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Venice Condensate Stablization

Parent Companies:
Enbridge Offshore Facilities, LLC
EPA Facility ID:
100000217785
Other ID:
Facility DUNS:
0
Parent Company DUNS:
0

Location:

Address:
1565 Tidewater Road
Venice, LA 70091
County:
PLAQUEMINES
Lat / Long:
29.235, -89.382 (Get map)
Method:
GPS - Unspecified
Description:
Center of Facility
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
Enbridge Offshore Facilities, LLC
Phone:
(800) 650-8099
Address:
5400 Westheimer Court
Houston, TX 77056
Foreign Address:

Person responsible for RMP implementation:

Name:
Bobby Prout
Title:
Plant Supervisor
Email:

Emergency contact:

Name:
Bobby Prout
Title:
Plant Supervisor
Phone:
(214) 716-3152
24-hour phone:
(800) 650-8099
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Plaquemines County LEPC
Full-Time Equivalent Employees:
8
Covered by OSHA PSM:
Yes
EPCRA section 302:
No
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:

Flammable Liquid Storage
RMP ID:
1000085876
CBI claimed:
No
Program Level:
3
NAICS:
Natural Gas Liquid Extraction (211112)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
936,464
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Jordan Bridger
Address:
5400 Westheimer Court
Houston, TX 77056
Foreign Address:

Phone:
(713) 627-6319

Latest RMP Submission:

Date:
March 8, 2018
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000068458

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 Liquid Storage)
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 Liquid Storage)
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

Flammable Liquid Storage, Natural Gas Liquid Extraction (211112)
Prevention Program ID:
1000072534
Safety Review Date
Dec. 6, 2016, since latest RMP submission
PHA Update Date
Dec. 6, 2016, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Equipment failure
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
Mitigation Systems
  • Dikes
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • On the Job
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
March 13, 2017, since latest RMP submission
Training Review Date
July 12, 2017, since latest RMP submission
Maintenance Review Date
July 1, 2016, since latest RMP submission
Maintenance Inspection Date
Oct. 2, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Dec. 6, 2016
Management of Change Review Date
March 29, 2016
Pre-startup Review Date
July 23, 2017
Compliance Audit Date
March 29, 2016
Compliance Audit Change Completion Date
Jan. 23, 2017
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
March 29, 2016
Hot Work Review Date
Nov. 2, 2017
Contractor Safety Review Date
March 29, 2016, since latest RMP submission
Contractor Safety Eval. Date
March 29, 2016, 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:
Dec. 1, 2017
Local Response Agency:
Local Response Agency Phone:
(504) 297-5660
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

Introduction and Policies



Venice Station Condensate Stabilization Facility (Venice Station), owned and operated by Enbridge Offshore Facilites, LLC is committed to the same quality of safety and environmental excellence that all other Enbridge assets promote. This philosophy involves making each and every employee and contractor accountable for their own safety as well as that of the community around them. As a company we follow a close adherence to all applicable federal, state, and local laws to ensure a safe and healthy environment for all.



Employees who enter the Venice Station complete a thorough training, both in the classroom and on-the-job, that enables them to address emergency issues as they arise. This preparation includes standard operational, emergency operational, and release prevention training. In addition, periodic refresher courses help to keep operators' problem solving abilities up to date and in sync with our recurring safety improvements. Our regular internal audits provide an excellent checks and balances system for monitoring these high standards that we set.



The Venice Station is one of the many facitlities operated by Enbridge Offshore Facilities, LLC The facility is an onshore facility at the endpoint of the Mississippi Canyon Gas Offshore Pipeline (MCGP) and located inside the Targa Facility. The facility receives gas and liquids from the MCGP. The liquids are separated from the gas, which is piped to Targa for processing and sale. The liquids are piped to the condensate stabilization units, then to storage tanks and ultimately to the Chevron Texaco Pipeline for sale to wholesale markets. There are four 796 barrell tanks for stabilized condensate storage at the facility. There are no threshold quantities of toxic substances present. The facility consists of multiple small lube oil, waste oil, and fuel tanks and their associated piping, valves, pumps, and compressors on site that support the stabilization unit. The fa
cility consists of multiple small lube oil, waste oil, condensate and fuel tanks and their associated piping, valves, pumps, and compressors on site that support the plant's compression as well as the NGL tanks. As such, the Venice Station is classified as a Program 3 RMP facility.



The purpose of the Risk Management Plan (RMPlan) is to provide information about our operations at the facility, our programs to prevent accidental chemical releases, our emergency response plans in case an accidental release should occur, our 5-year accident history, and our planned changes to improve safety at the facility.



 

Worst Case and Alternative Release Scenarios



As specified by the U.S. Environmental Protection Agency (EPA) RMP Regulations, our worst-case release scenario for flammables would be the loss of all of the liquids in our largest vessel causing a vapor cloud explosion. In the case of the Venice Station, this would involve our 796 barrell (33,432 gallons) flammable natural gas liquids tank (91,404 pounds). Such a scenario is highly unlikely; however, using the EPAs RMP Comp calculations, the distance at which the resulting vapor cloud explosion could cause an overpressure of 1 psi would be approximately 0.4 miles (approximately 2,112 feet). An overpressure of 1 psi is the EPA's threshold for measurable impacts.



The alternative release scenario characterized as a more likely scenario that would involve offsite consequences is calculated to reach approximately 0.2 miles (approximately 1,056 feet) from the release point. This distance calculation is also based on the EPAs RMP Comp, which is known to be highly conservative and should over predict any potential release from such a scenario. We have selected the alternative release scenario based on a release from our 33,432 gallon NGL tank due to a four inch puncture of the tank and a release of 20,520 pounds of Methane (largest constiuent of NGL tank) in 90 minutes resulting in a vapor cloud ex
plosion. This incident could occur if a truck backs into the tank or piping is broken off of the tank in the event that a truck drives off while load lines are still connected. Additionally, this sceanrio would account for any potential releases from process piping including flanges, joints, welds, valves, and valve seals. Any releases from vessels including drains, bleeds, cracks, seal failures, plug failures, overfiling, overpressurization, and venting would also be accounted for in this scenario. As a method of preventing such events, signs are posted in conspicuous locations to provide constant reminders to the drivers about proper unloading techniques.



Enbridge has discussed these potential hydrocarbon releases with its employees and with local emergency response officials in Plaquemines Parish , thereby further reducing the possibility of any impact on the public.



Prevention Program



Below is a summary of the accident prevention program in place at the Venice Station. Because the processes at the facility are regulated by the Environmental Protection Agency's (EPA's) Risk Management Program (RMP) and are also subject to the OSHA PSM, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program.



Employee Participation: Active employee participation and involvement in the development and implementation of Venice Station PSM program is an important step toward achieving the objective to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. Employee involvement will help to ensure that all perspectives regarding PSM are considered, and that the best ideas are implemented. Open communications are encouraged between supervisors and employees regarding all safety and health issues. Venice Station strongly promotes employee involvement in safety issues through existing programs. These programs include
Unit Safety Teams (which are made up of a cross section of employees and supervision), regularly scheduled safety meetings, tail-gate safety meetings, Hazard Communication, Safety Suggestion Forms, and special training programs (Emergency Response Training, First Aid, etc.).



Process Safety Information: Complete and accurate written process safety information (PSI) concerning process chemicals, process technology, and process equipment is essential to an effective PSM and RMP program and to completing and maintaining a process hazard analysis (PHA). The PSI will be useful to the operators; the team performing the PHA; those in charge of training; contractors; those conducting pre-startup safety reviews; and those in charge of updating the emergency preparedness plans. Process safety information is readily available to all employees. Venice Station keeps a variety of technical documents that are used to help maintain safe operation of the process. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Chemical-specific information, including exposure hazards and emergency response / exposure treatment consideration, is provided in material safety data sheets (MSDSs).



Process Hazard Analysis (PHA): Venice Station 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 facility primarily uses the hazard and operability (HAZOP) method analysis technique to perform these evaluations. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention
and mitigation measures when the team believes such measures are necessary. Periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating.



Operating Procedures: Venice Station maintains written procedures that address various modes of process operations, such as startup, normal operations, temporary operations, emergency shutdown, normal shutdown, and initial startup of a new process. These procedures provide guidance for experienced operators and also provide the basis for training new operators. Operating procedures are periodically reviewed and annually certified as current and accurate. The review and certification process involves both operators and technical staff.



Training: In addition to training on operating procedures, the facility has a comprehensive training program for all employees involved in operating the process. New employees receive basic training on the operating procedures to ensure that their skill 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: Venice Station uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the facility has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have appropriate skills, (3) are aware of the hazards of their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site specific safety rules, and (6) inform facility personnel of any hazards that they find during their work. This is accomplished by providing contractors with orientation sessions pertaining to these key points.



Pre-startup Safety Review
(PSSR): Venice Station conducts a PSSR on any new facility or facility modification that requires a change in 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 design specifications and that all supporting systems are operationally ready. The PSSR involves field verification of the construction and serves as a quality assurance function by requiring verification that accident prevention program requirements are properly implemented.



Mechanical Integrity: Venice Station has well established practices and procedures for maintaining process equipment. The basic aspects of this program include (1) training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting equipment deficiencies when identified, and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process.



Safe Work Practices: Venice Station has long standing 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) 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 and 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: Venice Station has a comprehen
sive system to manage changes to all covered processes. This system requires that changes to items such as process equipment, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to ensure that adequate controls have not been compromised by the changed. Affected chemical hazard information, process operating limits, and equipment information, as well as maintenance personnel are provided any necessary training on the change.



Incident Investigation: Venice Station 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. The goal of each investigation is to gather the facts, determine the root cause, and develop corrective action to prevent the reoccurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a reoccurrence, and forwards these results to the business management team for resolution.



Compliance Audits: To help ensure that the accident prevention program is functioning properly, the Venice Station periodically conducts an audit to determine whether procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. Both hourly and staff personnel participate as audit team members. The audit team develops findings that are forwarded to Venice Station 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.



 

Five-year Accident History



No incident resulting in onsite or offsite impacts from a hydrocarbon release has occurred at the Venice Station wit
hin the last five years. Although we take pride in that record, we also place daily emphasis on our prevention and safety programs to ensure this record continues.



Emergency Response Program



In the event of an emergency involving our natural gas liquid extraction, LP-Gas handling and storage facility, it is our policy to follow our Emergency Action Plan, which is linked with the Plaquemines Parrish Emergency Response Plan. Activation of this emergency response plan sets in motion a pre-planned series of events that notify all area emergency response agencies. Emergency response agencies are notified on the 911 system and directly. The 911 call is channeled through the Plaquemines Parrish Sheriff's Department. All agencies and personnel respond to predetermined staging areas with representatives from each agency reporting to the Central Command Post (CP). A contingency plan is developed and executed using trained industry personnel along with other emergency response personnel from responding agencies, as needed.



Mr. Clint Persick, Chair Iberville Parish Emergency Planning Committee

c/o Total Petrochemicals and Refining USA, Inc

PO Box 324 Plaquemine, LA 70765

Phone: 225-642-4574

Email: clint.persick@total.com



Employees of this facility are provided with copies of the Emergency Response Plan when initially hired and the plan is reviewed and kept up to date by the Emergency Response Supervisor and deemed to be acceptable. All of our operators at this facility have had the appropriate emergency response training as mandated by the OSHA standard. This plan and our emergency response policy have also been discussed with the local fire departments and members of the fire departments have thoroughly inspected our facility.



Planned Changes to Improve Safety



Diligent compliance with our RMP Prevention Program forms the framework on which we will continue to improve the level of safety at the Venice Station. Some of the key components o
f the safety improvements we expect to achieve are as follows:



? The Management of Change provisions ensures that we consider the potential safety and health impacts of any change we make to process chemicals, technology, equipment or procedures.

? The Process Hazard Analysis (PHA) provisions serve as a tool to ensure continual evaluation of potential hazards, thereby leading to continual improvements in our safety standards.

? The Mechanical Integrity provisions ensure that process equipment and instrumentation are designed, constructed, installed and maintained to minimize the risk of hazardous releases, thereby serving as an integral part of our safety program.

? Internal and third party compliance audits will ensure we maintain and increase our level of safety protection.



We encourage all interested citizens or community organizations to learn more about our latest information on emergency response for the county. We plan to diligently integrate our response capabilities and personnel with those of the county on an ongoing basis.