Sea Robin Gas Processing Plant
Erath, LA 70533
Houston, TX 77210 -4324
Person responsible for RMP implementation:
Latest RMP Submission:
2. Toxics: Worst-case
3. Toxics: Alternative release
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:
- Names of the chemicals in the Off-Site Consequence Analysis
- Amount of chemical released
- Rate of chemical release
- Radius of affected area
- Vulnerable areas affected
- Count of affected population
- Maps or other optionally provided supplementary material
Instructions on how to make an EPA appointment can be found here.
- Blast walls
5. Flammables: Alternative release
6. Five-year accident history
7. Prevention: Program level 3
8. Prevention Program level 2
9. Emergency response
Environmental Protection Agency Risk Management Plan
Sea Robin Gas Plant
Risk Management Plan (RMP)
EPA Identifier: 1000 0017 5115
Accidental Release Prevention and Response
The Sea Robin 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.
Description of the Stationary Source and Regulated Substances
The Sea Robin Gas Plant is a gas processing facility that recovers natural gas liquids (NGL's) from gas being transported by the Sea Robin pipeline utilizing the cryogenic turboexpander process. The plant processes the gas utilizing either of two installed turbo expanders to remove recoverable natural gas liquids from the inlet gas stream. Finished products are residual natural gas and extracted hydrocarbon liquids which are removed from the plant by pipeline systems.
The plant contains regulated flammables, such as Liquefied Petroleum Gas (LPG) and Natural Gas Liquids (NGL). The main components are Ethane, Propane and Butane within its process areas. The Plant is subject to the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) regulation and is classified as a Program Level 1 site under the EPA RMP program.
No toxic materials to report.
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 on site and 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 Sea Robin Gas Plant. The processes at the plant are regulated by the Environmental Protection Agency (EPA) Risk Management Program (RMP) regulation (Program 1), and are also subject to the OSHA's PSM standard. This summary addresses each of the PSM program elements and describes the management system in place to implement the accident prevention program which is required only by the facility OSHA PSM regulation coverage.
Enterprise strongly promotes employee involvement in safety issues through existing programs. These programs include regularly scheduled safety meeting, tail-gate safety meetings, hazard communications, a "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. Employees are encouraged to discuss accident prevention with their supervisors and to bring any questions, comments or suggestions forward for open discussion.
Process Safety Information
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 o
Process Hazard Analysis (PHA)
Enterprise primarily uses the hazard and operability (HAZOP) and Checklist method analysis technique to perform these evaluations. The analyses are conducted using a team of Enterprise staff which has 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 recommendations for additional prevention and/or mitigation measures when the team believes such measures are 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. 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.
As part of Enterprise Process Hazard Analysis program, the facility will periodically update and revalidate the hazard analysis results.
The Sea Robin 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 include applicable safety precautions that must be taken in the operation of the facility. The procedures are periodically reviewed and annually certified as current and accurate. The review and certification process involves both operators and technical staff.
In addition to training on operating procedures, the Sea Robin Gas Pla
nt has a comprehensive training program for all employees involved in operating the process. New employees receive basic training in gas plant operations and safe work practices. All operators receive refresher training on the operating procedures at least every three years to ensure that their skills and knowledge are maintained at an acceptable level.
The Sea Robin 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 contractor selection process. Enterprise personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations.
Pre-Startup Safety Review (PSSR)
The Sea Robin Gas Plant conducts a PSSR prior to the startup of all new facilities or any 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.
The Sea Robin Gas Plant has well established practices and procedures for maintaining process equipment. The basic aspects of t
his 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.
Safe Work Practices
The Sea Robin Gas Plant has 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, along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely
Management of Change
The Sea Robin Gas Plant uses Enterprise software-based change approval system to manage change to all covered processes. This system requires that changes to items such as process equipment, technology, procedures and other facility changes be properly reviewed and authorized before being implemented to ensure that the safety of the facility is not compromised by the change. Operating and maintenance personnel are provided any necessary training on any changes as part of the change management process.
The Sea Robin 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 investigation team documents its findings, develops recommendation(s) to prevent a reoccurrence and forwards these results to the business managem
ent team for resolution.
To help ensure that the accident prevention program is functioning properly, Enterprise periodically conducts an audit of the program 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 team develops findings that are forwarded to operations or facility management for resolution. 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 Sea Robin 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 RMP covered processes at the Sea Robin 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 Sea Robin 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:
* Hydrocarbon (hazardous gas) detectors and alarms
* Fire detectors on gas compression equipment
* Plant video surveillance system
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 pressure).
* Secondary containment (cur
bs and dikes) to contain any release of liquid chemicals
* Redundant equipment and instrumentation where advisable
* Dual mechanical seals with seal failure alarms installed on hydrocarbon liquid pumps.
* Atmospheric relief devices
* Hand-held fire extinguishers
* Personnel trained in emergency response and procedures.
* Personnel protective equipment (e.g., chemical protective clothing, self-contained breathing apparatus, etc.)
Five Year Accident History
Over the past five years there have been no large or small releases which resulted in any injuries, property damage or offsite consequences.
Emergency Procedures Information
The Sea Robin Gas Plant maintains a written emergency procedure, which is 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. Employees receive training in emergency procedures. The emergency procedure is updated when necessary based on modifications made to the plant facilities.
The overall emergency procedure program for the Sea Robin Gas Plant is coordinated with the Vermillion 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 Sea Robin Gas 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 Sea Robin Gas Plant conducts periodic emergency drills that involve the LEPC and emergency response organizations, and also provides
periodic refresher training to local emergency responders regarding the hazards of regulated substances in the plant.
Planned Changes to Improve Safety
The Sea Robin Gas Plant resolves all findings from PHAs, some of which result in modifications to the process. Other recommendations for possible changes to improve safety come from periodic accident prevention program audits, incident investigations, or employee suggestions and recommendations. The following changes are planned for implementation at the Sea Robin Gas Plant.
* The Control Room has recently been reinforced to protect occupants from explosion hazards.