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Lake Charles Depropanizer Plant

Parent Companies:
Petrologistics, LLC
EPA Facility ID:
100000213235
Other ID:
Facility DUNS:
610322633
Parent Company DUNS:
610322633

Location:

Address:
504 Dave Dugas Rd
Sulphur, LA 70665
County:
CALCASIEU
Lat / Long:
30.164, -93.362 (Get map)
Method:
Unknown
Description:
Unknown
Horizonal accuracy:
10 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
P.L. Midstream, LLC
Phone:
(225) 706-7683
Address:
4460 Bluebonnet, Suite B
Baton Rouge, LA 70809
Foreign Address:

Person responsible for RMP implementation:

Name:
Jerry Guidry
Title:
Lake Charles Depropanizer Supervisr

Emergency contact:

Name:
Jerry Guidry
Title:
Lake Charles Depropanizer Supervisr
Phone:
(337) 313-1029
24-hour phone:
(866) 574-4483
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(225) 706-7700
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Calcasieu Parish LEPC
Full-Time Equivalent Employees:
13
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:
Inspecting Agency:
Never had one
Using Predictive Filing:
No

Processes:

Storage of Flammables
RMP ID:
1000033793
CBI claimed:
No
Program Level:
3
NAICS:
Petrochemical Manufacturing (32511)
Chemical name
CAS#
Quantity (lbs.)
CBI
Propane
74-98-6
290,000
No
Isobutane [Propane, 2-methyl]
75-28-5
500,000
No
Butane
106-97-8
500,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Eagle Environmental Services Inc.
Address:
18639 Petroleum Drive
Baton Rouge, LA 70809
Foreign Address:

Phone:
(225) 757-0870

Latest RMP Submission:

Date:
July 10, 2012
Type:
Resubmission
Reason:
Revised OCA due to change (40 CFR 68.190(b)(6))
Registered:
No
RMP ID:
1000027683

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 Storage of Flammables)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
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 of Flammables)
CBI claimed:
No
Model used:
PHAST dispersion model
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

Storage of Flammables, Petrochemical Manufacturing (32511)
Prevention Program ID:
1000029523
Safety Review Date
Dec. 20, 2010, since latest RMP submission
PHA Update Date
Dec. 28, 2010, since latest RMP submission
PHA Techniques
  • What if/Checklist
Hazards Identified
  • Fire
  • Explosion
  • Corrosion
  • Equipment failure
Process Controls
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • None Recommended
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
April 5, 2012, since latest RMP submission
Training Review Date
June 9, 2010, since latest RMP submission
Maintenance Review Date
Dec. 20, 2010, since latest RMP submission
Maintenance Inspection Date
May 13, 2010, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
July 1, 2010
Management of Change Review Date
Nov. 15, 2010
Pre-startup Review Date
Dec. 28, 2010
Compliance Audit Date
None
Compliance Audit Change Completion Date
None
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
April 27, 2011
Hot Work Review Date
Aug. 10, 2009
Contractor Safety Review Date
July 6, 2010, since latest RMP submission
Contractor Safety Eval. Date
None, 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:
March 27, 2011
Local Response Agency:
Local Response Agency Phone:
(337) 721-3800
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
No
Subject To - CWA:
No
Subject To - RCRA:
No
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

PetroLogistics Lake Charles Depropanizer Plant, located in Sulphur, Louisiana, has a standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, training of highly qualified personnel, and considering safety in the design, installation, operation and maintenance of our processes. Our policy is to implement reasonable controls to prevent chemical releases. However, if a release does occur, our trained personnel will respond to control, contain, and mitigate the release.



PetroLogistics Lake Charles Depropanizer Plant uses a mixed hydrocarbon gas feed to produce several regulated flammables such as propane, butane and ethane. Chemicals maintained on site at the plant, listed on the EPA's list of flammable chemicals, and are above EPA's threshold quantity are butane, isobutane and propane. Other regulated chemicals used in our process, which are stored below the threshold quantity, may be present but not subject to RMP.



Process Safety Information



The Lake Charles Depropanizer Plant maintains a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters, specific chemical inventories, and equipment design basis/configuration information. Specific departments within the chemical complex are assigned responsibility for maintaining up-to-date process safety information. Employees are provided training on how to locate the information from various computer terminals located throughout the chemical complex.



Chemical specific information, including exposure hazards and emergency response/exposure considerations, is provided in material safety data sheets (MSDS). This information is supplemented by documents that address known corrosion concerns and known hazards associated within inadvertent mixing of specific chemicals. For the different process are
as, the chemical complex has documented safety related limits for specific process parameters (e.g. temperature, pressure, composition, etc.). The chemical complex insures that the processes are maintained within the limits using process controls, monitoring instruments, protective instrument systems, and highly trained personnel.



The Lake Charles Depropanizer Plant also maintains a database, this accessible by both the employees and contractor supervision, which provides information about the design pressure and temperature ratings, electrical classification, etc. 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



The Lake Charles Depropanizer Plant has a comprehensive program to help ensure the hazards associated with the various processes are identified and controlled. Within this program, each process is systemically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.



The Lake Charles Depropanizer Plant primarily used the What-if/Checklist method for future Process Hazard Analysis. The analysis is conducted using a team of people who have operating and maintenance experience as well as engineering expertise. The team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary.



The PHA team findings are made available to people associated with the process for comments and forwarded to local and corporate management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative ranking assigned by the PHA team. This ranking helps ensure
that potential accident scenarios assigned the highest rank receive immediate attention. All approved mitigation options being implemented in response to PHA findings are tracked until they are complete. The final resolution of each finding is documented and retained.



Operating Procedures



Operators, supervisors, and plant engineers work together to develop and maintain operating procedures. These procedures define how tasks related to process operations and safely performed. At the Lake Charles Depropanizer Plant, operating procedures are used to train employees and serve as reference guides for appropriate actions to take during both normal operations and process upsets. Operating procedures include:

- Steps for safely conducting activities

- Applicable process safety information, such as safe operating limits,

- Safety and health considerations, such as chemical hazards, personnel protective equipment required and steps to take if exposed to a particular chemical.



Plant personnel develop and maintain operating procedures that cover all phases of operations, including initial startup, normal operation, normal shutdown, emergency shutdown, startup following a turnaround or emergency shutdown, and temporary operations.



Training



The Lake Charles Depropanizer Plant trains its workers to safely and effectively perform their assigned tasks. The training program includes both initial and refresher training.



All new employees assigned as operators receive comprehensive training before being assigned to a specific operating area. This training includes training on specific types of equipment, such as pumps and compressors, general overview of the process, properties and hazard substances in the process, and detailed review of complex procedures, such as, safe work practices and of emergency response. Oral review and written tests are used to verify that employees understand the training material before a new employee can report to a process u
nit. Once a new employee reports to a particular process area, he receives detailed training with respect to process specific procedures and for specific tasks; he is allowed to begin work in a specific operating area.



Annual refresher training covers a general overview of the process, the properties and hazards of the substances in the process and, a review of the process operating procedures and safe work practices. Oral review and written tests are used to verify that employees understand the training before an employee can resume work in the process. The operators have been consulted in safety meetings and through questionnaires regarding effectiveness and frequency of training. Recommendations are reviewed and changes to the training program are implemented as appropriate.



Management of Change



The Management of Change program for the Lake Charles Depropanizer Plant evaluates and approves all proposed changes to chemicals, equipment, and procedures for covered processes to help ensure that a change does not negatively affect safe operations. Process changes that are determined to be a replacement in kind (e.g. replacing a valve with an identical valve) are allowed without completing a full management of change program. All other changes must be confirmed through a full management of change program to help ensure process safety information and procedures are updated, and affected employees are notified of the change.



Pre-Startup Safety Review (PSSR)



The Lake Charles Depropanizer Plant conducts a safety review of a new or modified process before the process is placed in service. The purpose of the PSSR is to ensure the safety features, procedures, personnel and equipment are appropriately prepared for startup prior to placing the equipment in service. The review provides one additional check to make sure construction of new processes and significant modifications to existing processes are, in accordance with the design specifications and
that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A 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 Lake Charles Depropanizer Plant has well established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, emergency shutdown systems, and rotating equipment (pumps and compressors) in a safe operating condition. The basic aspects of this program include (1) conducting training, (2) develop written procedures, (3) perform inspections and tests, (4) correcting identified deficiencies and, (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process.



Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices. Written procedures help ensure that work is performed in consistent manner and provides basis for training. Inspections and tests are performed to help ensure that equipment is within acceptable limits (e.g. adequate wall thickness for pressure vessels). If a deficiency is identified, the equipment will be repaired in a timely manner. All outstanding deficiencies are tracked until such time a final solution has been implemented and documented.



Another integral part of the mechanical integrity program is quality assurance. The Lake Charles Depropanizer Plant incorporates quality assurance into equipment purchase and repairs. This helps ensure that new equipment is suitable for intended use and that proper materials and spare parts are used when repairs are made.



Safe Work Practices



The Lake Charles Depropanizer Pla
nt has a safe work program in place to ensure worker safety. Examples of the program include (1) control of the entry/presence/exit of support personnel, (2) lockout/tagout procedures to ensure isolation of energy sources for equipment undergoing maintenance, (3) procedures for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedures to conduct spark producing activities (i.e. hot work), and (5) a permit and procedures 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.





Incident Investigation



The Lake Charles Depropanizer Plant investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public, or the environment so similar incidents can be prevented. Employees at the plant are trained to identify and report any incident requiring investigation. The investigation is initiated within hours of the incident. Depending on the incident, an investigation team may be formed. Results of the investigation are documented and appropriate changes are made.



Employee Participation



The Lake Charles Depropanizer Plant maintains a written employee participation program to help ensure that safety and environmental concerns of the plant workers are addressed. The plant encourages active participation of personnel in safety, health, and environmental activities at the plant. Employees are consulted and/or informed about all aspects of the RMP prevention program including PHA's (Process Hazard Analysis) and operating procedures.



Compliance Audits



The Lake Charles Depropanizer Plant audits the covered processes to be certain that the prevention program is effectively addressing safety, health, and environmental issues. The complex assembles an audit team that includes personnel
knowledgeable in the processes. This team evaluates whether the prevention program satisfies the requirements of the RMP rule and whether the prevention program is sufficient to ensure safe operation of the complex. The results of the audit are documented, recommendations are resolved, and appropriate enhancements made to the operations of the plant.



Contractors



The Lake Charles Depropanizer Plant has established a program to help ensure that contractor activities are performed in a safe manner. This program reviews the safety record of the contractors to ensure the plant only hires contractors who can safely perform the desired task. The complex communicates to the contractor supervisor the hazards of the process on which they and their employees will work, the plant's safe work practices, and the plant's emergency response procedures. The plant requires that the contractor supervisors train each of their employees on hazards and procedures specific to the complex site.



Five Year Accident History



The facility has experienced zero events which had offsite impacts.



Emergency Response Program



The Lake Charles Depropanizer Plant emergency response program has been developed to meet the emergency planning, response, and notification requirements of the regulations listed below.



? OSHA 29 CFR 1910.38(a)-Employee Emergency Action Plans

? OSHA 29 CFR 1910.120(q)-Hazardous Waste Operations and Emergency Response (HAZWOPER)

? OSHA 29 CFR 1910.119(n)-Process Safety Management of Highly Hazardous Chemicals

? OSHA 29 CFR 1910 Subpart L-Fire Protection

? LADEQ LAC 33.1? 3901-Notification Regulations for Unauthorized Discharge

? LDPS Title 33, Part V, Subpart 2, Ch.101? 1011-Release Reporting

? EPA 40 CFR Part 302.6- Notification Requirements

? EPA 40 CFR Part 355.40-Emergency Planning and Release Notification

? EPA 40 CFR Part 68-Risk Management Programs for Chemical Accidental Release Program

? EPA 40 CFR Part 355.30-Facility Coordinator an
d Emergency Response Plan

? EPA 40 CFR Part 112-Spill prevention, Control and Countermeasures Plan

? EPCRA 302-List of Extremely Hazardous Substances



The emergency response strategy for the plant is to prevent and/or control emergency situations via the use of engineering, design, and fixed protection systems. All employees are trained to handle and respond to emergencies, and take actions to contain, control, and mitigate any release that might occur. The team has access to on-site emergency equipment which is appropriate for situations that could possibly occur at the plant. These items include those listed below.



? Fire pumps w/fixed firewater system

? Fire Monitors

? Fire Extinguishers

? Water Deluge Systems

? Fixed Extinguishing Systems



Drills are conducted to assess the emergency response effort at the Lake Charles Depropanizer Plant.



Planned Changes to Improve Safety



The Lake Charles Depropanizer Plant constantly strives to improve safety and reduce risk through auditing, suggestions from employees, incident investigations, and the use of proper engineering standards and specifications.