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Enterprise Anse La Butte Terminal

Parent Companies:
Enterprise Field Services, LLC
EPA Facility ID:
100000180877
Other ID:
Facility DUNS:
0
Parent Company DUNS:
135476534

Location:

Address:
1243A Salt Mine Highway (Hwy 354)
Breaux Bridge, LA 70517
County:
ST. MARTIN
Lat / Long:
30.263, -91.945 (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) 880-6670
Address:
2727 North Loop West
Houston, TX 77008 -1074
Foreign Address:

Person responsible for RMP implementation:

Name:
Alfred J. Wussler
Title:
RMP Coordinator

Emergency contact:

Name:
Ronald Poirier
Title:
Lead Operator
Phone:
(337) 332-2141
24-hour phone:
(337) 332-2141
Ext or PIN:
Ext. 706

Other contacts:

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

Safety:

Local Emergency Planning Committee:
St. Martin Parish LEPC
Full-Time Equivalent Employees:
6
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Jan. 23, 2004
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Storage & Terminal Optns
RMP ID:
73096
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Bulk Stations and Terminals (42471)
Chemical name
CAS#
Quantity (lbs.)
CBI
Propane
74-98-6
140,000,000
No
Flammable Mixture
00-11-11
68,000,000
No
Flammable Mixture
00-11-11
230,000,000
No
Flammable Mixture
00-11-11
140,000
No
Flammable Mixture
00-11-11
260,000,000
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

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
Dec. 11, 2007
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
No
RMP ID:
50349

Deregistration:

Date:
Effective Date:
Reason:
Other
Other Reason:
State has determined the source DOT jurisdictional & exempt from the rmp rule

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 Storage & Terminal Optns)
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 Storage & Terminal Optns)
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

Storage & Terminal Optns, Petroleum Bulk Stations and Terminals (42471)
Prevention Program ID:
42872
Safety Review Date
Nov. 30, 2005, since latest RMP submission
PHA Update Date
Dec. 11, 2003, since latest RMP submission
PHA Techniques
  • Checklist
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Equipment failure
  • Cooling loss
  • Floods
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Process Controls
  • None Recommended
Training Type
  • None
Competency Testing
  • Written Test
  • Demonstration
Procedure Review Date
May 21, 2007, since latest RMP submission
Training Review Date
Nov. 30, 2005, since latest RMP submission
Maintenance Review Date
Dec. 16, 2006, since latest RMP submission
Maintenance Inspection Date
July 27, 2007, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 31, 2006
Management of Change Review Date
Jan. 2, 2005
Pre-startup Review Date
Aug. 23, 2005
Compliance Audit Date
Nov. 30, 2005
Compliance Audit Change Completion Date
Nov. 30, 2008
Incident Investigation Date
Oct. 8, 2007
Incident Invest. Change Completion Date
Oct. 8, 2007
Participation Plan Review Date
Nov. 30, 2005
Hot Work Review Date
Nov. 30, 2005
Contractor Safety Review Date
Nov. 30, 2005, since latest RMP submission
Contractor Safety Eval. Date
March 12, 2007, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
No
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:
Dec. 13, 2006
Local Response Agency:
Local Response Agency Phone:
(337) 394-3071
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:
Yes
Subject To - Other:

Executive Summary

Anse La Butte Storage and Terminal
Enterprise Products Operating LLC.
Executive Summary
Risk Management Plan
EPA Identifier: 1000 0018 0877


Accidental Release Prevention and Response

The Anse La Butte Storage and Terminal 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 Anse La Butte Storage and Terminal located in Saint Martin Parish, Louisiana, is owned and operated by Enterprise Products Operating, LLC.

The Anse La Butte Storage and Terminal facilitiy is a bulk hydrocarbon storage and handling facility. The facility receives propane, butane, isobutane and mixed refinery grade butane (RGB) liquids either by pipeline or transport truck and stores these liquids in one of five active underground storage caverns. These liquids are stored until needed and are then shipped back out of the facility to wholesale customers. All of the liquid products stored at Anse La Butte are shipped out either by pipeline or transport truck. There are four product storage tanks on site at the facility to receive products prior to subsequent pumping into the storage caverns. A solid bed propane dehydrator is used to provide dehydration for stored propane product prior to truck shipment. There is also a flare knockout tank that accumulates liquid products sent flare in the facility flare system. The storage facility also has a storage tank and underground storage for storage of a natural gasoline product that is exempt from the RMP rule.
.

The Anse La Butte Storage and Terminal facility 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 the known volumes of the storage caverns and terminal vessels. Listed flammable substances which are stored above the threshold quantities at the Anse La Butte Storage and Terminal facility are propane, iso-butane, normal butane anda mixed refinery grade butane (RGB) product. Ethyl mercaptan for product odorization is also present at the facility, but is present below the threshold quantity. As noted earlier, an exempt natural gasoline product is also handled and stored at Anse La Butte. The Storage and Terminal facility 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 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 being put in place at the Anse La Butte Storage and Terminal. Enterprise has been able to locate only a minimal amount of records of the former owner?s safety management program, and is actively implementing its own standard safety management program at the facility as quickly as is practical. The storage, processing and loading operations at the Storage and Terminal facility are regulated by the Environmental Protection Agency (EPA) Risk Management Program (RMP) regulation, and are also subject to the OSHA PSM standard. This summary addresses each of the PSM program elements and describes the management system being put into place to implement the acc
ident prevention program.

Employee Participation

Active employee participation and involvement in the development and implementation of the Storage and Terminal facility?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 helps to insure that all perspectives regarding PSM compliance and accident prevention 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, tail-gate safety meetings, hazard communications, Safety Suggestion Forms, 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. 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 and to 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 an effective PSM and RMP program as well as 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 e
mployees. 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 insure that safety features in the process are not compromised.

Process Hazard Analysis (PHA)

The Anse La Butte Storage and Terminal has a comprehensive program to help insure that hazards associated with the various processes are identified and controlled. Within this program, the facility is systematically examined to identify hazards and insure 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 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 suggestions 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 insure 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 insure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the Storage and Terminal facility 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 responses to the team findings are also documented and retained.


Operating Procedures

The Anse La Butte Storage and Terminal 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 involves 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 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 Anse La Butte Storage and Terminal has a comprehensive training program for all employees involved in operating the process. New employees receive basic training in equipment and process flows, dehydration, fractionation and storage and terminal facility operations. In addition, all operators periodically receive refresher training on the operating procedures to insure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at lease 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 Anse La Butte Storage and Terminal uses contractors during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the Storage and Terminal facility has procedures in place to insure 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 Storage and Terminal facility 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, the Anse La Butte Storage and Terminal facility evaluates contractor safety programs and performance during the contractor selection process. Enterprise personnel periodically monitor contractor performance to
insure that contractors are fulfilling their safety obligations.


Pre-Startup Safety Review (PSSR)

The Anse La Butte Storage and Terminal facility 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 insure 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 are 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 Anse La Butte Storage and Terminal 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 insure 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 Anse La Butte Storage and Terminal has long standing 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 insure 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 insure 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 insure that operations and maintenance activities are performed safely

Management of Change

The Anse La Butte Storage and Terminal 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 insure 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 Anse La Butte Storage and Terminal 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 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(s) to prevent a reoccurrence and forwards these results to the business management team for resolution.

Compliance Audits

To help insure that the accident prevention program is functioning properly, Enterprise 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 years. Both hourly and staff personnel participate as audit team members. The audit team develops findings that are forwarded to Storage and Terminal facility management for resolution. Corrective actions taken in response to the audit team?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 Anse La Butte Storage and Terminal have hazards that must be managed to insure 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 Anse La Butte Storage and Terminal. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors.

Specialized Safety Features

The Anse La Butte Storage and Terminal has safety features on the facilty equipment and storage wells 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

? Loading rack and area hydrocarbon (hazardous gas) detectors.

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).
? Loading rach ground system connect loading permissive and ESD.
? Automatic shutdown systems for specific process parameters (e.g., high pressure).
? Redundant equipment and instrumentation (e.g., excess flow shutdown, backed up by a technician activated ESD system.).
? Atmospheric relief devices.

Release Mitigation

? Hand-held and wheeled
cart 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

The Anse La Butte Storage and Terminal has an excellent record of accident prevention. Over the past five years there have been no large or small releases, with no injuries or offsite consequences.


Emergency Procedures Information

The Anse La Butte Storage and Terminal 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 Storage and Terminal facility facilities. The emergency procedure changes are administered through the Management of Change process.


The overall emergency procedure program for the Anse La Butte Storage and Terminal is coordinated with the Saint Martin 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 Anse La Butte Storage and Terminal 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 Anse La Butte Storage and Terminal conducts periodic reviews of emergency procedures with emergency response organizations, and the Anse La Butte Storage and Terminal facility provides periodi
c refresher training to local emergency responders regarding the hazards of the regulated substances handled by the Storage and Terminal facility.


Planned Changes to Improve Safety

The Anse La Butte Storage and Terminal facility resolves all findings from PHA?s, some of which result in modifications to the process. The following types of changes are planned over the next few years in response to PHA, safety audits, and incident investigation findings, or from employee or location management recommendation:

? A project to upgrade the facility hazardous gas detection system has been submitted for management approval and inclusion in the next capital budget.