Napoleonville Liquid Storage - Executive Summary
LDEQ Facility ID 27926 |
Napoleonville Liquid Storage Risk Management Plan: Executive Summary
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES
The Coastal Field Services Company (Coastal) Napoleonville Liquid Storage has a long standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of the facility's processes. The Coastal policy is to implement reasonable controls to prevent foreseeable releases of substances. However, if a release does occur, trained personnel will respond to control and contain the release.
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES
Coastal owns and operates Napoleonville Liquid Storage facility located in Assumption Parish, Louisiana. Napoleonville Liquid Storage is a natural gas liquids storage facility that receives propane or butanes and raw make by pipeli
ne. The site consists of product storage equipment. Products are transported from the facility via pipeline.
Napoleonville Liquid Storage was evaluated to determine if any regulated flammable or toxic substances exceeded the threshold quantity. Based on process knowledge, Coastal identified the regulated substances and quantities kept on site.
The listed flammable substances that are stored above threshold quantities at Napoleonville Liquid Storage are raw make and propane. Based on worst-case analysis, the distance to the endpoint exceeds the distance to public receptors. In addition, Napoleonville Liquid Storage is subject to OSHA PSM. Therefore, Napoleonville Liquid Storage is classified as a Program 3 process under the ARP program.
OFF-SITE CONSEQUENCE ANALYSIS RESULTS
Flammable Substances - Worst-Case Scenario
The endpoint for worst-case release of flammable substances is 1 psi overpressure (i.e., 15.7 psia), resulting from a vapor cloud explosion. The ARP Program requir
ement for flammables assumes an instantaneous release and vapor cloud explosion. A yield factor of 10 percent of the available energy released in the explosion shall be used to determine the distance to the explosion endpoint. Since the worst-case release scenario for a flammable substance is based on the assumption that the entire quantity of the substance forms a vapor cloud, passive mitigation systems are not applicable. In accordance with 40 CFR 68.25(a)(2)(iii), an additional worst-case release scenario was analyzed since potentially affected public receptors differ between the listed flammable substances evaluated. The worst-case flammable release for the propane has a 0.67-mile distance to the endpoint. The worst-case flammable release for raw make has a 0.57-mile distance to the endpoint.
Flammable Substances - Alternative-Case Scenario
A single alternative release scenario for all flammable substances is required under the ARP program. A hypothetical, but likely to occ
ur, release scenario has been identified for raw make as follows. A product pump seal failure during transfer operations causes a release from a one-inch opening. The pump operates at 1,600 psig (discharge pressure) and 82?F. The release is assumed to continue for 10 minutes. The discharge raw make will vaporize and may ignite in a vapor cloud explosion with an endpoint of 1 psi overpressure. The distance to 1 psi overpressure for the alternative-case release of raw make using the EPA equations was calculated. The gas factor used in these equations was from the components (n-butane and isobutane) representing the heaviest gas components of the mixture. The alternative-case release of raw make resulted in a 0.21-mile distance to the 1 psi overpressure endpoint.
Napoleonville Liquid Storage does not have any toxic substances held above the threshold quantity. Therefore, analysis of worst-case or alternative-release scenarios for toxic substances is not require
GENERAL ACCIDENT RELEASE PROGRAM
The following is a summary of the of the accident prevention program in place at Napoleonville Liquid Storage. Because the processes at the plant that are regulated by the Environmental Protection Agency's (EPA's) risk management program (RMP) regulation are also subject to the Occupational Safety and Health Administration's (OSHA's) 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.
Active employee participation and involvement in the development and implementation of Napoleonville Liquid Storage's PSM program is an important step toward achieving the objective to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. Employee involvement will help to ensure that all perspectives regarding PSM are considered, and that the best
ideas are implemented. Open communications are encouraged between supervisors and employees regarding all safety and health issues.
Napoleonville Liquid Storage strongly promotes employee involvement in safety issues through existing programs. These programs include a Health, Safety & Environmental Team (which are made up of a cross section of employees and supervision), regularly scheduled safety meetings, tail-gate safety meetings, Hazard Communication, Safety Suggestion Forms, "near-miss" reporting, Behavioral Based Safety Programs and special training programs (emergency response training, first aid, etc.).
Napoleonville Liquid Storage actively seeks employee involvement in the development and conduct of all accident prevention activities through the appropriate existing safety programs. Accident prevention is discussed at the regularly scheduled safety meetings and/or during special training sessions if necessary. Employees are encouraged to discuss accident prevention with
their supervisors if they have questions, comments, or suggestions.
Process Safety Information
Complete and accurate written Process Safety Information (PSI) concerning process chemicals, process technology, and process equipment is essential to effective PSM and RMP programs and to completing and maintaining a process hazard analysis (PHA). The process safety information will be useful to the operators; the team performing the PHA; those in charge of training; contractors; those conducting pre-startup safety reviews; and those in charge of updating the emergency preparedness plans. PSI is under continual development.
Napoleonville Liquid Storage 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.
Chemical-specific information, including
exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDS).
The facility 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, and electrical rating of equipment. 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)
Napoleonville Liquid Storage has a developmental program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process will be systematically examined to identify hazards and ensure that adequate controls are in pla
ce to manage these hazards.
Napoleonville Liquid Storage primarily uses the hazard and operability (HAZOP) and What-if/Checklist method analysis technique to perform these evaluations. 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 the team 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 facility 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.
Napoleonville Liquid Storage maintains written procedures that address various modes of process operations, such as; (1) startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures provide guidance for experienced op
erators and also provide the basis for training new operators. Operating procedures are periodically reviewed and annually certified as current and accurate. The review and certification process involves both operators and technical staff.
The intent of the operating procedures is to provide workable, useful, and clearly written instructions for conducting operating activities. To have effective operating procedures, the task and procedures directly and indirectly related to the covered process must be appropriate, clear, consistent, and most importantly, communicated to employees. Operating procedures are specific instructions or details on what steps are taken or followed in carrying out the stated procedures. The specific instructions include the applicable safety precautions and appropriate information on safety implications.
In addition to training on operating procedures, Napoleonville Liquid Storage has initiated a comprehensive training program for all employee
s involved in operating the process. New employees receive basic training in facility operations. In addition, all operators will periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at acceptable levels. This refresher training is conducted at least every 3 years. All of this training is documented for each operator including the means used to verify that the operator understood the training.
Napoleonville Liquid Storage uses contractors during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the facility has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have appropriate knowledge and skills, (3) are aware of the hazards of their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site specific safety rules, and (6) inform liquid
storage personnel of any hazards that they find during their work. This is accomplished by providing contractors with an orientation session that covers (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to beginning their work. In addition, Napoleonville Liquid Storage evaluates contractor safety programs and performance during the selection of a contractor. Facility personnel periodically monitor contract performance to ensure that contractors are fulfilling their safety obligations.
Pre-startup Safety Review (PSSR)
Napoleonville Liquid Storage will conduct a PSSR on any new facility or facility modification that requires a change in process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and 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 design specification and that all supporting systems are operationally ready. The PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented.
Napoleonville Liquid Storage has well established practices and procedures for maintaining process equipment. The basic aspects of this program include (1) training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting equipment deficiencies, when identified, 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 health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practi
ces to help ensure that they can perform their jobs in a safe manner.
Another integral part of mechanical integrity program is quality assurance. Napoleonville Liquid Storage 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 made.
Safe Work Practices
Napoleonville Liquid Storage 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 undergoing maintenance, (3) a procedure for safe removal of hazardous substances before process piping and 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 plac
e 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
Napoleonville Liquid Storage has a comprehensive system to manage changes to all covered processes. This system requires that changes to items such as process equipment, technology (including process operating conditions), procedures, and other facility changes 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, will be updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change.
Napoleonville Liquid Storage 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 gather the facts, determine the root cause, and develop corrective action to prevent the reoccurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendation to prevent a recurrence, and forwards these results to the business management team for resolution.
To help ensure that the accident prevention program is functioning properly, Napoleonville Liquid Storage 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 participate as audit team members. The audi
t team develops findings that are forwarded to facility management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained.
CHEMICAL SPECIFIC PREVENTION STEPS
The processes at Napoleonville Liquid Storage have hazards that must be managed to ensure continued safe operation. The following is a description of existing safety features applicable to prevention of accidental releases of regulated substances in the facility.
Universal Prevention Activities
The accident prevention program summarized previously is applied to all RMP-covered processes at Napoleonville Liquid Storage. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors.
Specialized Safety Features
Napoleonville Liquid Storage 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:
1. Hydrocarbon detectors with alarms
1. Process relief valves that discharge to a flare to capture and incinerate episodic releases
2. Valves to permit isolation of the process (manual or automated)
3. Automated shutdown systems for specific process parameters (e.g., high temperature)
4. Curbing or diking to contain liquid releases
5. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump)
6. Atmospheric relief devices
1. Fire suppression and extinguishing systems
2. Deluge system for specific equipment
3. Trained personnel in emergency procedures
4. Personal protective equipment (e.g., chemical protective clothing, face shields)
FIVE YEAR ACCID
Napoleonville Liquid Storage has an excellent record of accident prevention. Over the past 5 years there have been no accidental releases.
EMERGENCY RESPONSE PROGRAM INFORMATION
Napoleonville Liquid Storage maintains a written emergency response 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 response, including proper first aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post-incident cleanup and decontamination requirements. In addition, the facility has procedures that address maintenance, inspection, and testing of emergency response equipme
nt, 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 response program is updated when necessary based on modifications made to Napoleonville Liquid Storage facilities. The emergency response program changes will be administered through the Management of Change (MOC) process, which includes informing and/or training affected personnel in the changes.
The overall emergency response program for Napoleonville Liquid Storage is coordinated with the First Call Network. This coordination includes periodic meetings of the First Call Network, which includes local emergency response officials, local government officials, and industry representatives. Napoleonville Liquid Storage has around-the-clock communications capability with the First Call Network. This provides a means of notifying the public of an incident, if necessary, as well a
s facilitating quick response to an incident. In addition to periodic First Call Network meetings, Napoleonville Liquid Storage conducts periodic emergency drills that involve the First Call Network, and the facility provides annual refresher training to local emergency responders regarding the hazards of regulated substances at the site.