Rayne Fractionation Plant - Executive Summary

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LDEQ Facility ID 2129 
Rayne Fractionation Plant Executive Summary 
This risk management plan addresses the following items: 
Accidental Release Prevention and Response Policies 
Description of the Stationary Source and Regulated Substances 
Hazard Assessment Results 
General Accidental Release Prevention Program/Chemical-Specific Prevention Steps 
Summary of Process Hazards, Safety Features, and Hazard Analysis Findings 
Five-year Accident History 
Emergency Response Program Information 
Planned Changes to Improve Safety 
Accidental Release Prevention and Response Policies 
The Union Texas Petrochemicals' (UTP) Rayne Fractionation Plant has a long-standing commitment to worker and public safety and protection of the environment. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety and environmental consequences in the design, installation, operation, and maintenance of our processes. Our policy (See attached Healt 
h, Environmental and Safety Policy) is to implement reasonable controls to prevent foreseeable releases of regulated and non-regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the release. 
Description of the Stationary Source and Regulated Substances 
The Rayne Fractionation Plant, located in Rayne, Louisiana, operates Natural Gas Liquids (NGL) Fractionation Plant six miles north of the town of Rayne, Louisiana on the eastern side of State Highway 35, at 220 Nile Road, in Acadia Parish. The Rayne Fractionation Plant processes demethanized NGL to remove CO2 and separate NGL products (ethane, propane, butane, isobutane, and natural gasoline). NGL products are shipped via pipelines. 
The Rayne Plant includes the following facilities: Incoming and outgoing pipelines, fractionation processing facilities, storage tanks, wastewater ponds, on-site maintenance and fabrication shops, control room, an office building, and ancillary i 
ndustrial facilities. 
The Rayne Fractionation Plant has several regulated flammables: butane, Isobutane, propane, ethane and natural gasoline (which consists of a mixture of butane, pentane and Iso-pentane). Additionally, the plant uses hydrochloric acid, 30% concentration or greater, which is also a regulated toxic substance. 
The Rayne Fractionation Plant is situated on approximately 35 total acres, of which 25 acres are developed into plant process areas. The Rayne Fractionation Plant is bordered by Nile Road on the north and east. A Columbia Gulf natural gas compressor station lies on the western boarder, and farmland utilized for growing rice borders the Rayne Fractionation Plant to the south. 
The coordinates of the Rayne Fractionation Plant is 300, 19', 19" N Latitude and 92 0, 15', 49" Longitude measured at the center of the facility. See plot plan below. 
Hazard Assessment Results 
The worst-case scenario (WCS) associated with toxic materials in Program 3 processes at the Ray 
ne Fractionation Plant involves a release of the entire contents of the hydrochloric acid storage tank into a diked area.  No administrative controls were taken into account in evaluating this scenario.   The worst-case toxic release for hydrochloric acid resulted in a 0.74 mile distance to the endpoint. 
The alternative release scenario (ARS) associated with toxic materials in Program 3 processes at the Rayne Fractionation Plant involves the release of 8.4 pounds per minute of hydrochloric acid over a 60-minute period due to a 1" leak at the 35% aqueous hydrochloric acid solution storage tank. No administrative controls were taken into account in evaluating this scenario. Under alternative release conditions, the alternative-case release of hydrochloric acid resulted in a 0.20 mile distance to the endpoint.   
The WCS for the flammable materials at the Rayne Fractionation Plant involves the release of 527,000 pounds of hydrocarbons over a 10 minute period due to the failure of feed st 
orage tank. The maximum level in the storage tank is limited to 70% of the tank's capacity by facility procedures. Under worst-case conditions, the resulting vapor cloud explosion could cause an overpressure of 1 pound per square inch (psi) at a distance up  to 0.66 miles.  
The ARS for flammable material at the Rayne Fractionation Plant involves the release of 50,800 pounds of hydrocarbons over a 5-minute period due to a 2" pipe leak at the feed storage tank. Under alternative release conditions, the resulting vapor cloud explosion could cause an overpressure of 1 pound per square inch (psi) at a distance up to 0.30 miles.  
Five-Year Accident History 
The Rayne Fractionation Plant has had an excellent record of accident prevention over the past 5 years. None of the events that have occurred over the past five years have resulted in offsite effects. We investigate every incident very carefully to determine ways to prevent similar incidents from recurring.  
General Accidental Release/ 
Chemical-Specific Prevention Programs Steps 
The following is a summary of the accident prevention program in place at the Rayne Fractionation Plant. Because the processes at the Rayne Fractionation Plant that are regulated by the EPA Risk Management Program (RMP) regulation are also subject to the OSHA Process Safety Management (PSM) standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. 
Employee Participation 
The Rayne Fractionation Plant provides for and 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 Rayne Fractionation Plant accident prevention program. Specific ways that employees c 
an be involved in the accident prevention program are documented in an employee participation procedure that is maintained at the Rayne Fractionation Plant and addresses each accident prevention program element. In addition, the Rayne Fractionation Plant has a number of initiatives under way those address process safety and employee safety issues. These initiatives including forming teams to promote both process and personal safety. The teams typically have members from various areas of the plant, including operations, maintenance, engineering, and plant management. 
Process Safety Information 
The Rayne Fractionation Plant 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. Specific departments within the Rayne Fractionation Plant are assigned res 
ponsibility for maintaining up-to -date process safety information. A table summarizing the reference documents and their location is readily available as part of the written employee participation plan to help employees locate any necessary process safety information. 
Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets. For specific process areas, the plant has documented safety-related limits for specific process parameters (e.g., temperature, level; composition) in the operating procedures. The Rayne Fractionation Plant 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). A more complete description of process hazards and associated controls is provided in the Summary of Process Hazards, Safety Features, and Hazard Analysis Fi 
ndings section of this document. 
The Rayne Fractionation Plant 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, electrical rating of equipment, etc. 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) 
The Rayne Fractionation Plant has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. 
The Rayne Fractionation Plant primarily uses the hazard 
and operability (HAZOP) analysis technique to perform these evaluations. 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 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. 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 Rayne Fractionation Plant periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. 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 Rayne Fractionation Plant maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) 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 ba 
sis for consistent training of new operators. These procedures are periodically reviewed and annually certified as current and accurate. The procedures are maintained current and accurate by revising them as necessary to reflect changes made through the management of change process. 
To complement the written procedures for process operations, the Rayne Fractionation Plant has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in plant operations if they are not already familiar with such operations. After successfully completing this training, a new operator is paired with an area-qualified operator to learn process-specific duties and tasks. After operators demonstrate (e.g., 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 at least every 3 years. A11 of this training is documented for each operator, including the means used to verify that the operator understood the training. 
The Rayne Fractionation Plant 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 the event of an emergency, (5) understand and follow site safety rules, and (6) inform plant personnel of any hazards that they find during their work.  This is accomplished by providing contractors with (1) a process overview, (2) information about sa 
fety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to their beginning work. In addition, the Rayne Fractionation Plant evaluates contractor safety programs and performance during the selection of a contractor. Rayne Fractionation Plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. 
Pre-Startup Safety Reviews 
The Rayne Fractionation Plant conducts a pre-startup safety review (PSSR) for any new facility or facility modification that requires a change in the process safety information that exceeds $5O,OOO or otherwise deemed necessary by local management. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and the 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-s 
upporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements were properly implemented. 
Mechanical Integrity 
The Rayne Fractionation Plant 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 healt 
h hazards, (3) applicable maintenance procedures, (4) emergency control plans, and (5) applicable safe work practices to 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). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or a group of experts 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 Rayne Fractionation Plant 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 mad 
Safe Work Practices 
The Rayne Fractionation Plant 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 that is being worked on, (3) a procedure for safe removal of hazardous materials 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 
The Rayne Fractionation Plant has a comprehensive system to manage changes to all covered processes. This system requires that changes to items such as process equipmen 
t, chemicals, technology (including process-operating conditions), procedures, and other facility changes to 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 (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 
The Rayne Fractionation Plant promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas 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 plant management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are completed. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (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 future PHAs and PHA revalidations. 
Compliance Audits 
To help ensure that the accident prevention program is functioning properly, the Rayne Fractionation Plant periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. Both hourly and staff personnel partic 
ipate as audit team members. The audit team develops findings that are forwarded to Rayne Fractionation Plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are completed. The final resolution of each finding is documented, and the two most recent audit reports are retained. 
Summary of Process Hazards, Safety Features, and Hazard Analysis Findings 
The processes at the Rayne Fractionation Plant have hazards that must be managed to ensure continued safe operation. For ease of presentation, hazard categories, a summary of existing safety features, and a summary of the types of hazard analysis findings are presented in Table 1. 
Universal Prevention Activities 
The accident prevention program summarized previously is applied to all EPA RMP covered processes of the Rayne Fractionation Plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment f 
ailures and (2) human errors. 
Specialized Safety Features 
The Rayne Fractionation Plant 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 processes: 
Release Detection 
1. Hydrocarbon detectors with alarms 
Release Control 
1. Process relief valves that discharge to a flare to capture and incinerate episodic releases 
2. Check valves 
3. Flares 
4. Manual shutoffs 
5. Alarms and procedures 
6. Emergency instrument air supply 
7. Emergency power 
8. Backup pump 
9. Grounding equipment 
10. Inhibitor addition 
11. Rupture disks 
12. Excess flow device 
13. Purge system 
Release Containment 
1. Vessel to permit partial removal of the process inventory 
2. Curbing and diking to contain liquid releases 
3. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump) 

. Atmospheric relief devices 
Release Mitigation 
1. Dikes in process areas and surrounding storage vessels 
2. Fire water system administered through fire monitors throughout the plant 
3. Valves to permit isolation of the process (manual or automated) 
4. Fire suppression and extinguishing systems 
5. Deluge system for specific equipment 
6. Trained emergency response personnel 
7. Personal protective equipment (e.g., chemical protective clothing, self-contained breathing apparatus) 
8. Blast-resistant buildings to help protect control systems and personnel 
Emergency Response Program Information 
The Rayne Fractionation Plant maintains a written emergency control program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a 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 resp 
onse, including proper first-aid and medical treatment for exposures, evacuation plans and accounting for personnel after evacuation, notification of local emergency response agencies and the public if a release occurs, and post incident cleanup and decontamination requirements. In addition, the Rayne Fractionation Plant 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 control program is updated when necessary based on modifications made to Rayne Fractionation Plant processes or other Rayne Fractionation Plant facilities. The emergency control program changes are administered through the management of change (MOC) process, which includes informing and/or training affected personnel in the changes. 
The overall emergency control program  
for the Rayne Fractionation Plant is coordinated with the Acadia Parish local emergency planning committee (LEPC). This coordination includes periodic meetings of the committees, which include local emergency stet officials, local government officials, and industry representatives. The Rayne Fractionation Plant has around-the-clock communications capability with 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, the Rayne Fractionation Plant conducts periodic emergency drills that involve the LEPC and emergency response organizations, and the plant provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the Rayne Fractionation Plant. 
Planned Changes to Improve Safety 
The Rayne Fractionation Plant resolves all findings from 
Process Hazard Analyses, some of which result in modifications to the process. All Process Hazard Analysis recommendations have been implemented as of, July 30, 1997. The following types of changes were implemented in response to PHA findings: 
1. Installation of a process controls 
2. Installation of process detection system 
3. Enhancement of mitigation systems such as upgrades to the fire water system 
4. Revisions to personnel training programs 
5. Revisions to operating procedures 
6. Revisions to Health, Environmental and Safety Procedures 
There was a comprehensive Process Safety Management Audit conducted in April 1998. Further, the Process Hazard Analysis is planned to undergo the Revalidation process during the third quarter of 1998.
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