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Walton CDP (S23 15N 15W)

Parent Companies:
Indigo Minerals, LLC
EPA Facility ID:
100000215395
Other ID:
Facility DUNS:
0
Parent Company DUNS:
0

Location:

Address:
Appx 15 miles SW of Shreveport
Shreveport, LA 71047
County:
CADDO
Lat / Long:
32.277, -93.877 (Get map)
Method:
GPS - Unspecified
Description:
Center of Facility
Horizonal accuracy:
50 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
Indigo Minerals, LLC
Phone:
(713) 237-5012
Address:
600 Travis Street
Suite 4900
Houston, TX 77002
Foreign Address:

Person responsible for RMP implementation:

Name:
Mr. Fred Bakun
Title:
Sr. Vice President of Engineering

Emergency contact:

Name:
Darrell Pepper
Title:
Production Superintendent
Phone:
(318) 263-7500
24-hour phone:
(800) 865-2708
Ext or PIN:
Email:
N/A

Other contacts:

Facility (or company) email:
Facility phone:
(713) 237-5012
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Caddo 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:
Inspecting Agency:
Never had one
Using Predictive Filing:
No

Processes:

JT plant
RMP ID:
1000028610
CBI claimed:
No
Program Level:
2
NAICS:
Natural Gas Liquid Extraction (211112)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
275,080
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Will Ward
Address:
400 Texas Street
Suite 600
Shreveport, LA 71101
Foreign Address:

Phone:
(318) 429-2267

Latest RMP Submission:

Date:
Sept. 20, 2011
Type:
First-time submission
Reason:
Registered:
No
RMP ID:
1000023418

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 JT 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 JT plant)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • Dikes
  • Fire wall
not considered:
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
Public OCA Chemical (in JT plant)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • Dikes
  • Fire wall
not considered:
  • 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

JT plant, Natural Gas Liquid Extraction (211112)
Prevention Program ID:
1000019793
Safety Review Date
Sept. 16, 2011, since latest RMP submission
PHA Update Date
, since latest RMP submission
Safety Regulations
  • ASME Standards
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
  • Overfilling
Process Controls
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
Mitigation Systems
  • Dikes
  • Fire Walls
Monitoring Systems
  • None
Changes since PHA
  • None Recommended
Training Type
  • On the Job
Competency Testing
  • Observation
Procedure Review Date
Sept. 14, 2011, since latest RMP submission
Training Review Date
Sept. 16, 2011, since latest RMP submission
Maintenance Review Date
Sept. 16, 2011, since latest RMP submission
Maintenance Inspection Date
Sept. 16, 2011, 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
None
Compliance Audit Change Completion Date
None
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:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
Sept. 16, 2011
Local Response Agency:
Local Response Agency Phone:
(318) 425-5351
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

Walton CDP Facility Risk Management Plan
Executive Summary

DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES
Indigo Minerals, LLC owns and operates the Walton CDP Facility located in Caddo Parish, LA. The facility receives sweet natural gas and reservoir fluids from the Walton 23H #1 and the Walton 23 #1 well sites. The natural gas is separated from reservoir fluids, dehydrated, cooled by the Joules-Thompson effect (JT), compressed and sent to sales. The natural gas liquids produced from the JT plant are stored in pressurized tanks and eventually hauled by truck to sales.

ACCIDENT RELEASE PREVENTION AND RESPONSE POLICIES
Indigo Minerals, LLC has a commitment to worker safety 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 our processes. Our policy is to implement reasonable controls to prevent foreseeable releases. However, if a release does occur, the Emergency Response Plan will be initiated and trained personnel will respond to control and contain the release as well as notify local emergency response agencies for assistance.

GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM
The following is a summary of the accident prevention program in place at the facility. The processes at the Walton CDP Facility are regulated by the Environmental Protection Agency's (EPA's) Risk Management Program (RMP) regulation. This summary addresses the elements of the Walton CDP Facility's accident prevention program and describes the management system in place to implement the accident prevention program.

PROCESS SAFETY INFORMATION
The Walton CDP Facility keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address limits for key process parameters and specific equipment design and configuration information. Personnel responsible for the o
peration of the facility 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 Material Safety Data Sheets (MSDS). For specific process areas, the facility has documented safety related limits for specific process parameters (e.g., temperature, pressure, level) on the Pipe and Instrumentation Diagram (P&IDs). The facility personnel ensure that the process is maintained within these limits using process controls and monitoring instruments and protective instrument systems (e.g., automated and manual shutdowns).

Indigo Minerals, LLC also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construction and design pressures. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as evaluating proposed process and facility changes to ensure that safety features in the process are not compromised.

PROCESS HAZARD ANALYSIS

The Walton CDP Facility 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 Walton CDP Facility primarily uses the "What if" analysis technique to perform these evaluations. The analyses are conducted by trained and knowledgeable personnel who have operating and maintenance experience as well as engineering expertise. The PHA personnel identify and evaluate hazards as well as accident prevention and mitigation measures, and make suggestions for additional prevention and/or mitigation measures as necessary.

The PHA findings are forwarded to management f
or 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 ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options in response to PHA findings are tracked until they are completed. The final resolution of each finding is documented and retained. To help ensure that the process controls and/or process hazards do not eventually deviate significantly 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 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 PHA findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained.

OPERATING PROCEDURES
The Walton CDP Facility maintains written procedures that address various modes of operation such as 1) Unit Startup, 2) Normal Operations, 3) Emergency Shut Down, 4) Normal Shutdown. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. These procedures are periodically reviewed at least annually to verify completeness and accuracy.

In addition, the facility maintains a procedure that provides guidance on how to respond to upper or lower limit deviations for specific process or equipment parameters. This information, along with written operating procedures, is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks.

TRAINING

To complement the written procedures for process operations, the Walton CDP Facility has implemented a comprehensive training program for all employees involved in operating
a process. New employees receive basic training in gas plant operations if they are not already familiar with such operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate (e.g., through tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every 3 years. All of this training
is documented for each operator, including the means used to verify that the operator understood the training.

CONTRACTORS

The Walton CDP Facility uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the gas plant has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform gas plant personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to their beginning work. In addition, Indigo Minerals, LLC evaluates contractor safety programs and performance during the selection of a contractor. Gas plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations.

PRE-STARTUP SAFETY REVIEWS (PSSRs)

The Walton CDP Facility conducts a PSSR for any n
ew facility or 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 one additional check to make sure construction is 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 Walton CDP Facility has established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) performing 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 to help ensure that they can perform their jobs in a safe manner. Written procedures help ensure that work is performed in a consistent manner and provide a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into servi
ce (if possible), or a management of change team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment.


Another integral part of the mechanical integrity program is quality assurance. The Walton CDP Facility incorporates quality assurance measures into equipment purchases and repairs. This helps ensure 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 Walton CDP Facility has safe work practices in place to help ensure worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous substances before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely.

MANAGEMENT OF CHANGE

The Walton CDP Facility has a comprehensive system to manage changes to all covered processes. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) 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 change.

INCIDENT INVESTIGATION

The Indigo Minerals, LLC's policy is to promptly investigate 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. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to gas plant management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. 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. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs.

COMPLIANCE AUDITS

To help ensure that the accident prevention program is functioning properly, the Walton CDP Facility periodically conducts an internal audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. Both on-site and corporate personnel participate as audit team members. The audit team develops findings that are forwarded to gas plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. 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 Walton CDP Facility have hazards that must be managed to ensure continued safe operation. The following is a description of existing safety feat
ures applicable to prevention of accidental releases of regulated substances in the facility.

Specialized Safety Features

The Walton CDP Facility has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in the covered processes:

Release Detection
Release Containment/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)
Automated shutdown systems for specific process parameters (e.g., high temperature)

Release Mitigation
Fire extinguishers located through the plant
Trained emergency response personnel
Personal protective equipment (e.g., fire retardant clothing)

FIVE-YEAR ACCIDENT HISTORY
The Walton CDP Facility is an newly constructed facility and therefore does not have an accident history.

EMERGENCY RESPONSE PROGRAM INFORMATION

The Walton CDP Facility maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including proper first aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post-incident cleanup and decontamination requirements. In addition, the plant has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties.
The emergency response program is updated when necessary based on modifications made to gas plant processes or other facilities. The emergency response program changes are administered through the MOC process, which includes informing and/or training affected personnel in the changes.

Indigo Minerals, LLC is committed to operating in a safe manner for employees, the public and the environment. Plant personnel utilize various auditing processes to ensure that the facility complies with all safety requirements. Improvements are a continuous process and safety policies and procedures are constantly evolving. Every effort is made to modify the plant controls and equipment to reflect new and safer technology.