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Natrium NGL Extraction and Fractionation Plant

Parent Companies:
Blue Racer Midstream, LLC
EPA Facility ID:
100000219961
Other ID:
Facility DUNS:
78739599
Parent Company DUNS:
0

Location:

Address:
14786 Energy Road
Proctor, WV 26055
County:
MARSHALL
Lat / Long:
39.760, -80.862 (Get map)
Method:
Interpolation - Photo
Description:
Plant Entrance (General)
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Blue Racer Midstream, LLC
Phone:
(304) 455-4020
Address:
14786 Energy Road
Proctor, WV 26055
Foreign Address:

Person responsible for RMP implementation:

Name:
Steve Lynch
Title:
Plant Manager

Emergency contact:

Name:
Brad Billeter
Title:
PSM Coordinator
Phone:
(304) 455-4107
24-hour phone:
(304) 815-1907
Ext or PIN:

Other contacts:

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

Safety:

Local Emergency Planning Committee:
Marshall/Wetzel County LEPC
Full-Time Equivalent Employees:
82
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:
May 1, 2014
Inspecting Agency:
EPA
Using Predictive Filing:
No

Processes:

Extraction/Fractionation
RMP ID:
1000072746
CBI claimed:
No
Program Level:
3
NAICS:
Natural Gas Liquid Extraction (211112)
Chemical name
CAS#
Quantity (lbs.)
CBI
Isobutane [Propane, 2-methyl]
75-28-5
3,100,000
No
Propane
74-98-6
9,300,000
No
Butane
106-97-8
6,500,000
No
Flammable Mixture
00-11-11
6,100,000
No
Ethane
74-84-0
66,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Beatriz Cardona
Address:
1110 Nasa Pkwy
Suite 203
Houston, TX 77058
Foreign Address:

Phone:
(281) 333-5080

Latest RMP Submission:

Date:
June 14, 2016
Type:
Resubmission
Reason:
Revised PHA / Hazard Review due to process change (40 CFR 68.190(b)(5))
Registered:
Yes
RMP ID:
1000058218

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 Extraction/Fractionation)
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 Extraction/Fractionation)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
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

Sept. 21, 2013 at 01:10
ID:
1000044817
NAICS:
Natural Gas Liquid Extraction (211112)
Duration:
7 hours and 20 minutes
Chemicals involved:
  • Flammable Mixture
Release events:
Gas release
Fire
Explosion
Weather conditions at time of event
Wind speed:
10.0 miles/h S
Temperature:
70.00 ℉
Atmospheric stability:
E
Precipitation present:
No
Unknown weather conditions:
No
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:
$30000000
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
24
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Unknown
Contributing factors:
  • Equipment failure
  • Maintenance activity/inactivity
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Improved/upgraded equipment
  • Revised maintenance
  • Revised training
  • Revised operating procedures
  • Revised emergency response plan
  • As a result of the fire and explosion on September 21, 2013, the Natrium NGL Extraction and Fractionation facility implemented several recommendations as explained in the executive summary.

7. Prevention: Program level 3

Extraction/Fractionation, Natural Gas Liquid Extraction (211112)
Prevention Program ID:
1000060931
Safety Review Date
May 5, 2015
PHA Update Date
May 26, 2016
PHA Techniques
  • What if
  • Checklist
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Fire Walls
  • Blast Walls
  • Deluge System
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Increased Inventory
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Dec. 31, 2015
Training Review Date
June 2, 2016
Maintenance Review Date
April 25, 2016
Maintenance Inspection Date
March 2, 2016
Equipment Tested
Yes
Management of Change Most Recent Date
April 25, 2016
Management of Change Review Date
April 25, 2016
Pre-startup Review Date
June 1, 2016
Compliance Audit Date
April 13, 2016
Compliance Audit Change Completion Date
Jan. 30, 2017
Incident Investigation Date
June 2, 2016
Incident Invest. Change Completion Date
Sept. 30, 2016
Participation Plan Review Date
April 25, 2016
Hot Work Review Date
April 25, 2016
Contractor Safety Review Date
April 25, 2016
Contractor Safety Eval. Date
April 13, 2016

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
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:
April 7, 2016
Local Response Agency:
Local Response Agency Phone:
(304) 845-6644
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

Blue Racer Midstream, LLC, a joint venture between Dominion Resources, Inc. and Caiman Energy II, LLC, owns and operates the Natrium NGL Extraction and Fractionation plant. The Natrium facility is located in Marshall County West Virginia and includes two cryogenic processing plants and two fractionators.



1. Accidental Release Prevention and Emergency Response Policies - Blue Racer Midstream, LLC (Blue Racer) is committed to employee, public and environmental safety. This commitment is demonstrated by the release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at the facility. It is Blue Racer's policy to implement appropriate controls to prevent possible releases of regulated substances. If a release does occur, regular personnel are at hand to control and mitigate the effects of the release. Also, Blue Racer has coordinated response activities with the Washington Lands Fire and Rescue Department.



2. The Stationary Source and the Regulated Substances Handled - The Natrium extraction and fractionation facility extracts natural gas liquids (NGLs) from a 460 MMSCFD inlet production natural gas stream delivered by pipeline and NGL's from other facilities via pipeline. The facility is designed to fractionate a total of 120,000 bbl/day of product (C2+) of which 110,000 bbl/day of product is expected from the inlet gas stream and 10,000 bbl/day are estimated to be NGLs imported by truck from other liquids extraction processing facilities nearby. The product from the extraction/fractionation process includes natural gasoline, propane, isobutane, and normal butane, which are sent to dedicated storage tanks and ethane and methane to pipelines. Propane, isobutane and normal butane are regulated substances present in the process above their threshold quantities (10,000 pounds) for applicability under the Environmental Protection Agency's (EPA's) Risk Manage
ment Program (RMP) requirements. The NGL product is a flammable mixture that meets the NFPA-4 criteria and is present onsite in an amount that exceeds the threshold quantity (10,000 pounds). Thus, NGL product is also subject to the RMP requirements.



The Blue Racer facility in Natrium added four iso-butane storage vessels to the Natrium site in December 2015. A PHA for that process was conducted in 2015 and used the HAZOP, What If and Checklists methodologies to identify process hazards associated with the new vessels. This RMP is being resubmitted because of the addition of these storage vessels.



3. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps - The facility has taken all the necessary steps to comply with the accidental release prevention requirements, which are set out under 40 Code of Federal Regulations (CFR) Part 68 of the EPA. This facility is also subject to the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) standard under 29 CFR 1910.119. The following sections briefly describe the elements of the accidental release prevention program that is in place at this facility.



Process Safety Information - Natrium maintains a detailed record of process safety information that describes the hazards of regulated substances, operating parameters and equipment designs associated with all processes. Much of this information was compiled during the preparation of the Process Hazard Analysis (PHA). Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in safety data sheets (SDS's).



Process Hazard Analysis - The facility conducts comprehensive studies to ensure that hazards associated with the processes are identified and controlled efficiently. The HAZOP method is used to perform these evaluations. The studies were undertaken by a team of qualified personnel with expertise in engineering and proc
ess operations and will be revalidated at regular intervals of no more than 5 years. All findings related to the hazard analysis are addressed in a timely manner.



Operating Procedures - For the purposes of safely conducting activities within the covered process, Natrium maintains written operating procedures that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Safe work practices have been developed to provide for the control of hazards during operations such as lockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into a stationary source by maintenance, contractor, laboratory, or other support personnel. These safe work practices apply to employees and contractor employees.



Training - A training program is in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Initial training on gas plant operations is provided, and refresher training will be conducted at least every three years or more frequently as needed. Employee training is documented and records of training will be maintained onsite for at least three years.



Mechanical Integrity - Written procedures are in place for maintaining the on-going integrity of process equipment, which incorporates training for process maintenance activities, inspection and testing, corrective action for equipment deficiencies, and the application of quality assurance measures. Documented maintenance checks are carried out on process equipment to ensure proper installation and operation. Process equipm
ent examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Qualified and trained personnel carry out maintenance operations at the site. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. The plant also incorporates quality assurance measures to ensure that equipment and parts are suitable for the process application for which they will be used.



Management of Change - Written procedures are in place to manage changes in process chemicals, technology, equipment and procedures. These procedures are updated as needed. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification.



Pre-startup Reviews - Pre-startup safety reviews related to new processes and to modifications in established processes will be conducted as a regular practice at Natrium. These reviews are conducted to confirm that construction and equipment is in accordance with design specifications, and safety, operating, maintenance, and emergency procedures are suitable for safe startup prior to placing equipment into operation.



Compliance Audits - Regularly scheduled audits will be conducted to determine whether the provisions set out under the RMP rule are being implemented. These audits will be carried out by at least one person knowledgeable in the process and conducted at least once every three years. Audit findings will be documented in a report and corrective actions required from the audits will be undertaken in a safe and prompt manner and documented.



Incident Investigation - Any incident that results in, or could reasonably result in, a catastrophic release of a regulated substance will be promptly investigated. An incident investigation will be initiated as
promptly as possible, and will involve at least one person knowledgeable of the process involved. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. A report will be prepared at the conclusion of the investigation and will include any resolutions and corrective action.



Employee Participation - Blue Racer believes that PSM and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular.



Hot Work Permit - Hot work permits for hot work operations conducted on or near a covered process will be issued by facility safety leaders. The permit shall document that the fire prevention and protection requirements have been implemented prior to beginning the hot work operations; it shall indicate the date(s) authorized for hot work; and identify the object on which hot work is to be performed. The permit will be kept on file until completion of the hot work operations.



Contractors - Blue Racer hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Before any contractors are allowed to work on the Natrium facility, they undergo an orientation conducted by the PSM team. During this orientation contractors are made aware of the known potential hazards related the contractor's work, the hazards of regulated substances, the safe work procedures insisted on by Blue Racer, and familiarized with the Hot Work Permit Policy and the Lock Out/Tag Out Procedures used at Natrium. Contractors are informed of all the procedures f
or emergency response should an accidental release of a regulated substance occur, and this information includes evacuation routes and assembly points. Blue Racer will document that the contractor has received and understands the training.



Chemical Specific Prevention Steps - The processes at Natrium have hazards that must be managed to ensure continued safe operation. Safety features applicable to prevention of accidental releases of regulated substances at the facility are in place to help prevent potential accidental scenarios that could be caused by equipment failures and human error.



4. Five-year Accident History - The Natrium facility experienced an accident on September 21, 2013. While performing non-routine maintenance at Natrium, a valve was utilized in an attempt to remove foreign material from a low point drain. This resulted in an accidental release of NGL, creating a vapor cloud and fire. The vast majority of the release was controlled by the flare or consumed in the fire. An investigation was undertaken immediately following the incident, identifying factors for preventing similar incidents in the future. Based on the recommendations, plant operating procedures have been updated and training has been provided to all employees to ensure new procedures are followed going forward to prevent future occurrences.

Recommended actions included the following:

- Discuss options with CB&I and Cameron on glycol skid issues

- Evaluate the practice of opening low point drains (LPDs) to atmosphere

- Spot check electrical system throughout site to verify it meets area classification

- Monitor differential pressures (DPs) during startup

- Consider first responder training for operations and use of plant emergency shutdown device (ESD)

- Consider reviewing the site Emergency Response Plan to include vapor release response

- Schedule emergency drill for site employees on annual basis

- Consider upgrading signage and lighting of plant emergency shu
tdown device (ESD) stations

- Consider permanent means to fill the fire water system



In addition, a Fire Safety Analysis (FSA) was conducted for the facility to review the design and built status against the requirements in the applicable sections of the American Petroleum Institute (API) documents Standard 2510, Design and Construction of Liquefied Petroleum Gas Installations (LPG) and Publication 2510A, Fire Protection Considerations for the Design and Operation of Liquefied Petroleum Gas (LPG) Storage Facilities.



5. Emergency Response Program - The facility has coordinated emergency response activities with the Washington Lands Fire and Rescue Department. The facility has a written emergency plan to deal with accidental releases of regulated substances which is in place to protect worker and public safety, as well as the environment. The plan includes actions to be taken including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public. Employees receive training in emergency procedures. To ensure proper functioning, the emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within the processes that would require a modified emergency response. The emergency response activities have been coordinated with the Marshall/Wetzel County Local Emergency Planning Committee (LEPC).



On May 12, 2009, Senate Bill 279, entitled Emergency Response Regulations, more commonly known as the Fifteen Minute Rule was signed into law. The bill amends the Code of West Virginia, Chapter 131, adding new provisions that will require RMP subject industrial facilities (among others) to provide certain information to state and local emergency responders within 15 minutes of an accident or emergency. Local emergency responders must be provided information related to public health, safety and welfare regarding hazardo
us waste or material releases.



6. Planned Changes to Improve Safety - Blue Racer will continue to look for ways to continually improve safety at the Natrium facility. As mentioned in item number 4 above, the facility has implementing several recommendations and lessons learned from the incident investigation to improve facility safety.