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Port Hudson Terminal

Parent Companies:
NGL Supply Terminal Company, LLC
NGL Energy Partners LP
EPA Facility ID:
100000225696
Other ID:
Facility DUNS:
0
Parent Company #1 DUNS:
0
Parent Company #2 DUNS:
0

Location:

Address:
1249 Hwy 61
Jackson, LA 70748
County:
EAST FELICIANA
Lat / Long:
30.713, -91.270 (Get map)
Method:
Address Matching - Block Face
Description:
Administrative Building
Horizonal accuracy:
10 m
Horizontal reference datum:
World Geodetic System of 1984
Source map scale:

Owner/Operator:

Name:
NGL Supply Termianl Company, LLC
Phone:
(317) 379-0322
Address:
P.O. Box 568
Lebanon, IN 46052
Foreign Address:

Person responsible for RMP implementation:

Name:
John Fansher
Title:
Director of Operations

Emergency contact:

Name:
Glen Hanchey
Title:
Terminal Manager
Phone:
(225) 310-8003
24-hour phone:
(225) 244-2118
Ext or PIN:

Other contacts:

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

Safety:

Local Emergency Planning Committee:
East Feliciana Parish 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:
Feb. 1, 2016
Inspecting Agency:
EPA
Using Predictive Filing:
No

Processes:

Terminal and storage
RMP ID:
1000057006
CBI claimed:
No
Program Level:
3
NAICS:
Petroleum Bulk Stations and Terminals (42471)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
3,065,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Ron Sober
Address:
P. O. Box 470947
Tulsa, OK 74147
Foreign Address:

Phone:
(918) 663-9850

Latest RMP Submission:

Date:
Sept. 10, 2014
Type:
First-time submission
Reason:
Registered:
Yes
RMP ID:
1000045871

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 Terminal and storage)
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 Terminal and storage)
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

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

Terminal and storage, Petroleum Bulk Stations and Terminals (42471)
Prevention Program ID:
1000047572
Safety Review Date
Oct. 4, 2017, since latest RMP submission
PHA Update Date
Aug. 22, 2014, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Earthquake
  • Floods
  • Tornado
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Excess Flow Device
Mitigation Systems
  • Dikes
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
May 1, 2017, since latest RMP submission
Training Review Date
May 1, 2017, since latest RMP submission
Maintenance Review Date
Aug. 1, 2017, since latest RMP submission
Maintenance Inspection Date
June 1, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
None
Management of Change Review Date
Oct. 4, 2016
Pre-startup Review Date
Aug. 26, 2014
Compliance Audit Date
Jan. 1, 2016
Compliance Audit Change Completion Date
Jan. 1, 2016
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Oct. 4, 2016
Hot Work Review Date
Oct. 4, 2016
Contractor Safety Review Date
Oct. 4, 2016, since latest RMP submission
Contractor Safety Eval. Date
Oct. 4, 2016, since latest RMP submission

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:
Aug. 27, 2014
Local Response Agency:
Local Response Agency Phone:
(225) 939-5342
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

ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES



The Port Hudson Terminal Facility has a 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 our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, trained personnel and local emergency responders will respond to control and contain the release.



DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES



The Port Hudson Terminal Facility loads or off loads butane and naphtha transport trucks into or from 6-90,000 pressurized butane storage tanks, 2-90,000 pressurized naphtha storage tanks. These materials are considered flammable mixtures containing substances such as methane, ethane, propane, iso-butane, n-butane, iso pentane, n pentane, and hexane. The Port Hudson Terminal Facility does not use or store any regulated toxic substances above the EPA set threshold levels. Since the facility stores flammable substance above threshold values, an offsite consequences analysis was performed for a worst case release scenario and an alternate release scenario. Analyses were performed using EPA's Risk Management Program Guidance for Offsite Consequences Analyses, April 1999. Both scenarios included a vapor cloud explosions to a 1psi endpoint. The worst case scenario used a 10% yield, whereas the alternative scenario used a 3% yield. This facility is considered Program 3.



The following is a summary of the accidental release prevention program in place at the terminal. Because the facility is normally occupied and stores flammable substance above threshold values, and population is shown within the off site consequences radius, the facility is subject to both Risk Management Program regulation as well as Occupational Safety and Health
Administration (OSHA) process safety management (PSM) standards, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accidental prevention program.



Employee Participation



The Port Hudson Terminal Facility encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling process safety information to participation as a member of a process hazard analysis (PHA) team. Employees have access to all information created as part of the terminal PSM and accident prevention programs. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that is maintained at the Port Hudson Terminal Facility and addresses each element of the accident prevention program. In addition, the terminal has a number of initiatives under way that addresses process safety and employee safety issues. These initiatives include terminal safety meetings and safety training to promote both process and personal safety.



Process Safety Information



The Port Hudson Terminal Facility keeps a variety or 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 and specific chemical inventories, and equipment design basis/configuration information. The Safety Department, in conjunction with terminal personnel, is assigned the responsibility for maintaining up-to-date process safety information. A PSM and EHS Files list has been prepared to help employees readily locate any necessary process safety information.



Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDS). This information is supplemented by documents that specifica
lly address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For specific process areas, the Port Hudson Terminal Facility has documented safety-related limits for specific process parameters (e.g. temperature, level, pressure) in the terminal Operating Procedures. The Port Hudson Terminal Facility ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g. automated shutdown systems).



The Port Hudson Terminal Facility also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes material of construction, design pressure and temperature ratings, and electrical rating of equipment. This information, in combination with 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 (PHA)



The Port Hudson Terminal 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 Port Hudson Terminal Facility primarily uses the HAZOP analysis technique to perform these evaluations. OSHA and the EPA recognize this analysis technique as an approved methodology for conducting PHAs. PHAs are conducted using a team of people who have operating and maintenance experience as well as engineering and safety expertise. The team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and the team makes suggestion for additional prevention and/or mitigation measures when
the team believes such measures are necessary.



The PHA team findings are forwarded to company local management for resolution. Implementation of mitigation options, in response to PHA findings, are scheduled and resolved in a timely manner. All approved mitigations 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 terminal periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 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 team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained.



Operating Procedures



The Port Hudson Terminal Facility maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. 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 and annually certified as current and accurate. The procedures are kept current and accurate by revising them as necessary to reflect changes made through the management of change process.



In addition, Port Hudson Terminal Facility Operating Procedures provide guidance on how to respond to process equipment operating outside their upper and lower limits. Operating Procedures are readily available to operators and other personnel to use as necessary to safely perform their job tasks.



Training



To complement the written procedures for process operat
ions, the Port Hudson Terminal Facility has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in terminal 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 Port Hudson Terminal Facility uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the Port Hudson Terminal Facility 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 terminal 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. Personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations.



Pre-Startup Safety Reviews (PSSRs)



The Port Hudson Ter
minal Facility conducts a PSSR for any new 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 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 Port Hudson Terminal Facility has established practices and procedure 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. Equipment manufacturers 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 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 service (if possible), or 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 Port Hudson Terminal Facility incorporates quality assurance measures into equipment purchases and repair. 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 Port Hudson Terminal Facility 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 supporting 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 Port Hudson Terminal 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 are 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 info
rmation, 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 Port Hudson Terminal Facility 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 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 management for resolution. Corrective actions taken in response to the investigation team 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 investigations reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations.



Compliance Audits



To help ensure that the accident prevention program is functioning properly, the Port Hudson Terminal Facility periodically conducts an 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. Audit findings are forwarded to the company Safety Department for resolution. Both hourly and staff personnel participate in the audits. Corrective actions taken in response to the audit finding 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 Port Hudson Terminal Facility have hazards that must be managed
to ensure continued safe operation. The following is a description of existing safety features applicable to prevention of accidental releases of regulated substances in the facility.



Universal Prevention Activities



The accidental release prevention program summarized previously is applied to all RMP-covered processes at the Port Hudson Terminal Facility. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors.



Specialized Safety Features



The Port Hudson Terminal 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

1. Routine operator inspection.

2. Vapor Detectors.



Release Containment/Control

1. Process relief valves that prevent vessel over pressurization.

2. Valves to permit isolation of the process (manual or automated).

3. Automated shutdown systems for specific process parameters (e.g. high temperature).

4. Redundant equipment and instrumentation.



Release Mitigation

1. Fire extinguishing systems.

2. Trained emergency response personnel.

3. Personal protective equipment (e.g. hard hat, safety glasses, protective clothing).



FIVE-YEAR ACCIDENT HISTORY



There have not been any accidents at Port Hudson Facility.



EMERGENCY RESPONSE PROGRAM INFORMATION



The Port Hudson Facility maintains a written emergency response plan, which is in place to protect worker and public safety as well as the environment. The plan 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 ac
counting 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 terminal 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 plan is updated when necessary based on modifications made to Port Hudson Terminal Facility processes. Personnel are informed of and trained in any changes to the emergency response plan.



The overall emergency response plan for the Port Hudson Terminal Facility is coordinated with local response agencies. This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The Port Hudson Terminal Facility has effective communications capability with the appropriate emergency response organizations (e.g. fire department). This communication allows a means of notifying the public of an incident, if necessary, as well as facilitating a quick response to an incident. The Port Hudson Terminal Facility conducts periodic emergency drills, and may provide refresher training to local emergency responders regarding the hazards of regulated substances in the Port Hudson Terminal Facility.



PLANNED CHANGES TO IMPROVE SAFETY

Currently there are no planned changes.