations.



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



Operating Procedures



The Dubach Gas Plant maintains written procedures that address various modes of process operations, such as (1) initial startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) emergency operations, (6) normal shutdown, and (7) startup following a turnaround or after an emergency shutdown. These procedures can be used as a reference by experienced operators and provide a consistent training basis for new operators. Operating procedures are periodically reviewed and certified as current. When a process change occurs, operating procedures are revised as necessary through the management of change process.



Training



To complement the written process operation procedures, the Dubach Gas Plant has implemented a comprehensive training program for all employees. New employees receive job specific basic training in plant operations. Employee training includes emphasis on safety and health hazards, emergency shutdown operations, and safe work practices. Operators demonstrating adequate knowledge to safely perform duties and tasks are allowed to work independently.



Hot Work Permit



The Dubach Gas Plant issues a hot work permit for all hot work operations conducted on or near a covered process. The Dubach Gas Plant provides Hot Work Permit training to all plant employees. Copies of issued work permits are maintained in Operations and Maintenance for a p
eriod of 1 year following completion of work.



Contractors



The Dubach Gas Plant periodically uses contractors to perform maintenance or repair, turnaround, major renovations, or specialty work on or adjacent to a covered process. Because some contractors work on or near process equipment, the plant has procedures in place to ensure that contractors (1) are trained in the work practices necessary to safely perform his/her job, (2) have received and understood the training required and carry a training document card while on location, (3) follow the safety rules of the location including the safe work practices, (4) advise the plant of any unique hazards presented by the contractor, and (5) notify the facility of all illnesses and injuries that occur in the process areas.



Pre-Startup Safety Reviews (PSSRs)



The Dubach Gas Plant conducts a PSSR for any facility modification that requires a change in the 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 an additional check to make sure that construction and equipment are in accordance with design specification, that adequate safety, operating, maintenance, and emergency procedures are in place, and that training of each employee involved in operating the process or equipment has been completed. A standard checklist is used to document compliance.



Mechanical Integrity



The Dubach Gas Plant has well-established programs, procedures, and practices that are required to ensure that equipment used to process, store, or handle lightly hazardous chemicals and/or flammable gas or liquid is designed, constructed, installed, and maintained to minimize the risk of a release. Equipment examples include vessels, storage tanks, piping systems, and relief and vent systems with associated emergency shutdown systems and controls (i.e., moni
toring devices, sensors, alarms, and interlocks).



Maintenance personnel receive training on (1) an overview of the process, (2) a review of the process hazards, and (3) the procedures applicable to the employee's job tasks to ensure that the employees can perform the job tasks in a safe and satisfactory manner. Process equipment inspection and testing follows recognized and generally accepted good engineering practices. Equipment deficiencies that are outside of acceptable limits are corrected before further use or in a safe and timely manner when necessary means are taken to ensure safe operation.



Management of Change



The Dubach Gas Plant has a comprehensive system to manage and document changes to all covered processes. A systematic approach is followed to control and manage facility changes in order to minimize the possibility that such changes will have an adverse impact on personnel safety, equipment, or the environment. Employees involved in process operations and maintenance and contract employees whose job tasks might be affected by process changes are informed of and trained in the change prior to process start-up.



Incident Investigation



The Dubach Gas 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. An incident investigation is initiated as promptly as possible to thoroughly investigate and analyze the incident. This investigation is led by an incident investigation team consisting of those with appropriate knowledge and experience in the process. The findings and recommendations made by the incident investigation team are promptly addressed and resolved in a timely manner. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings.



Emergency Planning
and Response



The Dubach Gas Plant retains a written site specific formal emergency response plan which includes the designated actions the company and all personnel will take to ensure personal safety from fire and other emergencies. The plan outlines actions that company technicians and contract employees are to take when there is an unwanted release of highly hazardous chemicals. The intent of this plan is to facilitate the prompt evacuation of employees when necessary and to account for all personnel. The emergency plan also includes procedures for handling small releases.



Compliance Audits



To help ensure that the accident prevention program is properly functioning, the Dubach Gas Plant periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits will be conducted at least every 3 years. The audit team includes those knowledgeable in the process, operations personnel, and at least one person trained in audit techniques and practices. The audit team develops findings and corrective actions are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained.



PLANNED CHANGES TO IMPROVE SAFETY



Energy Transfer is committed to operating the Dubach Gas Plant in a safe manner for workers, the public, and the environment. Energy Transfer personnel utilize auditing processes to ensure the plant complies with safe operations of its processes. In the event improvements in safety can be realized through auditing efforts, actions are planned and instituted to respond to safety enhancements of operating practices. Improvements to safety are a continual process at the plant.



PREVIOUS OWNERS/OPERATORS



La Grange Acquisitions LLC became the owner/operator of the Dubach Gas Plant on May 01, 2015. The previous owner/operators listed in descending order are as follows:



1. Rege
ncy Gas Partners

2. El Paso Field Services

3. Cornerstone

4. Endevco

5. Kerr McGee