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Enterprise Calumet Gas Plant

Parent Companies:
Enterprise Gas Processing L.L.C.
EPA Facility ID:
100000172305
Other ID:
LAD 230065407
Facility DUNS:
109003467
Parent Company DUNS:
48210686

Location:

Address:
3617 Hwy 90 East
Patterson, LA 70392
County:
ST. MARY
Lat / Long:
29.693, -91.344 (Get map)
Method:
GPS - Unspecified
Description:
Administrative Building
Horizonal accuracy:
50 m
Horizontal reference datum:
World Geodetic System of 1984
Source map scale:

Owner/Operator:

Name:
Enterprise Products Operating LLC
Phone:
(713) 880-6500
Address:
P. O. Box 4324
Houston, TX 77210 -4324
Foreign Address:

Person responsible for RMP implementation:

Name:
Alfred J. Wussler
Title:
Senior Compliance Engineer - RMP

Emergency contact:

Name:
David Rogers
Title:
Plant Manager
Phone:
(985) 395-3854
24-hour phone:
(985) 397-0773
Ext or PIN:

Other contacts:

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

Safety:

Local Emergency Planning Committee:
St. Mary Parish LEPC
Full-Time Equivalent Employees:
18
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
2660-00083-V1
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
May 3, 2007
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Refr. Lean Oil Extraction
RMP ID:
1000012342
CBI claimed:
No
Program Level:
3
NAICS:
Natural Gas Liquid Extraction (211112)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
81,000
No
Flammable Mixture
00-11-11
88,000
No
Flammable Mixture
00-11-11
370,000
No
Flammable Mixture
00-11-11
38,000
No
Flammable Mixture
00-11-11
340,000
No
Propane
74-98-6
220,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
Sept. 18, 2009
Type:
Resubmission
Reason:
Voluntary update (not described by any of the above reasons)
Registered:
No
RMP ID:
1000010458

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 Refr. Lean Oil Extraction)
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 Refr. Lean Oil Extraction)
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

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

Refr. Lean Oil Extraction, Natural Gas Liquid Extraction (211112)
Prevention Program ID:
1000010262
Safety Review Date
Sept. 30, 2008, since latest RMP submission
PHA Update Date
Aug. 19, 2009, since latest RMP submission
PHA Techniques
  • Checklist
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
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
May 26, 2009, since latest RMP submission
Training Review Date
Oct. 22, 2007, since latest RMP submission
Maintenance Review Date
Oct. 22, 2007, since latest RMP submission
Maintenance Inspection Date
April 24, 2009, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
July 28, 2008
Management of Change Review Date
Oct. 22, 2007
Pre-startup Review Date
Jan. 27, 2009
Compliance Audit Date
Oct. 22, 2007
Compliance Audit Change Completion Date
May 13, 2008
Incident Investigation Date
Sept. 30, 2004
Incident Invest. Change Completion Date
Sept. 30, 2004
Participation Plan Review Date
Oct. 22, 2007
Hot Work Review Date
March 17, 2009
Contractor Safety Review Date
Oct. 22, 2007, since latest RMP submission
Contractor Safety Eval. Date
May 18, 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:
Aug. 25, 2009
Local Response Agency:
Local Response Agency Phone:
(985) 395-3636
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:
No
Subject To - Other:

Executive Summary

Environmental Protection Agency Risk Management Plan
Enterprise Calumet Gas Plant
RMP Executive Summary


EPA Identifier: 1000 0017 2305

The Enterprise Calumet 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. It is the practice of Enterprise Products Operating LLC (Enterprise) to implement reasonable controls to prevent foreseeable releases of substances. However, if a release does occur, trained personnel will respond to, control and contain the release.

The Enterprise Calumet Gas Plant is located in St. Mary parish, Louisiana. The plant is owned by Enterprise Gas Processing LLC, and operated by Enterprise Products Operating LLC.

We use a combination of accidental release prevention programs and emergency response planning programs to help provide for the safety of our employees and the public, as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including:

* A description of our facility and use of substances required by EPA's RMP regulation and the processes involved
* A summary of results from our assessment of the potential offsite consequences from accidental chemical releases
* Emergency Response Programs
* General Accidental Release Prevention Program and Chemical-Specific Prevention Steps
* A five-year accident history for accidental releases of chemicals at the Ogden Terminal that are regulated by EPA's RMP rule.


Description of the Stationary Source and Regulated Substances

The Enterprise Calumet Gas Plant receives a natural gas mixture stream feed from two separately operated pipelines, which are referred to as 'A Side' and 'B Side'. Feed gas from the 'A Side' is processed in A Train, while
feed gas from 'B Side' is processed in B and C Trains. The two gas plant streams make up a combined processing complex utilizing a refrigerated lean oil absorption process.

The two natural gas feed streams are purified by removal of water and heavy hydrocarbons. These purified streams are then processed into three products: residue gas, de-methanized natural gas liquid, and condensate. Residue gas is routed back to their respective feed pipeline for distribution and sales; condensate is transported via tank truck to outside consumers, and natural gasoline liquid is transported via pipeline to the Enterprise Pro-Mix Fractionation Plant at Napoleonville, Louisiana for additional processing.

The Enterprise Calumet Gas Plant was evaluated to determine if any regulated flammable or toxic substances exceeded the threshold quantity. Enterprise identified the regulated substances and quantities kept on site based on process knowledge.

Listed flammable substances which are stored above the threshold quantities at the Enterprise Calumet Gas Plant are absorption oil enriched with the recovered products (rich oil), raw make (flammable mixture), propane, and natural gas. The Plant is subject to the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) regulation and is classified as a Program Level 3 site under the EPA RMP program.


Offsite Consequence Analysis Results

The offsite consequence analysis will not be reflected in the executive summary, but rather is reflected in the data components. There are flammable substances above the threshold quantity on site and there are no toxic substances above the threshold quantity.


General Accident Release Prevention Program

The following is a summary of the accident prevention program in place at the Enterprise Calumet Gas plant. The processes at the plant are regulated by the Environmental Protection Agency (EPA) Risk Management Program (RMP) regulations and the OSHA Process
Safety Management (PSM) standard. This summary addresses each of the 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 plant's PSM program is an important step toward achieving the objective to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable or explosive chemicals. Employee involvement will help insure that all perspectives regarding PSM are considered and that the best ideas are implemented. Open communications are encouraged between supervisors and employees regarding all aspects of safety and health issues concerning the employees and the public.

Enterprise strongly promotes employee involvement in safety issues through existing programs. These programs include regularly scheduled safety meeting, tailgate safety meetings, hazard communications, Safety Suggestion Forms, 'near-miss' reporting system and special training programs such as emergency response training, first aid training, etc.

Enterprise actively seeks employee involvement in the development and conduct of all accident prevention activities through the appropriate existing safety programs. Accident prevention is discussed at the regularly scheduled safety meetings and/or during special training sessions if necessary. Employees are encouraged to discuss accident prevention with their supervisors as well as bring any questions, comments or suggestions forward for open discussion.

Process Safety Information

Complete and accurate written process safety information concerning process chemicals, process technology and process equipment is essential to effective PSM and RMP programs as well as to completing and maintaining a process hazard analysis. The process safety information will be useful to the operators, the team performing a process hazard analysis and those in charge
of updating the emergency preparedness plans. Process safety information is readily available to all employees. Enterprise keeps a variety of technical documents that are used to help maintain a safe operating process. These documents address chemical properties and associated hazards, limits for key process parameters, specific chemicals 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 (MSDS).

Enterprise also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure ratings, temperature ratings and electrical rating of equipment. This information 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 (PHA)

The Enterprise Calumet 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.

Enterprise 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 neces
sary.

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. 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 plant periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every five 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. Once again, the team findings is documented and retained.

Operating Procedures

The Enterprise Calumet Gas Plant maintains written procedures that address various modes of process operations such as; (1) start-up, (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 involved both operators and technical staff.

The intent of the operating procedures is to provide workable, useful and clearly written instructions for conducting operating activities. To have effective operating procedures, the tasks 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 instruction
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 Enterprise Calumet Gas Plant has a comprehensive training program for all employees involved in operating the process. New employees receive basic training in gas extraction and fractionation plant 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. This refresher training is conducted at least every three years. All of this training is documented for each operator including the means to verify that the operator understood the training.

Contractors

The Enterprise Calumet Gas 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 while performing their work. This is accomplished by providing contractors with an orientation session that covers (1) a process overview, (2) information about the safety and health hazards, (3) emergency response plan requirements and (4) safe work practices prior to beginning their work. In addition, Enterprise evaluates contractor safety programs and performance during the selection of a contractor. Enterprise personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations.

Pre-Startup Safety Review (PSSR)


The Enterprise Calumet Gas 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 specifications 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 Enterprise Calumet Gas 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 system that maintains the mechanical integrity of the process.

Enterprise 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 Enterprise Calumet Gas Plant has longstanding safe work practices in place to help insure 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 precaution
s 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 Enterprise Calumet Gas Plant has a comprehensive system to manage change 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 ensure that adequate controls are in place to manage any new hazards and to 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 changes.

Incident Investigation

The Enterprise Calumet 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. The goal of each investigation is to gather the factors, 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(s) to prevent a reoccurrence and forwards these results to the business management team for resolution.

Compliance Audits

To help ensure that the accident prevention program is functioning properly, Enterprise periodically conducts audits to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every three years. Both hourly and staff personnel participate as audit team members. The audit tea
m develops findings that are forwarded to plant management for resolution. Corrective actions taken in response to the audit teamA?s findings are tracked until they are resolved and completed. 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 Enterprise Calumet Gas 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 PSM and RMP covered processes at the Enterprise Calumet Gas Plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors.


Specialized Safety Features

The Enterprise Calumet Gas Plant has safety features on many units to help contain/control a release, to quickly detect a release and reduce the consequence of a release. The following types of safety features are used in the covered processes:

Release Detection

* Hydrocarbon detectors with alarms

Release Containment and Control

* Process relief valves that discharge to a flare to capture and incinerate episodic releases.
* Valves to permit isolation of the process (manual or automated).
* Automatic shutdown systems for specific process parameters (e.g., high temperature).
* Curbs or dikes to contain liquid releases.
* Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump).
* Atmospheric relief devices.

Release Mitigation

* Fire suppression and extinguishing systems.
* Deluge system for specific equipment.
* Personnel trained in emergency response and procedures.
* Personnel protective equipment (e.g., chemical pr
otective clothing, self-contained breathing apparatus, etc.).


Five Year Accident History

The Enterprise Calumet Gas Plant has an excellent record of accident prevention. Over the past five years there have been no accidental releases.


Emergency Procedures Information

The Enterprise Calumet Gas Plant maintains written emergency procedures, which are in place to protect worker and public safety as well as the environment. The procedures are for the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address notification of local emergency response agencies if a release occurs, 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 process.

The overall emergency procedure program for the Enterprise Calumet Gas Plant is coordinated with the St. Mary Parish 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 Calumet 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 Enterprise Calumet Gas Plant conducts periodic emergency drills that involve the LEPC, and other emergency response organizations. The Enterprise Calumet Gas Plant also provides periodic refresher training to local emergency responders regarding the hazards of regulated substances in the plant.


Planned Changes to Improve Safety

The Enterprise Calumet Gas Plant resolv
es all findings from PHAs or indicent investigations, some of which may result in modifications to the process. The plant also has a proactive safety program that considers employee concerns and recommendations for addtional procedure or equipment changes to improve safety. The following types of changes are planned over the next few years in response to PHA, safety audits and incident investigation findings:

* The Enterprise safety management / accident prevention (PSM) program is currently undergoing a complete review and updating to insure that the program correctly reflects the safety management practices being used at Enterprise facilities.