LIG Liquids Co. L.L.C. Plaquemine Plant - Executive Summary |
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The accidental release prevention and emergency response policies at our facility: In this gas processing plant, we handle natural gas, ethane, propane, butane, and natural gasoline. Because the Company recognizes that these substances are flammable and potentially dangerous, we assign the highest priority to protecting the safety and health of our employees, the community and the environment. Our policies follow the recommendations of the applicable industry recognized Codes and Standards, as well as the regulations of the Louisiana Department of Environmental Quality and the US Environmental Protection Agency. It is our policy to adhere to all applicable Federal and state rules and regulations. Safety depends on the manner in which we handle our products, combined with the safety devices inherent in the design of the facility and the training of our personnel. Our Process Safety Management Program emphasizes that safety and protection of the environment supercede production goals. The plant is designed with safety features that protect the plant from operational upsets and allow it to be safely shut down if necessary. We have conducted operability studies to insure the safety of the process and manage changes in the process as they become necessary. Monthly safety meetings are held with our employees as well as prior to both planned and unplanned maintenance activities. We also have written procedures for maintenance that insures the isolation of potentially dangerous sources of energy. Our facility and the regulated substances we handle: The primary purpose of this facility is to separate liquifiable hydrocarbons (ethane, propane, butane, and natural gasoline) from natural gas (methane). Our feedstock (natural gas) enters and leaves the plant via pipeline. The plant separates these products from the gas stream and delivers the majority of them to customers via pipeline. A small portion of the products is stored in pressurized tanks until customers pick th em up with tank trucks. This plant recovers these products using a process known as cryogenic gas processing. The pressure of the gas stream is dropped across turbo-expanders, which remove heat in the form of work thereby lowering the gas temperature sufficiently to liquefy the desired product hydrocarbons. Approximately one-half of the liquid fraction is then stabilized to remove excess methane, and delivered to a mixed product pipeline. The other half of the mixed product is further processed to separate it into commercial end products. The remaining methane vapor leaves the plant via a gas pipeline. The maximum quantity of each product that can be stored at this plant is: propane, 420,000 lbs.; iso-butane, 420,000 lbs.; commercial butane, 215,000 lbs. and normal butane, 440,000 lbs. The worst-case release scenario and the alternative release scenario: The "worst case scenario" accident has been established as the rupture of our largest propane storage tank. The tank has a maxim um capacity of 210,000 lbs., but is limited by written operating procedures to 90% full, or 190,000 lbs. It is assumed that this entire quantity is released as a vapor, that it contacts an ignition source, and that 10% of the released quantity participates in the resulting explosion. Under this scenario, the distance to the endpoint of a 1.0-psi pressure wave is calculated to be 0.50 miles. There are public receptors within this distance from the tank. These assumptions and calculations were made using EPA guidelines and the EPA's computer program RMP*Comp which was designed for use in preparing this Risk Management Plan. The "alternative scenario" accident, one that is less severe than the "worst case scenario" but more likely to happen would be a rupture of a loading hose during the loading of a butane tank truck. These hoses are equipped with "excess flow valves" that shut off the flow of product in the event that the hose ruptures. This will limit the quantity of the release to 32 lbs. of butane. The contents of the hose would vaporize. For this scenario, it is assumed that the vapors ignite. The estimated distance to the lower flammability limit is less than 0.10 mile. This release has the possibility of extending beyond the facility boundary. These calculations were done following the same guidelines described above. Our general accidental release prevention program and chemical-specific prevention steps: Our facility is subject to the provisions of OSHA Regulations (Standards - 29CFR) Standard Number 1910.119, "Process safety management of highly hazardous chemicals". Under this Standard, we have invested significant effort in developing, implementing and continually reviewing several programs designed to insure a safe working environment and minimal risk of a release. These programs include a written plan to include employee participation, compilation of written process safety information including information pertaining to the highly hazardous chemicals present, and written operating procedures for normal, temporary and emergency conditions. We also maintain current piping and instrument diagrams and maintain the integrity of the relief system. We have conducted a process hazards analysis that we review a minimum of every five years and have in place a Management of Change Program and a documented employee training program. We also maintain a Mechanical Integrity Program that tracks the condition of our equipment. Procedures are in place for incident investigations. We have also developed an emergency response plan that has been coordinated with the Local Emergency Planning Commission. Our five year accident history: We have had no accidents or accidental release of hazardous chemicals within the last five years. Our emergency response program: We have written a specific Emergency Action Plan for this facility. This plan is reviewed with our employees on a regular basis. We hold monthly safety meetings that cover current topics as well as regular review of fire extinguisher and respirator use. Safety meetings are also held prior to both planned and unplanned maintenance events. Our plan has been reviewed with the LEPC and the local volunteer fire department. Planned changes to improve safety: We continually monitor our industry for information on how to conduct our business more safely. This includes changes in risk management philosophy as well as improved equipment designs and controls. Continual training of our employees also leads to improved safety. |