Enterprise Products Operating L.P. - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES |
At Enterprise, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including:
* A description of our facility and use of substances regulated by EPA's RMP regulation
* A summary of results from our assessment of the potential offsite consequences from accidental chemical releases
* An overview of our accidental release prevention programs
* A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule
* An overview of our emergency response program
* An ove
rview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment
STATIONARY SOURCE AND REGULATED SUBSTANCES
Our facility produces Ethane, Propane, Propylene, Butanes, Natural Gasoline, and MTBE using a variety of chemicals and processing operations. The facility is an integrated complex of production units, above-ground tanks and underground storage wells, pipelines, and a product handling terminal involving rail cars and trucks.
The liquefied petroleum gases and other liquid hydrocarbons, produced, stored, and distributed at the complex are highly volatile, flammable, and explosive materials. The process units operated by Enterprise involve processing of liquified petroleum gases (LPG) into their individual components such as ethane, propane, propylene, isobutane, normal butane and natural gasoline. In addtion manufacturing of synthetic organic chemicals is conducted a
t the Mont Belvieu Complex including isobutene and methyl tert butyl ether (MTBE). The processes involved include fractionation, reaction, separation and distillation. Enterprise utilizes gas-fired turbines to generate electricity or run compressors, and to supply heat for process operations. Additionally, there are a number of gas-fired heaters to provide heat for various processes including distillation. The facility utilizes three flares: south flare (for the south complex), LRGO flare (for the Splitter I, West Terminal and Dow) and north flare (for MTBE and Splitter II).
In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release:
Chlorine which is used for the regeneration process of the oleflex catalyst and is consumed in that portion of the MTBE unit. The chemical is contained in two (2) one-ton cylinders for a maximum on site quantity
of 4,000 pounds.
Ammonia is used as a reagent treating the MTBE unit turbine exhaust in the SCR packing. A maximum total of 34,955 pounds of ammonia is stored in a coded pressure vessel. Ammonia is contained in a closed loop system until it is consumed in the SCR process in the heat recovery unit.
Propane is a finished product at the Mont Belvieu facility. A portion of this production comes from the Propylene Splitter units, as well as the NGL Fractionators. The quantity of this product is distributed through out the complex.
Propylene is a finished product. All of this production line derives from the two Propylene Splitter units. The quantity is distributed between the unit production and the Storage Well.
Isobutane is produced in the Butamer units of which there are two running in parrallel. This is done by converting normal butane into isobutane.
Normal Butane is the feed to the Butamer units. Most normal butane is pipelined directly into the butamer un
it and is converted to isobutane.
Mixed butanes are produced from the NGL Fractionators and Butamer units and are fed to De-Isobutanizers which separates the isobutane and normal butane.
Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals.
KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS
EPA's RMP rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario:
Worst-case Release Scenario - Regulated Toxic Chemicals
We have simulated the failure of one of the one-ton chlorine cylinders at the MTBE unit resulting in an ERPG-2. Total release is 2,000 pounds of the chlori
ne gas at a rate of 200 lbs/minute for 10 minutes. The simulated end point distance of of the chlorine gas is approximately 6 miles. The scenario would not reach mitagation due to the type of simulation. All emergency response and early warning to the employees and the community would be exercised immediately if this were to occur. All ERT protocols would be in effect. The offsite consequence would affect schools, public residences, recreation areas, public highways and other industrial sites.
Alternative Release Scenario(s) - Regulated Toxic Chemicals
The first alternate release scenario simulates a chlorine tubing break on the same chlorine system again resulting in an ERPG-2. The total release is approximately 287 pounds of chlorine gas at a rate of 28.7 lbs/minute for 10 minutes. The simulated end point distance would be approximately 0.69 miles. The scenario would be mitigated by means of the emergency response team responding to the incident, emergency shutdown system i
nitiated, and eventually closing isolation valves to the chlorine systems. All ERT protocols would be enacted. The offsite consequence may affect a minimum of 14 people due west of the Enterprise location. There would be no offsite environmental impact in this scenario due to the material being contained on site.
The second alternate release scenario simulates a 2" pipe rupture from the ammonia tank (which contains 34,955 pounds) to the ammonia pump resulting in an ERPG-2. The total release is approximately 23,600 pounds of ammonia at a rate of 2,360 lbs/minute for 10 minutes. The simulated end point distance would be approximately 1.6 miles. The scenario would be mitigated by means of the emergency response team responding to the incident, emergency shutdown systems initiated, and eventually closing isolation valves to the ammonia system. All ERT protocols would be enacted. The offsite consequence may affect appoximately 500 people (residents of Mont Belvieu and other industr
ial empolyees). There would be no offsite environmental receptor (ie; parks, forrest, mountains, wildlife sancturaries, preserves, refuges and wilderness areas) impact in this scenario due to the pooled material being contained on site.
Worst-case Release Scenario - Regulated Flammable Chemicals
This simulation involves the rupture or failure of the 1300 Deisobutanizer tower which contains normal butane and iso-butane resulting in a vapor cloud explosion. The total release would be 511,000 pounds. The simulated end point distance to the 1 pound overpressure would be approximatley 0.64 miles. This scenario would not be mitigated due to the type of scenario modeled. All emergency response and early warning to the employees and the community would be exercised immediately if this were to occur. All ERT protocols would be in effect. The offsite consequence may affect approximately 14 people located due west of the facility. There would be no offsite environmental impact in this
scenario due to the material being consumed on site.
Alternative Release Scenario(s) - Regulated Flammable Chemicals
The alternative release scenario is the simulation of a 3/4" bleed valve shear from the Propylene Splitter II splitter tower. The material released would be propylene and would result in a vapor cloud explosion. The total pounds released would be 5,060 pounds at a rate of 506 lbs/minute for 10 minutes. The simulated end point distance to the 1 pound overpressure would be approximatley 0.14 miles. This scenario would be mitaged by means of the emergency shutdown system and the activation of the emergency response team. All emergency response and early warning to the employees and the community would be exercised immediately if this were to occur. There would be no offsite environmental impact in this scenario due to the material being consumed on site.
We are using this information to help us ensure that our emergency response plan and the community emergency res
ponse plan address all reasonable contingency cases.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS
We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our Process Safety Management Systems address each of the key features of successful prevention programs including:
* Process safety information
* Process hazard analysis
* Operating procedures
* Mechanical integrity
* Management of change
* Pre-Startup Safety Review - "PSSR"
* Compliance audits
* Incident investigation
* Employee participation
* Hot work permit
As part of our prevention efforts, we have a multitude of programs in which our employees participate. We have a training program in which the Operations and Maintenance personnel are specifically trained in the operations of the plant, the operating procedures, maintenance procedures, and specific other regulations and policies as well as i
n all areas of emergency response. We train, use and apply the guidelines of our PSM program which include all of the above listed areas. All of these programs come under scheduled scruntity and critique.
We have an on-going inspection program designed to search out and find deficiencies with the process equipment prior to any incident.
The Operations personnel make regular inspections of the equipment and processes they operate. If something out of the ordinary is found, it is reported to managment in order to expediently resolve any problems.
FIVE-YEAR ACCIDENT HISTORY
We keep records for all significant accidental chemical releases that occur at our facility. The following is a brief summary of accidental chemical releases involving materials covered under EPA's RMP rule during the past five years:
On January 31st of 1996, we had a welded nipple break off of a pipe which resulted in a vapor cloud explosion. The chemical released was iso-butane. The resulting fire was
contained to the one unit with no offsite impact.
On February 24th of 1998 we had some maintenance activities ongoing in one of the butamer units. The Maintenance personnel inadvertantly left one of the PSV flanges loose and when the tower pressured up for startup, a hydrocabon release resulted.
For each of these incidents, we have conducted formal incident investigations to identify and correct the root causes of the events.
EMERGENCY RESPONSE PROGRAM
We maintain an integrated contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the Mutual Aid Mont Belvieu group which includes the Mont Belvieu Police, Fire Dept., and Emergency Medical Service as well as the Chambers County Emergency Managment system.
PLANNED CHANGES TO IMPROVE SAFETY
The following is a list of improvements that we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases:
We are constantly reviewing and improving our PSM program. This program is presently undergoing a front to back cover review and its written managment system. The same is being done to the mechanical integrity program. The Emergency Preparedness Plan is scheduled to be reviewed and updated in the fall of this year. The Safety Procedures and Policies were reviewed and updated in May of 1998.
We plan on increasing the safety inspections of the operating process units. This has been very successful in the past and we want to continue this effort.