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Gravel Point Plant

Parent Companies:
J-W Energy Company
EPA Facility ID:
100000215215
Other ID:
Facility DUNS:
0
Parent Company DUNS:
0

Location:

Address:
1131 Gravel Point Rd.
Frierson, LA 71027
County:
DE SOTO
Lat / Long:
32.237, -93.639 (Get map)
Method:
Interpolation - Satellite
Description:
Plant Entrance (General)
Horizonal accuracy:
12 m
Horizontal reference datum:
World Geodetic System of 1984
Source map scale:

Owner/Operator:

Name:
J-W Gathering Company
Phone:
(972) 233-8191
Address:
P.O. Box 226406
Dallas, TX 75222 -6406
Foreign Address:

Person responsible for RMP implementation:

Name:
Jim Rumsey
Title:
Regulatory Affairs

Emergency contact:

Name:
Robert Lewis
Title:
Operations Foreman
Phone:
(318) 925-8088
24-hour phone:
(800) 274-0033
Ext or PIN:
Email:
N/A

Other contacts:

Facility (or company) email:
Facility phone:
(318) 925-7363
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Desoto Parish LEPC
Full-Time Equivalent Employees:
4
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:

LPG Process
RMP ID:
1000028094
CBI claimed:
No
Program Level:
3
NAICS:
Natural Gas Liquid Extraction (211112)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
561,000
No
Propane
74-98-6
27,500
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
C-K Associates, LLC
Address:
2001 East 70th Street, Suite 503
Shreveport, LA 71105
Foreign Address:

Phone:
(318) 797-8636

Latest RMP Submission:

Date:
July 15, 2011
Type:
First-time submission
Reason:
Registered:
No
RMP ID:
1000023018

Deregistration:

Date:
Effective Date:
Reason:
Source no longer uses any regulated substance
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 LPG Process)
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 LPG Process)
CBI claimed:
No
Model used:
EPA Release Guidance
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

Jan. 2, 2009 at 09:30
ID:
1000018556
NAICS:
Natural Gas Liquid Extraction (211112)
Duration:
1 hours
Chemicals involved:
  • Flammable Mixture
Release events:
Gas release
Fire
Weather conditions at time of event
Wind speed:
None
Temperature:
None ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
Yes
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
1
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$0
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Human Error
Contributing factors:
  • Human error
  • Process design failure
Off-site responders notified:
No, not notified
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Revised training
  • New process controls
Nov. 19, 2008 at 08:00
ID:
1000018616
NAICS:
Natural Gas Liquid Extraction (211112)
Duration:
1 hours
Chemicals involved:
  • Propane
Release events:
Gas release
Fire
Weather conditions at time of event
Wind speed:
None
Temperature:
None ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
Yes
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
0
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$0
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Human error
Off-site responders notified:
No, not notified
Changes introduced as a result of the accident:
  • Improved/upgraded equipment

7. Prevention: Program level 3

LPG Process, Natural Gas Liquid Extraction (211112)
Prevention Program ID:
1000024316
Safety Review Date
May 17, 2011, since latest RMP submission
PHA Update Date
May 17, 2011, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Grounding Equipment
  • Rupture Disks
  • Excess Flow Device
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Demonstration
  • Observation
Procedure Review Date
June 24, 2011, since latest RMP submission
Training Review Date
June 24, 2011, since latest RMP submission
Maintenance Review Date
May 17, 2011, since latest RMP submission
Maintenance Inspection Date
May 27, 2011, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
June 23, 2011
Management of Change Review Date
June 23, 2011
Pre-startup Review Date
June 23, 2011
Compliance Audit Date
Feb. 20, 2011
Compliance Audit Change Completion Date
June 17, 2012
Incident Investigation Date
Jan. 7, 2009
Incident Invest. Change Completion Date
March 31, 2009
Participation Plan Review Date
May 17, 2011
Hot Work Review Date
May 17, 2011
Contractor Safety Review Date
May 17, 2011, since latest RMP submission
Contractor Safety Eval. Date
June 14, 2011, 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:
Jan. 27, 2011
Local Response Agency:
Local Response Agency Phone:
(318) 797-0025
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
No
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES
The Risk Management Plan for the Gravel Point Plant is being updated because a new refrigeration unit was installed at this facility. Prior to startup of the refrigeration unit, a Risk Management Plan was developed to include operating procedures, process safety information, and other process-specific information required for the RMP. A Process Hazard Analysis has been conducted for the new process.

ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES
The Gravel Point 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. The J-W Gathering (J-W) policy is to implement reasonable controls to prevent foreseeable releases of substances.

DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES
J-W operates the Gravel Point Plant located in DeSoto Parish, Louisiana. The Gravel Point Plant receives raw natural gas from well production. The raw gas is dehydrated and contaminants removed. Marketable natural gas is delivered via pipelines. Natural gas liquids are extracted and stored on site. The extracted natural gas liquids include ethane, propane, butane, and a pentane-natural gasoline mixture that are delivered to market via transportation vehicles. There are no listed toxic substances which exceed their respective threshold quantities stored at this facility.

FIVE YEAR ACCIDENT HISTORY
The Gravel Point Plant had one release-related injury in 2009 which was the result of a leaking ball valve. An incident inverstigation was initiated immediately and process changes and improvements were implemented to prevent recurrence of similar accidents.

LOCAL EMERGENCY RESPONSE COORDINATION
The Gravel Point Plant has coordinated its emergency response activities with the local emergency pla
nning and response agencies as required in 40 CFR 68.12(b)(3).

GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM
The following is a summary of the accident prevention program in place at the Gravel Point Plant. Because plant processes are subject to EPA's RMP regulations and to OSHA's PSM standards, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program.

Employee Participation
J-W and the Gravel Point Plant actively encourage all levels of 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 PSM rule compliance based on their knowledge, skill, job responsibilities, and experience.

Process Safety Information
The Gravel Point 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 for key process parameter limits and equipment design basis/configuration information. Specific departments within the plant are assigned responsibility for maintaining up-to-date process safety information.

Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in the material safety data sheets (MSDSs). This information is supplemented, when required, by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. 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 plant also maintains documentation that provides in
formation about the design and construction of process equipment. Equipment information includes construction materials, design pressure, and temperature and electrical ratings. This information provides a basis for establishing inspection and maintenance activities, as well as for evaluation proposed process and facility changes to ensure that safety features in the process are not compromised.

Process Hazard Analysis (PHA)
The Gravel Point Plant has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.

The Gravel Point Plant primarily uses the HAZOP and checklist methods to perform these evaluations. Combined, these techniques provide a highly structured approach where process parameters such as flow and temperature are examined for deviations from their intended design. Deviation effects are considered in order to determine resulting potential hazards while preliminary recommendations for improvement are proposed.

The PHA team findings are promptly and systematically addressed. The Gravel Point Plant 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. The plant also provides proof of communication with operating, maintenance, and other employees whose work assignments are in the process and who may be affected by the recommendations.

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 will be conducted at least every five years by the PHA team.

Operating Procedures
The Gravel Point Plant maintains written procedures that address variou
s modes of process operations, such as (1) initial startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) 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 through the management of change process.

Training
To complement the written process operation procedures, the Gravel Point Plant has implemented 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 operations, and safe work practices. Operators demonstrating adequate knowledge to safely perform duties and tasks are allowed to work independently.

Hot Work Permit
The Gravel Point Plant issues a hot work permit for all hot work operations conducted on or near a covered process. The Gravel Point Plant provides Hot Work Permit training to all plant employees. Copies of issued work permits are maintained in Operations and Maintenance for a period of 1 year following completion of work.

Contractors
The Gravel Point Plant periodically uses contractors to perform maintenance or repair, turnaround, major renovations, or specialty work on or adjacent to a covered process. Because some contractors work on or near process equipment, the plant has procedures in place to ensure that contractors (1) are trained in the work practices necessary to safely perform his/her job, (2) follow the safety rules of the location including the safe work practices, (3)advise the plant of any unique hazards presented by the contractor, and (4) notify the facility of all illnesses and injuries that occur in the process areas.

Pre-Startup Sa
fety Reviews (PSSRs)
The Gravel Point Plant conducts a PSSR for any facility modification that requires a change in the 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. This review provides an additional cheeck to make sure that construction and equipment are in accordance with design specification, that adequate safety, operating, maintenance, and emergency procedures are in place, and that training of each employee involved inoperating the process or equipment has been completed. A standard checklist is used to document compliance.

Mechanical Integrity
The Gravel Point Plant has well-established programs, procedures and practices that are required to ensure that equipment used to process, store, or handle lightly hazardous chemicals and/or flammable gas or liquid 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 employee'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.

Management of Change
The Gravel Point Plant has a comprehensive system to manage and document changes to all covered processes. A systematic approach is followed to control and manage facility changes
in order to minimize the possiblity that such changes will have an adverse impact on personnel safety, equipment, or the environment. Employees involved in process operations and maintenance and contract employees whose ob tasks might be affected by process changes are informaed of and trained in the change prior to process start-up.

Incident Investigation
The Gravel Point Plant 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 that incident. This investigation is lead 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 affected by the findings.

Emergency Planning and Response
The Gravel Point Plant retains a written emergency response plan which includes the designated actions the company and all personnel will take to ensure personal safety from fire and other emergencies. The plan outlines actions that company technicians and contract employees are to take when there is an unwanted release of highly hazardous chemicals. The intent of this plan is to facilitate the prompt evacuation of employees when necessary and to account for all personnel.

Compliance Audits
To help ensure that the accident prevention program is properly functioning, the Gravel Point Plant 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 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
J-W is committed to operating the Gravel Point Plant in a safe manner for workers, the public, and the environment. J-W personnel have an opportunity to make suggestions that could improve the safety of this facility during monthly regional safety meetings. J-W will also conduct compliance audits and hazard reviews as required and make improvements to safety based on findings of the audits and reviews.