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Lincoln Parish Gas Plant

Parent Companies:
Energy Transfer LP
EPA Facility ID:
100000229772
Other ID:
Facility DUNS:
0
Parent Company DUNS:
0

Location:

Address:
400 Elliott Rd.
Arcadia, LA 71001
County:
LINCOLN
Lat / Long:
32.575, -92.859 (Get map)
Method:
GPS - Unspecified
Description:
Center of Facility
Horizonal accuracy:
10 m
Horizontal reference datum:
World Geodetic System of 1984
Source map scale:

Owner/Operator:

Name:
PennTex North Louisiana OP 3, LLC
Phone:
(214) 981-0700
Address:
8111 Weshchester Drive
Dallas, TX 75225
Foreign Address:

Person responsible for RMP implementation:

Name:
James McClain
Title:
Operations Manager

Emergency contact:

Name:
Todd McKee
Title:
Operations Director
Phone:
(214) 840-5842
24-hour phone:
(337) 375-4831
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(318) 263-2932
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Lincoln Parish LEPC
Full-Time Equivalent Employees:
13
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:

Lincoln Parish Gas Plant
RMP ID:
1000074066
CBI claimed:
No
Program Level:
3
NAICS:
Natural Gas Liquid Extraction (211112)
Chemical name
CAS#
Quantity (lbs.)
CBI
Flammable Mixture
00-11-11
447,304
No
Pentane
109-66-0
35,025
No
Methane
74-82-8
45,953
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Rodrick Nunez
Address:
8100 Big Lake Rd
Lake Charles, LA 70605
Foreign Address:

Phone:
(337) 475-4392

Latest RMP Submission:

Date:
Oct. 10, 2016
Type:
Resubmission
Reason:
Voluntary update (not described by any of the above reasons)
Registered:
Yes
RMP ID:
1000059317

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 Lincoln Parish Gas 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 Lincoln Parish Gas Plant)
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

Lincoln Parish Gas Plant, Natural Gas Liquid Extraction (211112)
Prevention Program ID:
1000062192
Safety Review Date
March 15, 2016, since latest RMP submission
PHA Update Date
Dec. 15, 2015, since latest RMP submission
PHA Techniques
  • What if
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
Process Controls
  • Vents
  • Check Valves
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
  • Grounding Equipment
  • Inhibitor Addition
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • None Recommended
Training Type
  • Classrom
Competency Testing
  • Written Test
  • Demonstration
Procedure Review Date
April 12, 2017, since latest RMP submission
Training Review Date
Sept. 1, 2016, since latest RMP submission
Maintenance Review Date
March 15, 2016, since latest RMP submission
Maintenance Inspection Date
Aug. 31, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
None
Management of Change Review Date
May 1, 2015
Pre-startup Review Date
March 15, 2016
Compliance Audit Date
None
Compliance Audit Change Completion Date
None
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
May 1, 2015
Hot Work Review Date
May 1, 2015
Contractor Safety Review Date
May 1, 2015, since latest RMP submission
Contractor Safety Eval. Date
July 19, 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:
Nov. 13, 2015
Local Response Agency:
Local Response Agency Phone:
(318) 251-5111
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:
No
Subject To - Other:

Executive Summary

PennTex Midstream Partners, LLC

Lincoln Parish Gas Plant

Executive Summary



PennTex Midstream, owner and operator of the Lincoln Parish Gas 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 our processes. PennTex's policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. PennTex employees are trained to respond to releases in a "limited" manner meaning at no time will an employee assume an unreasonable risk to deal with an emergency. Only when safe to do so, trained employees may secure the area; identify the problem; conduct a hazard and risk assessment; perform system shutdowns, isolation and pressure reduction, as deemed necessary; contain and mitigate incidental releases, etc. If an unreasonable risk exists, employees will evacuate from the danger zone and will contact trained emergency responders and 3rd party contractors to assist in controlling and mitigating emergency situations. During such emergencies, employees will assist in an indirect manner and will not assume active response measures within the danger zone.





Description of the Stationary Source and Regulated Substances



The PennTex Lincoln Parish Gas Plant is a 200 MMscf/d cryogenic processing plant that processes the natural gas received and then sends the Residue Natural Gas to customers via the Residue Pipeline and the Natural Gas Liquids (NGL) to customers via the NGL Pipeline. The facility processes the gas to drop the temperature of the gas to remove condensed Ethane and other Natural Gas Liquids (NGL), which reduces the British Thermal Unit (BTU) level of the gas flowing from the well to approximately 1,100 BTU which is a suitable level for use as natural gas. To achieve these results the natural gas is received via an Inlet Separat
or that allows the liquid to drop out of the Gas. The Gas then enters the two (2) Inlet Gas Compressors (each rated for 102.5 MMscf/d).



From the Inlet Compressors the compressed gas enters the Amine Unit, as necessary. The Gas is contacted with the Amine, which removes impurities (CO2) from the gas. The CO2 (acid gas) flows out with the Amine and is typically routed to an RTO to destroy entrained VOC's. The gas flows to the Mol Sieve Dehydrators, which removes moisture from the gas before the gas enters the Chilling and Expansion Section. The heat exchange that takes place in this section allows the heavier hydrocarbons to condense in the Demethanizer and supply the NGL System and Pipeline. The lighter hydrocarbons go out the top of the Demethanizer and supply the Residue Gas Compressor. The Residue Compressors increase the Residue Gas Pressure. This increase in pressure is necessary so that the Residue Gas can enter the Residue Gas Pipeline. The NGLs from the Demethanizer enter the NGL Product System where Pipeline Pumps provide the pressure necessary for the NGLs to enter the NGL Pipeline.



The processes at the Plant are interconnected by piping and fit the EPA's definition of a stationary source in 40 CFR part 68. The facility contains three sources of regulated substances held over their respective threshold quantities; Methane, Condensate (Pentane), and NGLs (Flammable Mixture).



General Accident Release Prevention and Program Information



Processes at the Lincoln Parish Gas Plant are regulated by the Environmental Protection Agency's (EPA's) risk management program 3 (RMP) regulation. The following summary addresses each of the OSHA elements and describes the management system in place to implement the accident prevention program.



Employee Participation



PennTex Midstream encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compi
ling technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team. Employees have access to all information created as part of the facility accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that is maintained at the facility.



Process Safety Information



PennTex Midstream keeps a variety of 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 reference documents are maintained on file at the facility to provide open access.



Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in safety data sheets (SDSs). This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For the process, the facility has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in key process parameter documents. The 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 Lincoln Parish Gas Plant also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, and electrical rating of equipment. This information, in combination with written procedures and 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)



PennTex Midstream has a comprehensive program to help ensure that hazards associated with the process 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 initial Lincoln Parish Gas Plant's PHA used a combined technique utilizing the What-If/Checklist, HAZOP and Failure mode and effects analysis. Future PHA techniques are determined on a case by case basis. 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, and the team makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary.



The PHA team findings are forwarded to local and corporate management for resolution per PennTex's Risk Management Protocol. 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 team 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 Lincoln Parish Gas Plant periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted when major changes occur at the Plant, or at minimum every five years. 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



Lincoln Parish Gas Plant maintains written procedures that address various modes of 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, the Lincoln Parish Gas Plant maintains key process parameter documents that provide guidance on how to respond to upper or lower limit exceedance 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 Lincoln Parish Gas Plant has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in facility 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 a
re maintained at an acceptable level. This refresher training is conducted on an as needed basis. All of this training is documented for each operator, including the means used to verify that the operator understood the training.



Contractors



The Lincoln Parish Gas Plant uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the 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 event of an emergency, (5) understand and follow site safety rules, and (6) inform facility 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, PennTex has a program in place to evaluate contractor safety programs and performance. Facility personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations.



Pre-startup Safety Reviews (PSSRs)



PennTex 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 and that all supporting systems are operationally ready. The PSSR team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves as a quality assurance function by requiring
that accident prevention program requirements are properly implemented.





Mechanical Integrity



PennTex has well-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. Job plans/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 service (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 Lincoln Parish Gas Plant 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



PennTex has long-standing safe work practices in place to help ensure worker and process safe
ty. 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



PennTex 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 to (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



PennTex promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, 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 facility 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 PHAs and PHA revalidations.



Compliance Audits



To help ensure that the accident prevention program is functioning properly, PennTex periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted on a periodic basis. Both hourly and staff personnel participate as audit team members. The audit team develops findings that are forwarded to facility 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 Lincoln Parish Gas Plant have hazards that must be managed to ensure continued safe operation. The following is a description of existing safety features applicable to the prevention of accidental releases of regulated substances in the facility.





Universal Prevention Activities



The accident prevention program summarized previously is applied to all RMP-covered processes at the Lincoln Parish Gas Plant. Collectively, these prevention program activities prevent or mitigate potential accident scenarios that could be caused by equipment failures and human errors.



Specialized Safety Features



The Lincoln Parish Gas Plant 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 process:



Release Detection



1. Tanks are gauged

2. Tanks/vessels are equipped with level alarms and shutdowns



Release Containment/Control



1. Process relief valves venting vapors to the atmosphere to prevent tanks/vessels from rupturing

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

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



Release Mitigation



1. SPCC Plan

2. Fire extinguishers





Emergency Response Program Information



The Lincoln Parish Gas Plant 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 the 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 facility 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 facility processes. Periodic drills or tabletop exercises are conducted to test the response plan.



The overall emergency response program for the Lincoln Parish Gas Plant is coordinated with the Lincoln County Local Emergency Planning Committee (LEPC). Mr. Kip Franklin is the contact for the LEPC (318-513-6200). This coordin
ation includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The Lincoln Parish Gas Plant has around-the-clock communications capability. PennTex operators are automatically notified in the event of a process upset. In the event of an emergency, the operator will immediately notify the Emergency Response Supervisor. The Emergency Response Supervisor or designee will notify the appropriate local emergency responders, as needed. This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an emergency.



PennTex conducts periodic emergency response training for employees, and may request local emergency responders to attend. PennTex maintains knowledge of the emergency response agencies having jurisdiction near PennTex facilities by maintaining liaison with the various agencies. In addition to periodic Public Awareness meetings, PennTex encourages local emergency responders to periodically visit and tour the facility to stay appraised of the hazards, acquaint the officials with PennTex's ability to respond to emergencies, as well as plan how PennTex and the officials can engage in mutual assistance to minimize hazards. In the event of an environmental incident, PennTex will follow the appropriate procedures for isolating the event, containing the leak/spill, notifying the appropriate agencies, clean up/remediation and any necessary follow-up reporting.





Five - Year Accident History



According to PennTex personnel the Lincoln Parish Gas Plant has had no accidents in the last five years.





Planned Changes to Improve Safety



The Lincoln Parish Gas Plant resolves all findings from PHAs, some of which result in modifications to the process.