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Sorrento Gas Storage

Parent Companies:
EnLink Midstream Operating LP
EPA Facility ID:
100000235532
Other ID:
Facility DUNS:
0
Parent Company DUNS:
0

Location:

Address:
6536 LA Hwy 3140
Sorrento, LA 70778
County:
ASCENSION
Lat / Long:
30.167, -90.783 (Get map)
Method:
GPS - Unspecified
Description:
Center of Facility
Horizonal accuracy:
3 m
Horizontal reference datum:
World Geodetic System of 1984
Source map scale:

Owner/Operator:

Name:
EnLink Midstream Operating LP
Phone:
(214) 953-9500
Address:
1722 Routh Street, Suite 1300
Dallas, TX 75201
Foreign Address:

Person responsible for RMP implementation:

Name:
Don Nguyen
Title:
PSM Manager

Emergency contact:

Name:
Thomas Boudreaux
Title:
Operation Compliance Manager
Phone:
(225) 692-6945
24-hour phone:
(985) 226-8692
Ext or PIN:

Other contacts:

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

Safety:

Local Emergency Planning Committee:
Ascension Parish LEPC
Full-Time Equivalent Employees:
3
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:

Gas Storage
RMP ID:
1000079680
CBI claimed:
No
Program Level:
3
NAICS:
Other Petroleum and Coal Products Manufacturing (32419)
Chemical name
CAS#
Quantity (lbs.)
CBI
Methane
74-82-8
6,300,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Andy Cheung
Address:
1301 McKinney Street, Suite 1600
Houston, TX 77010
Foreign Address:

Phone:
(713) 739-3219

Latest RMP Submission:

Date:
May 23, 2017
Type:
First-time submission
Reason:
Registered:
Yes
RMP ID:
1000063504

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 Gas 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 Gas 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

Gas Storage, Other Petroleum and Coal Products Manufacturing (32419)
Prevention Program ID:
1000067016
Safety Review Date
Aug. 3, 2015, since latest RMP submission
PHA Update Date
Feb. 2, 2015, since latest RMP submission
PHA Techniques
  • HAZOP
Hazards Identified
  • Toxic release
  • Fire
  • Overpressurization
  • Equipment failure
  • Cooling loss
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Purge System
Mitigation Systems
  • Dikes
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • On the Job
Competency Testing
  • Written Test
  • Observation
Procedure Review Date
Dec. 1, 2016, since latest RMP submission
Training Review Date
Aug. 3, 2015, since latest RMP submission
Maintenance Review Date
Aug. 3, 2015, since latest RMP submission
Maintenance Inspection Date
March 1, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Feb. 1, 2017
Management of Change Review Date
Aug. 3, 2015
Pre-startup Review Date
June 1, 2016
Compliance Audit Date
Feb. 2, 2015
Compliance Audit Change Completion Date
May 1, 2015
Incident Investigation Date
July 1, 2016
Incident Invest. Change Completion Date
July 3, 2017
Participation Plan Review Date
Aug. 3, 2015
Hot Work Review Date
Aug. 3, 2015
Contractor Safety Review Date
Aug. 3, 2015, since latest RMP submission
Contractor Safety Eval. Date
April 3, 2017, 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:
April 3, 2017
Local Response Agency:
Local Response Agency Phone:
(225) 647-5000
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
No
Subject To - CWA:
No
Subject To - RCRA:
No
Subject To - OPA:
No
Subject To - State EPCRA:
No
Subject To - Other:

Executive Summary



EnLink Midstream Partners owner and operator of the Sorrento Gas Storage Facility, 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 the processes. Enlink's policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, facility trained personnel will respond to control and contain the release.

Description of the Stationary Source and Regulated Substances



The Sorrento Gas Storage Facility is utilized for gas processing and storage and is designed for injecting pipeline quality gas into underground storage wells or withdrawing stored gas for delivery by 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 one source of a regulated substance held over its respective threshold quantity; Methane.





General Accident Release Prevention and Program Information



Processes at the Sorrento Gas Storage Facility 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



Enlink Midstream Partners encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling 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 doc
umented in an employee participation plan that is maintained at the facility.



Process Safety Information



Enlink Midstream Partners 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 Sorrento Gas Storage Facility 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)



Enlink Midstream Partners has a comprehensive program to help ensure that hazards associated with the process are identified and control
led. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.



Enlink Midstream Partners primarily used the hazard and operability (HAZOP) analysis technique to perform this evaluation. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. 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 Enlink'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 Sorrento Gas Storage Facility 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



The Sorrento Gas Storage Facility maintains written procedures that address var
ious 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 Sorrento Gas Storage Facility 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 Sorrento Gas Storage Facility 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 are 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 Sorrento Gas Storage 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 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, Enlink 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)



Enlink 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



Enlink 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 Sorrento Gas Storage Facility incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made.



Safe Work Practices



Enlink 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) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardo
us 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



Enlink 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



Enlink 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 em
ployees (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, Enlink 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 Sorrento Gas Storage Facility 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 Sorrento Gas Storage Facility. 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 Sorrento Gas Storage 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 process:



Release Detection



1. Tanks are gauged

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

3. High/Low 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)

4. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system)



Release Mitigation



1. Trained emergency response personnel

2. Personal protective equipment (e.g., chemical protective clothing)

3. SPCC Plan

4. Fire extinguishers





Emergency Response Program Information



The Sorrento Gas Storage Facility maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to 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. The emergency response program changes are administered through the Management of Change (MOC) process, which includes informing and/or training affected personnel in the changes. Periodic drills or tabletop exercises are conducted to test the response plan.



The overall emer
gency response program for the Sorrento Gas Storage Facility is coordinated with the Ascension Parish Local Emergency Planning Committee (LEPC). Mr. Richard Webre is the contact for the LEPC (225-621-8360). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The Sorrento Gas Storage Facility has around-the-clock communications capability. Enlink operators are automatically called in the event of a process upset. The operator will then call the appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, Enlink conducts periodic emergency drills that involve emergency response organizations, and the Sorrento Gas Storage Facility provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the facility.





Five - Year Accident History



According to Enlink personnel the Sorrento Gas Storage Facility has had no accidents in the last five years.





Planned Changes to Improve Safety



The Sorrento Gas Storage Facility resolves all findings from PHAs, some of which result in modifications to the process.