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Benton Separation Facility

Parent Companies:
Empresa Energy IV, LLC
EPA Facility ID:
100000195059
Other ID:
Facility DUNS:
0
Parent Company DUNS:
0

Location:

Address:
Cycle Plant Road
Benton, LA 71006
County:
BOSSIER
Lat / Long:
32.745, -93.656 (Get map)
Method:
GPS - Unspecified
Description:
Storage Tank
Horizonal accuracy:
10 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
Empresa Energy IV, LLC
Phone:
(713) 463-3925
Address:
9821 Katy Fwy. #910
Houston, TX 77024
Foreign Address:

Person responsible for RMP implementation:

Name:
W. Ricky Harris
Title:
Vice President - Operations

Emergency contact:

Name:
Bubba Cook
Title:
Senior Production Foreman
Phone:
(318) 465-0730
24-hour phone:
(318) 465-0730
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
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:
June 19, 2013
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Refrigeration Plant
RMP ID:
1000070761
CBI claimed:
No
Program Level:
2
NAICS:
Natural Gas Liquid Extraction (211112)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
169,633
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Larry N. Cooper
Address:
400 Texas St. Suite 600
Shreveport, LA 71101
Foreign Address:

Phone:
(318) 429-2358

Latest RMP Submission:

Date:
April 6, 2016
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000056666

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 Refrigeration Plant)
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 Refrigeration Plant)
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

Refrigeration Plant, Natural Gas Liquid Extraction (211112)
Prevention Program ID:
1000044414
Safety Review Date
March 14, 2013, since latest RMP submission
PHA Update Date
, since latest RMP submission
Safety Regulations
  • None
Hazards Identified
  • Fire
  • Explosion
  • Overfilling
Process Controls
  • None
Mitigation Systems
  • Dikes
Monitoring Systems
  • None
Changes since PHA
  • None Recommended
Training Type
  • On the Job
Competency Testing
  • Oral Test
  • Demonstration
Procedure Review Date
March 10, 2016, since latest RMP submission
Training Review Date
March 11, 2016, since latest RMP submission
Maintenance Review Date
March 11, 2016, since latest RMP submission
Maintenance Inspection Date
April 5, 2016, 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
July 15, 2016
Compliance Audit Change Completion Date
July 15, 2016
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) 965-9454
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

Executive Summary



BENTON SEPARATION FACILITY RISK MANAGEMENT PLAN: EXECUTIVE SUMMARY



ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES



Empresa Energy IV, LLC (Empresa) has recently purchased this Benton Separation Facility from Samson Contour Energy E&P, LLC (Samson). Like Samson, Empresa has a long-standing commitment to workers 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 facilityA?s processes. Empresa is dedicated to implementing reasonable controls to prevent foreseeable releases of substances.



DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES



Empresa operates the Benton Separation Facility located in Bossier Parish, Louisiana. Benton is a natural gas processing plant that produces liquefied natural gas (LNG) by mechanical refrigeration with water removal by glycol dehydration. The LNG, a mixture of ethane, propane, butanes, pentanes, hexanes, and C6+ compounds, is stored in a pressurized bullet tank for transportation by truck. A level switch is installed on the bullet tank, which provides a shut in on the compressor and refrigeration unit and calls out the operator in the event of a high level situation. Condensate and produced water is also stored onsite prior to transportation from the site via tanker trucks. As evidenced in the ensuing text and based on criteria outlined in the Accidental Release Prevention (ARP) Program, Benton is a Program 2 RMP process.



Operations at Benton were evaluated while owned by Samson 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. None of these processes or operations of the facility have changed as a result of the recent change in ownership.



FIVE-YEAR ACCIDENT HISTORY



Benton has not had any accidental releases which meet the criteria outlined in 40 CFR 68.42(a).



GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM



The following is a summary of the accident prevention program in place at Benton:



Employee Participation



Empresa actively encourages all 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 RMP rule compliance based on their knowledge, skill, job responsibilities, and experience.



Process Safety Information



Empresa 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/configuration information.



Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in the safety data sheets (SDSs) of the materials being used at the facility to which employees could potentially be exposed. 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.



Hazard Review and Analysis



Empresa has a comprehensive program to ensure that hazards associated with the process are identified and controlled. Within this program, each process is systematicall
y examined to identify hazards and ensure that adequate controls are in place to manage these hazards.



Empresa primarily uses the checklist method to perform these evaluations. The checklist used in the Hazard Review was provided by persons knowledgeable about the process. Based on the answers to the questions, consequences and preliminary recommendations can be determined.



The Hazard Review findings are promptly and systematically addressed. Empresa assures that the recommendations are documented and resolved in a timely manner. This documentation includes the actions to be taken and a written schedule of completion dates. All Hazard Review findings are communicated with Empresa employees and contractors that may be affected.



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.



Operating Procedures



The Benton facility 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.



Training



To complement the written process operating procedures, Empresa continues implementing 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 operat
ions, and safe work practices. Operators demonstrating adequate knowledge to safely perform duties and tasks are allowed to work independently.



Mechanical Integrity



Empresa continues the use of well-established programs, procedures, and practices that are required to ensure that equipment used to process, store, or handle flammable material 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., monitoring 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 employeeA?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.



Incident Investigation



Empresa 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 affect
ed by the findings.



Emergency Planning and Response



Emergency Response activities for the Benton facility are coordinated with the local fire department and LEPC. In the case of an accidental release, the Empresa employee will activate the emergency shutdown system if possible and evacuate upwind of the release. They will immediately notify the local fire department who will then respond to the emergency.



Compliance Audits



To ensure that the accident prevention program is functioning properly, Empresa periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. 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 which 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



Empresa is committed to operating the Benton facility in a safe manner for workers, the public, and the environment. Empresa personnel have an opportunity to make suggestions that could improve the safety of this facility during regional safety meetings. Emprresa will also conduct compliance audits and hazard reviews as required and make improvements to safety based on findings of the audits and reviews.