Promix L.L.C. - Executive Summary |
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28031 LDEQ Facility ID Number KOCH HYDROCARBON SOUTHEAST, INC. Promix Fractionation Facility Belle Rose, Louisiana EXECUTIVE SUMMARY FOR THE RISK MANAGEMENT PLAN (RMPlan) Introduction and Policies Under the Koch Environmental Excellence Program (KEEP) at Koch Industries, Inc., we are committed to being associated with unmatched environmental performance as measured by our employees, customers, regulators, and the public. Our KEEP management philosophy goals are achieved by the personal commitments of our employees and contractors, and by open communication with our employees, customers, neighbors, and with regulators. The accidental release prevention and emergency response programs we have at our facilities are part of the high standards we strive for through KEEP. Our high standards are achieved by operating in compliance with all required environmental permits and regulations, by operating and maintaining our assets in such a manner that any unpermitted release will be unin tentional and acknowledged as unacceptable, by remedying any shortcomings found during regular audits of our facilities, and by reporting promptly to regulators any shortcomings found during the course of our audits as required by law. The Promix Fractionation Facility is operated by Koch Hydrocarbon Southeast, Inc. (Koch). At the facility, we receive natural gas liquids from natural gas facilities as feed stock, which is directed to an underground cavern on the Promix property. The natural gas liquids from the underground cavern are fed to the fractionation plant where they are fractionated into five products streams: Ethane-Propane (E-P) Mix, Propane, Iso-Butane, Normal Butane, and Natural Gasoline. These five product streams are further purified to remove contaminants such as water, carbon dioxide, and mercaptans. The purity products are stored in tanks or caverns and are distributed to various customers via pipeline, barge, or truck. Chlorine is the only toxic substance regu lated under the Risk Management Program (RMP) that is present at the facility. Ethane, Propane, n-Butane, Iso-Butane, Natural Gas Liquid (NGL) Mixture, and Ethane-Propane (E-P) Mix are the flammable substances regulated under the RMP that are present at the facility. The facility is classified as Program Level 3 under the regulation. The purpose of this Risk Management Plan (RMPlan) is to provide information about our operations at the facility, our programs to prevent accidental chemical releases, our emergency response plans in case an accidental release should occur, our 5 year accident history, and our planned changes to improve safety at the facility. Worst Case and Alternative Release Scenarios As specified by the U. S. Environmental Protection Agency (EPA) RMP Regulations, our worst case release scenario for toxic chemicals would be the loss of all of the chlorine in our largest vessel within 10 minutes. In the case of the Promix Fractionation Facility, this would involve our 1 ton chlorine cylinder. Such a scenario is highly unlikely, however, using the EPA Offsite Consequence Analysis (OCA) methods, the distance that chlorine vapors could travel, in this hypothetical case, would be 3.0 miles from our facility. The alternative release scenario, characterized as a more likely scenario that could involve an offsite exposure to chlorine, is calculated to reach 0.4 miles (2,100 feet) from the release point. This distance calculation is also based on the EPA OCA methods, which are known to overpredict the impact of any potential release from such a scenario. Although we have numerous controls to prevent such releases (high level alarms, emergency shutdown, and others) and to manage their consequences, no credit for any controls or mitigation measures was taken into account when evaluating this alternative release scenario. We selected the alternative release scenario based on a leak of chlorine due to failure of a 3/8" hose on the 1 ton chlorine cylin der. We have several mitigation measures in place to greatly reduce the chance that such an event could ever occur. We conduct visual inspections of the chlorine cylinder and the associated piping and hoses several times during each shift. In addition, we have a leak repair kit at the site in order to fix any problems with the cylinder or valves and holes on the hose. The presence of these mitigation measures serves to either prevent this scenario from occurring or minimize its impact if it does occur. Our worst case release scenario for flammables would be the loss of all of the n-butane in our largest vessel causing a vapor cloud explosion. In the case of the Promix Fractionation Facility, this would involve our 80,220 gallon n-butane tank. Using the EPA OCA methods, the distance that the resulting vapor cloud explosion could cause a overpressure of 1 psi would be approximately 0.6 miles (approximately 3,200 ft). An overpressure of 1 psi is EPA's threshold for measurable impact s. Although we have numerous controls to prevent such releases (high level alarms, emergency shutdown, etc.) and to manage their consequences, no credit for any controls or mitigation measures was taken into account when evaluating this scenario. The alternative release scenario, characterized as a more likely scenario which would involve offsite consequences is calculated to reach approximately 0.4 miles (approximately 2,100 ft) from the release point. This distance calculation is also based on the EPA OCA methods, which are known to overpredict the impact of any potential release from such a scenario. We selected the alternative release scenario based on a release of ethane from an 8" deethanizer relief valve due to loss of condensing on the deethanizer tower. We have several active mitigation measures in place to greatly reduce the chance that such an event could ever occur. We have provided high pressure and high level alarms on the deethanizer tower, which are audible in the control room. These alarms enable us to take timely corrective actions to prevent the overpressurization of the deethanizer tower. The presence of these active mitigation measures serves to either prevent this scenario from occurring or minimize its impact if it does occur. We have discussed these potential chlorine and hydrocarbon releases with our employees and with local emergency response officials in Assumption Parish, thereby further reducing the possibility of any impact on the public. Prevention Program The Promix Fractionation Facility has been operating under the strict guidelines of the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) Program since 1992. Our ongoing analysis of the potential hazards of our process, detailed training of our employees, and constant emphasis on safety have helped us avoid any serious accidents over the last 5 years. Part of this program has also involved identifying and taking steps to avoid potent ial accidental chemical releases. A few examples of the additional prevention features implemented at this facility include: 7 We have installed hydrocarbon gas detectors throughout the process area, which will sound an alarm in the control room upon detection of elevated hydrocarbon concentrations. 7 We have installed chlorine gas detectors around the process area. 7 We require truck drivers to check wheels and to attach an electrical grounding strip prior to truck loading/unloading. 7 We have installed a fire water system consisting of fire extinguishers, fire monitors (canons), and a fire water deluge system at the facility for fire fighting purposes. 7 We have provided emergency shutdown buttons at various locations within the facility in order to safely shutdown the facility during emergency situations. 7 We have installed a burner management system in order to provide a safe air purge of furnaces during emergency shutdown of the heaters and reboilers. 7 We provided continuous p ilots on our flares in order to ensure uninterrupted combustion of vented hydrocarbon gases. These safeguards as well as the vigilance of our trained employees have helped us operate safely at this facility since we acquired it in 1996. Five Year Accident History No incident resulting in onsite or offsite impacts from a release of an RMP substance has occurred at the Promix facility within the last five years. Although we take pride in that record, we also place daily emphasis on our prevention and safety programs to ensure this record continues. Emergency Response Program We will continue to conduct emergency response preparedness activities and coordinate any emergency response actions necessary for the Promix Fractionation Facility with the Assumption Parish Volunteer Fire Department and the Assumption Parish Sheriff. Also involved in emergency response for the facility would be the Paincourtville Volunteer Fire Department, the Assumption Parish Office of Emergency Preparedness, Acadian Ambulance Service, and the Lady of the Lake Hospital. The Promix Fractionation Facility Manager is responsible for coordinating all emergency actions. A specific Emergency Response Plan for the facility is in place, and that plan has been coordinated with local officials, along with evacuation procedures, regular drilling, and training. Our Emergency Response Program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Planned Changes to Improve Safety Diligent compliance with our RMP Prevention Program forms the framework on which we will continue to improve the level of safety at the Promix Fractionation Facility. Some of the key components of the safety improvements we expect to achieve are as follows: 7 The Management of Change provisions ensure that we consider the potential safety and health impacts of any change we make to process chemicals, technology, e quipment or procedures. 7 The Process Hazard Analysis (PHA) provisions serve as a tool to ensure continual evaluation of potential hazards, thereby leading to continual improvements in our safety standards. 7 The Mechanical Integrity provisions ensure that process equipment and instrumentation are designed, constructed, installed and maintained to minimize the risk of hazardous releases, thereby serving as an integral part of our safety program. 7 Internal and third party compliance audits will ensure we maintain and increase our level of safety protection. 7 An ongoing dialogue with the Assumption Parish Emergency Management Director or his designate will ensure a constant state of readiness to respond to any potential emergencies, as well as a means to implement improvements as the need develops. In this way, we shall bolster our strong commitment to the safety of our workers and the community. We encourage all interested citizens or community organizations to contact the Assumpt ion Parish Emergency Management Director for the latest information on emergency response for the county. We plan to diligently integrate our response capabilities and personnel with those of the county on an ongoing basis. |