Henry Gas Processing Complex - Executive Summary

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Risk Management Plan 
Henry Gas Processing Complex 
Executive Summary 
LaDEQ Henry Gas Processing Complex ID No. 615 
    The Henry Complex has a long-standing commitment to worker and public safety.  This commitment is demonstrated by our efforts in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes.  Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances.  However, if a release does occur, Henry Complex trained personnel will evaluate the situation, take actions within the capabilities of the Henry Complex, and/or notify the necessary outside agencies. 
    The Henry Complex consists of two processes, Henry Processing / Natural Gas Liquid (NGL) Fractionation Area and Henry Product Storage Area. The Complex location is 5624 Aristide 
Road near Henry, Louisiana.   
    It should be noted that the Henry Product Storage Area is no longer being used for product storage and the Henry Processing / NGL Fractionation Area is no longer processing gas and/or NGL fractionation.  It should also be noted that there are no immediate plans to return either of these processes to their original operational service.  In its current state, the Henry Processing / NGL Fractionation Area provides (1) condensate/free liquid removal and dehydration of natural gas prior to re-delivery to transmission pipeline systems, and (2) Y-grade NGL product handling and delivery services into NGL transmission pipeline systems.  The Henry Product Storage Area is not being used to store any new products. However, for the purpose of this RMPlan submittal, the inventory calculations and the off-site consequence analyses were based on the entire Henry Complex being in full operational service.   
    The worst-case 
scenario (WCS) for the Henry Complex is a vapor cloud explosion involving the largest inventory of a flammable mixture (predominately consisting of Normal Butane) contained in a single pressurized storage vessel.  The maximum quantity possible contained within this storage vessel is 1,500,000 pounds.  Although administrative controls are in place to limit this quantity, those controls were not considered in calculating this maximum quantity determination.  The entire inventory of the storage tank is assumed to release, forming a vapor cloud, igniting and exploding - creating a Vapor Cloud Explosion (VCE).  Using RMP*CompTM, the maximum distance to the 1-psig overpressure endpoint is 0.9 miles. Although there are numerous controls to prevent such releases, and to manage their consequences, no credit for passive mitigation measures was taken into account in evaluating this WCS. 
    The alternative release scenario (ARS) that is used as a planning case at the Henry Complex is a 1" nozz 
le on a propane storage tank detaching, and causing a release of pressurized propane liquid to the atmosphere at a rate of 475 pounds per minute.  This particular ARS is assumed to last for 10 minutes before operation of isolation valves, pumps, fire monitor cooling water and/or other mitigating actions can be utilized to mitigate the release.  Under this ARS, the released propane vapor is accidentally ignited - causing a vapor cloud fire (VCF).  Using RMP*CompTM, the maximum distance to the Lower Flammability Limit endpoint for this ARS is 0.1 mile.  With a radius of 0.1 miles, this ARS would extend outside of the boundary of the Henry Complex possibly impacting an industrial area.  This event was selected as being a practical scenario for use in emergency planning and response. 
    The following is a summary of the accident prevention program in place at the Henry Complex.  The above referenced processes at the Henry Complex are regu 
lated by both the Environmental Protection Agency's (EPA's) risk management program (RMP) rule and the Occupational Safety and Health Administration's (OSHA's) process safety management (PSM) standard.  Because RMP accident prevention requirements for these processes are essentially the same as PSM, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program at the Henry Complex. 
Employee Participation 
    The Henry Complex encourages employees to participate in all facets of process safety management and accident prevention, including process hazard analyses, incident investigations, and the development of operating and maintenance procedures. Employees also participate in safety meetings, resolving certain safety concerns, and updating and compiling technical documents and chemical information pertaining to the process and critical equipment.   
    Employees have access to all information creat 
ed as part of the Henry Complex's accident prevention program.  Specific ways that employees can be involved in the accident prevention program are documented in a written employee participation plan that is maintained at the Henry Complex.  This employee participation plan addresses each accident prevention program element.   
    In addition, the Henry Complex has a number of initiatives under way which address process safety and employee safety issues.  These initiatives include forming teams to promote both process and personal safety.  The teams typically have members from various areas of the Henry Complex, including operations, maintenance, engineering, and Henry Complex management. 
Process Safety Information 
    The Henry Complex 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 inventories; safety inter 
locks; suppression systems; vent and relief studies; 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). For specific process areas, the Henry Complex has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in the equipment specifications and operating procedures. The Henry Complex maintains the process within these limits by using process controls and monitoring instruments, trained personnel, and protective instrument systems (e.g., automated shutdown systems). 
    The Henry Complex also maintains 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 combinat 
ion with procedures and equipment operating history, provides a basis for inspection and maintenance activities, as well as for evaluating proposed process and facility changes so safety features in the process are not compromised. 
Process Hazard Analysis (PHA) 
    The Henry Complex has a comprehensive program to identify and control hazards associated with the various processes that are identified and controlled.  Within this program, each process is systematically examined to identify potential hazards and controls in place to manage these hazards, and recommend additional controls, as appropriate. 
    The Henry Complex uses a variety and combination of applicable methodologies to conduct PHAs.  These PHAs address (1) facility siting, (2) human factors, (3) qualitative evaluation of a range of the possible safety and health effects of failure of controls on personnel, and (4) one or more of the following methodologies appropriate to determine and evaluate the hazards of the p 
rocess, (a) What-if, (b) Checklist, (c) Hazard and Operability (HAZOP), (d) Failure Mode and Effects Analysis (FMEA), (e) Fault Tree Analysis, and/or (f) an appropriate equivalent methodology.  
    PHAs are conducted using a team of people who have the appropriate operating and maintenance experience for the process, as well as engineering expertise.  This PHA team identifies and evaluates potential hazards of the process, as well as accident prevention and mitigation measures, and then makes recommendations for additional prevention and/or mitigation measures.  
    The PHA team recommendations are forwarded to local management for resolution. Implementation of additional prevention and/or mitigation options in response to PHA recommendations is based on a relative priority ranking assigned by the PHA team.  The approved mitigation options in response to PHA team recommendations are tracked until they are completed.  The final resolution of each recommendation is documented and r 
    The Henry Complex periodically revalidates these PHAs.  These PHAs are revalidated at least every 5 years, and will be conducted at this frequency until the process no longer contains hazardous chemicals above the threshold quantities.  The recommendations from these revalidated PHAs are also forwarded to management for consideration, and the final resolution of each revalidated PHA recommendation is documented and retained. 
Operating Procedures 
    The Henry Complex maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) 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 basis for consistent training of new operators.  These procedures are periodically reviewed and annually certified as current and accurate. In addition, the Henry Complex maintains i 
nformation on how to respond to upper or lower limit exceedances for specific process or equipment parameters.  This information, along with written operating procedures, is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks. 
    To complement the written procedures for process operations, the Henry Complex has implemented a comprehensive training program for employees involved in operating a process.  New operational employees receive training on the Henry Complex's Operating Procedures, and basic training in process operations if they are not already familiar with such operations.  After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks.  After operators demonstrate 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, or more frequently upon request. All of this training is documented for each operator, including skills demonstration used to verify that the operator understood the training.  Process maintenance personnel are trained in their perspective duties for maintaining the mechanical integrity of critical process equipment and systems.  Operational and maintenance personnel also receive training on the procedures for conducting hot work permitting; lockout/tagout, management of change; and other appropriate safe work practices.   
    The Henry Complex uses contractors to supplement its workforce during periods of increased maintenance or construction activities.  Because some contractors work on or near process equipment, the Henry Complex has procedures in place to verify that con 
tractors perform their work in a safe manner.  These contractor safety procedures include steps to verify contractors (1) have the appropriate knowledge and skills to perform their jobs safely, (2) are aware of the hazards in their workplace, (3) understand what they should do in the event of an emergency, (4) understand and follow site safety rules and (5) inform facility personnel of any potential hazards that they introduce or find during their work.  Contractors working within the Henry Complex are provided with (1) a process overview, (2) information about safety and health hazards, (3) emergency procedure requirements, and (4) site-specific applicable safe work practices prior to their beginning work.  In addition, the Henry Complex evaluates contractor safety programs and performance prior to selection of a contractor. Henry Complex personnel periodically monitor contractor performance with respect to their safety obligations, and provide contractors with applicable safety perfo 
rmance feedback. 
Pre-startup Safety Reviews (PSSRs) 
    The Henry Complex conducts a PSSR for any new facility or facility modification that requires a change in the process safety information.  The purpose of the PSSR is to see 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 that construction is in accordance with the design specifications and required safety systems are operationally ready.  A PSSR also verifies that appropriate safety, operational and maintenance procedures are in place, and adequate training has been provided to the appropriate personnel.  A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented.  When new facilities are commissioned, a PHA is included in the PSSR.   
Mechanical Integrity 
    The Henry Complex has 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) utilization of appropriately trained maintenance personnel, (2) developing written procedures, and (3) performing inspections and tests, and correcting identified deficiencies.  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 procedures, and (5) applicable safe work practices to help ensure that they can perform their jobs in a safe manner. Written inspection, testing and maintenance procedures provide that work is performed in a consistent manner, and serve as a basis for training maintenance per 
sonnel in their relative assigned duties.  Inspections and tests are performed to help verify equipment functions as intended and that equipment is within acceptable limits.  If a deficiency is identified that presents an immediate safety concern, Henry Complex personnel will correct the defect before placing the equipment back into service.  
Safe Work Practices 
    The Henry Complex has long-standing safe work practices in place to help provide worker and process safety.  Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to isolate energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous substances 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 verify that adequate precautions are in place before entry into a confined space.  These procedures (and others), a 
long with training of affected personnel, form a system to help perform operations and maintenance activities safely. 
Management of Change 
    The Henry Complex has a comprehensive system to manage changes to all covered processes.  This system requires that changes to items such as process equipment, chemicals, technology (including operating conditions of the process), procedures, and other facility changes be properly reviewed and authorized before being implemented.  Changes are reviewed to (1) determine 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, equipment information, and operating procedures are updated prior to incorporating these changes.  In addition, operating and maintenance personnel and affected contractors are provided any necessary training on the change. 
Incident Investigation 
    The Henry Complex p 
romptly investigates all incidents related to a covered process 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 factors that may have led to the incident, and develop corrective actions to prevent a recurrence of the incident or a similar incident.  The investigation team documents its recommendations to prevent a recurrence, and forwards these results to Henry Complex management for resolution.  Corrective actions taken in response to the investigation team's recommendations are tracked until they are complete.  The final resolution of each recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the recommendations.  Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future and revalidate 
d PHAs.  
Compliance Audits 
    To help determine that the accident prevention program is functioning properly, the Henry Complex 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 in these audits.  The audit team develops findings that are forwarded to Henry Complex 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.   
    The processes at the Henry Complex have potential hazards that are managed for continued safe operation.  The following is a description of current safety features applicable to prevention of accidental releases of regulated substances in the faci 
Universal Prevention Activities 
    Henry Complex's previously summarized accident prevention program is applied to RMP-covered processes at the Henry Complex. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. 
Specialized Safety Features 
    The Henry Complex has safety features to provide a means of containing /controlling a release, detecting a release, and reducing the consequences of (mitigate) a release.  The following types of safety features are used in the covered processes:  
    Monitoring and detection systems include (1) Hydrocarbon gas detectors to detect the presence of hydrocarbons, (2) Operations personnel on site 24 hours per day providing routine surveillance, (3) Camera surveillance from the Control Room, (4) Audible and visual warning alarms, and (5) Distributed Control System (DCS) on some processes providing real-time monitoring and control. 
   Containment and process controls include (1) Relief devices to avoid overpressure of process equipment, (2) Flare system to capture and incinerate episodic releases, (3) Valves to permit process control or isolation (manual or automated), (4) Interlocks and automated shutdown systems for specific process parameters (e.g., high temperature, pressure, level, etc.), (5) Curbing or diking for spill prevention and control, and (6) Redundant equipment and instrumentation (e.g., uninterruptible power supply for DCS). 
    Active and passive mitigation systems include (1) Fire suppression and extinguishing systems, (2) Emergency procedures to react to emergencies, and (3) Communications link with local emergency planning committee (LEPC). 
    Release mitigation systems include (1) Fire suppression and extinguishing, (2) Coordination with emergency response personnel, and (3) Personal protective equipment (e.g., fire retardant clothing). 
    The Henry Co 
mplex has an excellent record of accident prevention over the past 5 years. The following table is a summary showing we have had no RMP incidents that have occurred during the past 5 years.  
                                                                          1995  1996  1997  1998  1999  2000 
Number of RMP Events with Onsite Effects         0        0        0        0        0        0 
Number of RMP Events with Offsite Effects         0        0        0        0        0        0 
    The Henry Complex maintains a written emergency response and action plan, which is in place to help protect worker and public safety as well as the environment.  The plan identifies steps to be taken in case of an accidental release 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 responding to small fires and ot 
her emergencies.  Employees receive training in these procedures as necessary to perform their specific emergency duties.  This plan is updated when necessary based on modifications made to the Henry Complex.   
    The overall emergency response program for the Henry Complex has been coordinated with the Henry Volunteer Fire Department.  The Henry Complex is manned 24 hours a day and has around-the-clock communications capability with the Henry Volunteer Fire Department, the Vermilion Parish Office of Emergency Preparedness, and the Vermilion Parish Sheriff Department.  This interface provides the means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident.  
    The Henry Complex has completed all of the planned changes for the improvement of safety as indicated in our initial submission, these changes included: (1) Significantly reducing total inventories of flammable chemicals, (2) Installa 
tion of a 50,000 barrel fire water storage tank, (3) Replacement of the existing firewater pumps with pressure demand auto-start diesel driven firewater pumps, (4) Replacement of the plant air compressors to increase instrument air pressure and capacity, (5) Replacement of flood-pit pumps, (6) Demolition and removal of steam boilers, sponge oil furnace and associated piping containing hazardous materials, (7) Installation of concrete containment systems around pumps, equipment and storage vessels to contain potential hazardous liquid spills, and (8) Installation of flare stack continuous monitoring system.
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