Act Frac #1 - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Act Frac #1 Baton Rouge Fractionator L.L.C. Enterprise Products Operating L.P. Port Allen, Louisiana This is a new facility that is now at the 99.9% completion stage of construction and will be into the systematic start-up phase next week. We are planning to charge the unit with hydrocarbon possibly starting Wednesday and therefore are filing the RMP in preparation of the expected date of introduction of hydrocarbon. 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 off site 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 overview 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 will produce five products from a raw mix Natural Gas Liquid (NGL) feed stream. The five products are ethane, propane, isobutane, normal butane and Natural Gasoline using a small variety of chemicals and fractionation processing operations. The facility is an integrated complex divided up into different operating sections which are the F eed Treating, DeHydration and DeEthanizer Section, DePropanizer Section, DeButanizer Section, DeIsobutanizer Section and Refrigeration and Hot Oil Section. All Feed is imported via pipelines and all products are exported via pipelines. The liquefied petroleum gases and other liquid hydrocarbons, produced, stored, and distributed at the complex are highly volatile, flammable, and explosive materials. The process unit operated by Enterprise involves processing of liquefied petroleum gases (LPG) into their individual components such as ethane, propane, isobutane, normal butane and natural gasoline. The primary separation process utilized is fractionation by distillation. A supplemental fired heat recovery unit provide heat energy to the process via a heat medium system. A gas turbine is utilized to drive a refrigeration compressor while recovering the heated exhaust gases in the fired heat recovery unit. The facility utilizes an air assisted flare for any and all venting of the pro cess. In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant off site consequences in the event of a substantial accidental release: Toxics There are no toxic chemicals to report. Flammables Ethane is a finished product at the Port Allen facility. This product stream is the overhead product from the DeEthanizer tower. Propane is a finished product. This product stream is the overhead product from the DePropanizer tower. Butanes are produced from the overhead of the DeButanizer tower, which then are immediately fed to a DeIsobutanizer which separates the two types of butanes. IsoButane is a finished product from the overhead stream of the DeIsobutanizer. Normal Butane is a finished product from the bottoms stream of the DeIsobutanizer. Natural Gasoline is a finished product from the bottoms stream of the DeButanizer consisting mostly of pentanes and hexanes. 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 processing of these flammable 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 There are no regulated toxic chemicals on site and therefore there will be no worst-case release scenario reported. Alternative Release Scenario(s) - Regulated Toxic Chemicals There are no regulated toxic chemicals on site and therefore there will be no alternate-case release scenario reported. Worst-case Release Scenario - Regulated Flammable Chemicals This simulation in volves the rupture or failure of the DeEthanizer tower shell which contains a flammable mixture of hydrocarbons which are ethane, propane, isobutane, normal butane and natural gasoline (pentanes and hexanes) resulting in a vapor cloud explosion. The total pounds release would be approximately 186,301 pounds. The simulated end point distance to the 1 pound overpressure would be approximately 0.47 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 off site consequence will not affect any of the residential population. There would be no off site 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 Deisob utanizer tower. The material released would be an isobutane/normal butane mix and would result in a vapor cloud explosion. The total release 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 approximately 0.14 miles. This scenario would be mitigated 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 off site 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 response 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 release s 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 * Training * Mechanical integrity * Management of change * Pre-Startup Safety review * Compliance audits * Incident investigation * Employee participation * Hot work permit * Contractors 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 train in 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 scrutiny and critique. We have an ongoing inspection program designed to search out and find deficiencies with the process equipment prior to any incident. The Operations personnel make regular walk through inspections of the equipment and processes they operate. If anything out of the ordinary is found, it is repaired by the observer or reported to management in order to expediently resolve any problems. FIVE-YEAR ACCIDENT HISTORY We will keep records for all significant accidental chemical releases that will occur at our facility. Since this is a new facility that is not yet operational, there is not any reportable history of accidental chemical releases involving materials covered under EPA's RMP rule for the past five years. In the future if there are any accidental releases, we will conduct incident investigations to identify and correct the root causes of any event(s) that may occur. 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 West Baton Rouge Emergency Response Task Force which includes the Port Allen Police, Fire Dept., and Emergency Medical Service as well as West Baton Rouge Parish Emergency Management 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 of the program and its written management system. The same is being done to the mechanical integrity program. The Safety Procedures and Policies were reviewed and updated in May of 1998. We plan to conduct safety inspections of the operating process units as well as conducting a PSM audit after start-up of the facility. |