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Caspiana Gas Plant

Parent Companies:
Enable Midstream Partners
EPA Facility ID:
100000190553
Other ID:
Facility DUNS:
46862173
Parent Company DUNS:
0

Location:

Address:
Approx. 10 mi. SE of Shreveport
Shreveport, LA 71115
County:
CADDO
Lat / Long:
32.345, -93.613 (Get map)
Method:
Interpolation - Map
Description:
Center of Facility
Horizonal accuracy:
12.2 m
Horizontal reference datum:
World Geodetic System of 1984
Source map scale:
24000

Owner/Operator:

Name:
Enable Midstream Partners
Phone:
(405) 525-7788
Address:
211 N. Robinson Ave
Suite 1000
Oklahoma City, OK 73102
Foreign Address:

Person responsible for RMP implementation:

Name:
Paul Brewer
Title:
Executive Vice President

Emergency contact:

Name:
Chuck Morgan
Title:
Manager, Operations
Phone:
(318) 357-3614
24-hour phone:
(318) 357-3614
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(405) 525-7788
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Bossier/Caddo Parish LEPC
Full-Time Equivalent Employees:
0
Covered by OSHA PSM:
No
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Sept. 11, 2013
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Flammable Mixture
RMP ID:
1000076831
CBI claimed:
No
Program Level:
2
NAICS:
Natural Gas Liquid Extraction (211112)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
174,600
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Stephen Swanson
Address:
211 N. Robinson Ave
Suite 1000
Oklahoma City, OK 73102
Foreign Address:

Phone:
(405) 530-7478

Latest RMP Submission:

Date:
Jan. 24, 2017
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000061421

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 Flammable Mixture)
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 Flammable Mixture)
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

No Prevention Program level 3

8. Prevention Program level 2

Flammable Mixture, Natural Gas Liquid Extraction (211112)
Prevention Program ID:
1000048071
Safety Review Date
Dec. 7, 2016, since latest RMP submission
PHA Update Date
, since latest RMP submission
Safety Regulations
  • ANSI Standards
  • ASME Standards
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Equipment failure
  • Cooling loss
Process Controls
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
  • Grounding Equipment
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • Mitigation Systems
Training Type
  • Classroom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
Dec. 7, 2016, since latest RMP submission
Training Review Date
March 1, 2016, since latest RMP submission
Maintenance Review Date
Jan. 9, 2015, since latest RMP submission
Maintenance Inspection Date
Oct. 2, 2015, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Management of Change Review Date
Pre-startup Review Date
Compliance Audit Date
Jan. 7, 2015
Compliance Audit Change Completion Date
Jan. 7, 2015
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Hot Work Review Date
Contractor Safety Review Date
, since latest RMP submission
Contractor Safety Eval. Date
, since latest RMP submission

9. Emergency response

Facility In Community Plan:
No
Facility Own Response Plan:
No
Specific Facility Response Plan:
No
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
No
Plan Review Date:
Response Training Date:
None
Local Response Agency:
Local Response Agency Phone:
(318) 797-4111
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:
Yes
Subject To - Other:

Executive Summary

Caspiana Gas Plant RMP Executive Summary



1.0 Accidental Release Prevention and Emergency Response Policies



Enable Midstream Partners, LP (Enable) owns and operates the Caspiana Gas Plant and has implemented a Program 2 Risk Management Plan (RMP) in accordance with 40 CFR Part 68, which is intended to function as a robust accident prevention program, reducing the risk of accidental releases of highly hazardous chemicals and their impacts to the public and the environment. The management system which maintains the RMP is defined by company procedure PM-001 Management Program



Enable and the Caspiana Gas Plant have a 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 process at the facility. Enable's policy is to implement reasonable controls to reduce the likelihood releases of highly hazardous chemicals below unacceptable levels.



The facility information required by the RMP also aids local fire, police, and other emergency response personnel to prepare and respond in the event that an accidental release occurs. Making this information available to the public fosters communication and awareness to improve accident prevention and emergency response practices at the local level. Enable's policy is to coordinate emergency response activities with local emergency planning and/or response agencies.



2.0 Description of Stationary Source and Regulated Substances



The Caspiana Gas Plant meets the definition of a stationary source and is located in Caddo Parish, Louisiana approximately 10 miles southwest of Shreveport, LA on Highway 1, Zip Code 71115. The facility GPS coordinates are 32.344975, -93.613042.



The Caspiana Gas Plant is an unmanned facility and contains a single process, due to interconnection and colocation of process equipment. This process is a natural gas p
rocessing plant (NAICS Code 211112) that produces liquefied petroleum gas (LPG), a regulated flammable substance (NFPA 4 liquid), consisting of a mixture including methane, ethane, propane, butanes, pentanes, and heavier hydrocarbons, utilizing the Joule-Thompson cooling effect for LPG separation from field natural gas. The maximum intended inventory of LPG in the process at the facility is 174,600 lbs, the majority of which is contained by a 30,000 gallon bullet tank. There are no regulated toxic substances present at the facility.



Other auxiliary operations at the facility include (1) glycol dehydration of the inlet field gas, (2) field liquid separation from the inlet gas stream, yielding produced water and condensate (NFPA 3 liquid), which are stored in atmospheric tanks, and (3) Compression of residue natural gas after LPG separation. The LPG product, condensate, and produced water are transported from the site via tanker trucks.



2.1 Hazard Assessment



2.1.1 Worst-Case Release Scenario (WCS)



The LPG (flammable mixture) resulted in the WCS. This was determined utilizing the EPA's RMP*Comp software to analyze the release of the largest quantity of LPG held in a single vessel or pipe resulting in a vapor cloud explosion, which is 162,768 lbs contained by a 100% full V-105 LPG Bullet Tank. This analysis yielded an endpoint to 1 psi overpressure of 0.3 miles. There is no residential population within the endpoint. However, industrial areas are present.



2.1.2 Alternative Case Scenario (ACS)



One ACS to represent all flammable regulated substances was selected and analyzed for the process. The following types of releases were considered during the selection of the ACS:

- Transfer hose releases due to splits or sudden hose uncoupling

- Process piping releases from failures at flanges, joints, welds, valves and valve seals, and drains or bleeds

- Process vessel or pump releases due to cracks, seal failure, or drain, bleed, or plug failure

- Vessel
overfilling and spill, or overpressurization and venting through relief valves or rupture disks

- Shipping container mishandling and breakage or puncturing leading to a spill



Based on the lack of previous accidents and the failure scenarios identified by the process hazard analysis, the ACS selected consists of seal failure on the transfer pump used to load the flammable mixture (LPG) into trucks resulting in a release from a three-inch opening at a pressure of 200 psig and a temperature of 100oF. The release is assumed to continue for ten minutes. The flammable mixture is assumed to vaporize and ignite in a vapor cloud explosion with an endpoint of 1-psi overpressure. It was determined that a 10-minute release would involve 20,653 pounds of the flammable mixture (LPG). The ACS was analyzed utilizing the EPA's RMP*Comp software and yielded an endpoint of 0.1 miles. There is no residential population within the endpoint. However, industrial areas are present.

2.2 RMP Program Level



Based on (1) the quantity of LPG (a regulated substance) in the process at this stationary source, (2) the fact that no accidents have occurred at the facility in the last 5 years, (3) the presence of public receptors within the distance to the endpoint from the worst-case release scenario, and (4) the facility is not subject to 29CFR 1910.119, the Caspiana Gas Plant is subject to RMP Program 2 requirements.



3.0 The General Accidental Release Prevention Program and Chemical-Specific Prevention Steps



The following is a summary of the RMP Program 2 accident prevention program in place at the Caspiana Gas Plant.



3.1 Process Safety Information per Company procedure PM-202



The Caspiana 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 key process parameter limits and equipment design basis/configurat
ion information.



Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in the material safety data sheets (SDS). 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 company 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. Original equipment manufacturer information and industry standards are utilized to 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.



3.2 Process Hazard Analysis per Company Procedure PM-204



The Caspiana Gas Plant has a comprehensive program to help ensure that hazards associated with the process are identified and controlled. Within this program, the process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. Where deficiencies are identified, recommendations are made to reduce associated risk below unacceptable levels.



The Caspiana Gas Plant primarily uses HAZOP methodology to perform these evaluations, also known as Process Hazard Analysis (PHA), performed by an interdisciplinary team. The PHA findings are systematically resolved in a timely manner acceptable to Enable Operations Leadership.

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 Hazard Review team.



3.3 Operating Procedures
per Company procedure PM-206



Written operating procedures have been developed that provide instructions to safely operating and conducting activities related to the covered process. Operating procedures have been developed for the following operating phases where applicable to the process:

- Initial startup

- Normal operations

- Temporary operations

- Emergency shutdown

- Emergency operations

- Normal shutdown

- Startup following a normal or emergency shutdown or a major change



Information presented in operating procedures must include steps necessary to conduct activities, as well as, consequences of deviating; steps to avoid and/or correct deviations; and equipment inspections necessary for equipment. Operating procedures will be updated whenever a change is made to the process that alters the steps needed to operate safely. This update may be triggered when new equipment is added, equipment is removed, or when Process Safety Information changes.



3.4 Training per Company procedure PM-208



To complement the written process operation procedures, the Caspiana Gas Plant has implemented a comprehensive training program for all employees assigned operations and maintenance duties for the process. 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.



3.5 Mechanical Integrity Program per Company procedure PM-214



In order to assure the integrity of equipment used to store, process or handle regulated substances, the Caspiana Gas Plant has implemented a mechanical Integrity Program (MIP). The MIP consists of procedures for proper maintenance, inspection and testing of process equipment and training for maintenance personnel in accordance with recognized and generally accepted standards and practice
s.



3.6 Management of Change per Company procedure PM-216



In order to maintain current and accurate process safety information and operating procedures, the Caspiana Gas Plant is subject to the management of change MOC procedure. Managing changes ensures that each change to the process is evaluated thoroughly by those with appropriate knowledge, any associated hazards are identified and mitigated, and that the change is implemented safely.



3.7 Pre-Startup Safety review per Company procedure PM-212



The Caspiana Gas Plant has established and implemented written procedures to ensure that a pre-startup safety review (PSSR) is performed prior to the introduction of a regulated substance, into a new process or following a change to an existing process. PSSRs ensure that the process or change has been completed as designed and is safe for the introduction of hazardous substances.



3.8 Compliance Audits per Company procedure PM-222



To help ensure that the accident prevention program is properly functioning, the Caspiana Gas Plant periodically conducts audits to determine whether the procedures and practices required by the accident prevention program are being followed correctly. Compliance audits are to be conducted at least every 3 years. The audit team develops findings and appropriate corrective actions are developed by Enable Operations Leadership to resolve the findings. The final resolution of each finding is documented, and the two most recent audit reports are retained.



3.9 Incident Investigation per Company procedure PM-218



The Caspiana Gas Plant has a procedure in place to promptly investigate all releases of regulated substances 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 performed by team
consisting of those with appropriate knowledge and experience in the process. The findings and recommendations made by the incident investigation team are promptly 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.



4.0 The Five-Year Accident History



There have been no accidents at the Caspiana Gas Plant in the last five years.



5.0 The Emergency Response Program



All emergency response activities are coordinated with local emergency planning and/or response agencies. For the Caspiana Gas Plant the local emergency response agency is Caddo Parish Fire District Five.



The Caspiana Gas Plant is unmanned and employees who are assigned operations and maintenance activities to not respond to releases of regulated substances. Therefore, this facility is not subject to the emergency response program requirements of 40 CFR Part 68.95 per the exemption of 40 CFR Part 68.90(b).



6.0 Planned Changes to Improve Safety



In order to reduce the risk of exposing facility personnel and public receptors to releases of regulates substances as low as reasonably practicable, the Caspiana Gas Plant plans to make the following changes to the process:

- Additional overpressure protection

- Additional automated shutdowns