Worland Gas Plant - Source |
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***** Risk Management Plan *****
***** Section 1. Registration Information ***** * Source Identification Facility Name: Worland Gas Plant Parent Company #1 Name: Devon Energy Corporation (Nevada) Parent Company #2 Name: * Submission and Acceptance Submission Type: First-time submission Description: Receipt Date: 21-JUN-1999 Postmark Date: 15-JUN-1999 Next Due Date: 15-JUN-2004 Completeness Check Date: 06-JUL-1999 Complete RMP: YES De-Registered Date: De-Registered Effective Date: Certification Received: YES * Facility Identification EPA Facility Identifier: 1000 0009 2231 Other EPA Systems Facility ID: * Dun and Bradstreet Numbers (DUNS) Facility DUNS: Parent Company #1 DUNS: 049401565 Parent Company #2 DUNS: * Facility Location Address Street 1: 364 Highway 20 North Street 2: City: Worland State: WYOMING ZIP: 82401 ZIP4: 9724 County: WASHAKIE Facility Latitude and Longitude Lat. (dd mm ss.s): 44 07 48.0 Long. (ddd mm ss.s): -107 54 33.0 Latitude (decimal): 44.13 Longitude (decimal): -107.909167 Lat/Long Method: Classical Surveying Techniques Lat/Long Description: Administrative Building * EPA Default Map Value Latitude/Longitude EPA Default Map Value Latitude (decimal): 44.13 EPA Default Map Value Longitude (decimal): -107.909167 EPA Default Map Value Lat/Long Method: CLASSICAL SURVEYING TECHNIQUES EPA Default Map Value Lat/Long Description: ADMINISTRATIVE BUILDING * Owner or Operator Operator Name: Devon Energy Corporation (Nevada) Operator Phone: (405) 235-3611 Mailing Address Operator Street 1: 20 North Broadway Operator Street 2: Operator City: Oklahoma City Operator State: OKLAHOMA Operator ZIP: 73102 Operator ZIP4: 8260 Operator Foreign State or Province: Operator Foreign ZIP: Operator Foreign Country: * Name and title of person or position responsible for part 68 (RMP) implementation RMP name of person: Charles McDonald RMP Title of person or position: Environmental/Safety Specialist * Emergency Contact Emergency contact name: Guy Shipley Emergency contact title: Plant Supervisor Emergency contact phone: (307) 347-2495 Emergency contact 24-hour phone: (307) 347-2495 Emergency contact ext. or PIN: * Other Points of Contact Facility or Parent Company E-mail Address: Facility Public Contact Phone: none Facility or Parent Company WWW Homepage Address: * Local Emergency Planning Committee LEPC: Washakie County LEPC * Full Time Equivalent Employees Number of full time employees (FTE) on site: 9 FTE Claimed as CBI: * Covered by OSHA PSM : YES EPCRA 302 : CAA Title V: Air Operating Permit ID: * OSHA Ranking OSHA Star or Merit Ranking: * Last Safety Inspection Last Safety Inspection (by an External Agency) Date: Last Safety Inspection Peformed by an External Agency: Never had one * Predictive Filing Did this RMP involve predictive filing?: * Confidential Business Information (CBI) CBI Claimed: Substantiation Provided: Unsanitized RMP Provided: * Reportable Accidents Reportable Accidents: No accidents meeting RMP reporting requirements were claimed. ***** Executive Summary ***** Devon Energy Worland Gas Plant Risk Management Plan: Executive Summary ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The Devon Energy Worland gas plant 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 a strong record for safety in the design, installation, operation, and maintenance of Devon's equipment and processes. Devon's policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, trained gas plant personnel will respond to control and contain the release. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES The Worland gas plant, located 9 miles north of Worland, Wyoming, operates a variety of processes to produce petroleum products (e.g., natural gas, propane, butane, and condensate) from wet (i.e. contains hydrocarbon liquids) natural gas. The Worland gas plan t produces several regulated flammables, such as propane and butane. OFFSITE CONSEQUENCE ANALYSIS RESULTS The worst-case scenario (WCS) associated with flammable substances in Program Level 3 processes at the gas plant is a rupture of a tank car being loaded with propane at the tank car loading rack, with the car almost full and product being pumped into it. A north to south or west to east wind of any velocity could carry released propane to either one of two offsite receptors. These sites are a house 650 feet south of the loading station, and an occupied compressor station 875 feet to the east of the loading station. Ignition of the released propane could cause a vapor cloud explosion, jet fire, pool fire or BLEVE of the tank. No other dwellings are within the endpoint distances calculated for this situation. Approximately 120,000 pounds of propane could be released. The endpoint at 1 psi is 2,112 feet from the loading rack. Ten percent of the released quantity is assumed t o participate in the resulting explosion. Safety shutoff valves located at a safe distance are present to stop flow to the tank car. The alternative release scenario (ARS) is a rupture of a propane storage tank at the tank farm with the tank almost full and propane being produced into it. A north to south wind of any velocity could carry released propane to an ignition point creating a potential vapor cloud explosion and subsequent jet fire, pool fire, and/or BLEVE. Affected offsite habitation is one home 1,914 feet south of the storage tanks, and an occupied compressor station 875 feet east of the storage tanks. No other dwellings are within the endpoint distances calculated for this tank. Approximately 144,398 pounds of propane could be released. The endpoint at 1 psi is 2,270 feet. Ten percent of the released quantity is assumed to participate in the resulting explosion. Isolation valves are present at the plant and a PSV (pressure safety valve) is present on the tank. Che mical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For specific process areas, the gas plant has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in a key process parameter document. The gas plant ensures that the process is maintained within these limits using highly trained personnel, process controls and monitoring instruments, and protective instrument systems (e.g., manual and automated shutdown systems). The gas 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, volume 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) The Worland gas plant has a comprehensive program to help ensure that existing and potential 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 Worland gas plant primarily uses the "what if" analysis technique to perform these evaluations. The analyses are conducted using a multi-disciplined 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 a ccident prevention and mitigation measures, and the team makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. 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 plant periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every five 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. PRE-STARTUP SAFETY REVIEWS (PSSRs) The Worland gas plant 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 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 the design specifications and that all supporting 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 as a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. MECHANICAL INTEGRITY The Worland gas 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 condit ion. 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, health, environmental hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their jobs in a safe manner. Written procedures 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 for pressure vessels, relief valve testing). If a deficiency is identified, emplo yees will correct the deficiency, if it is considered to be a major potential safety problem before placing the equipment back into service, or a management of change team 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 Worland gas plant incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. SAFE WORK PRACTICES The Worland gas 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 undergoing maintenance, (3) a procedure for safe removal of hazardous subst ances 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 and during 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. SPECIALIZED SAFETY FEATURES The Worland gas 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 in the process building. Release Containment/Control 1. Process relief valves that discharge to a flare to incinerate episodic releases; 2. Valves to permit isolation of the process (manual or automated); 3. Automated shut down systems for specific process parameters (e.g., high/low temperature, pressure and volume); 4. Redundant equipment and instrumentation (i.e., backup firewater pump); 5. Atmospheric relief valves. Release Mitigation 1. Fire suppression and extinguishing systems; 2. Trained emergency response personnel; 3. Personal protective equipment (e.g., fire retardant clothing). PLANNED CHANGES TO IMPROVE SAFETY The Worland gas plant resolves all findings from PHAs, some of which result in modifications to the process. The following types of changes are planned over the next few years in response to PHA, safety audit, and incident investigation findings: 7 Upgrade process control system to use distributed computerized control system. * Process Chemicals Process ID: 14765 Description: Process Chemical ID: 18097 Program Level: Program Level 3 process Chemical Name: Propane CAS Number: 74-98-6 Quantity (lbs): 750000 CBI claimed: Flammable/Toxic: FLAMMABLE Process ID: 14765 Description: Process Chemical ID: 18098 Program Level: Program Level 3 process Chemical Name: Butane CAS Number: 106-97-8 Quantity (lbs): 490000 CBI claimed: Flammable/Toxic: FLAMMABLE * Process NAICS Process ID: 14765 Process NAICS ID: 15125 Program Level: Program Level 3 process NAICS Code: 211112 NAICS Description: Natural Gas Liquid Extraction ***** Section 2. Toxic: Worst Case ***** ***** Section 3. Toxic: Alternative Release ***** ***** Section 4. Flammables: Worst Case ***** Flammable Worst ID: 2382 Model Used: EPA's RMP Guidance for Propane Storage Facilities Reference Tables or Equations Endpoint Used: 1 PSI Passive Mitigation considered Blastwalls: Other: ***** Section 5. Flammable: Alternative Release ***** Flammable Alter ID: 1938 Model Used: EPA's RMP Guidance for Propane Storage Facilities Reference Tables or Equations Passive Mitigation considered Dikes: Fire Walls: Blast Walls: Enclosures: Other: Active Mitigation considered Sprinkler System: Deluge System: Water Curtain: Excess Flow Valve: YES Other Type: ***** Section 6. Accident History ***** ***** Section 7. Program Level 3 ***** ** Description: propane Program Level 3 Prevention Program Chemicals Prevention Program Chemical ID: 10031 Chemical Name: Propane Flammable/Toxic: FLAMMABLE CAS Number: 74-98-6 Prevention Program Level 3 ID: 7455 NAICS Code: 211112 * Saftey Information Safety review date (The date on which the safety information was last reviewed or revised): 17-DEC-1998 * Process Hazard Analysis (PHA) PHA completion date (date of last PHA or PHA update: 17-DEC-1998 The Technique Used What IF: YES Checklist: What If/Checklist: HAZOP: Failure Mode and Effects Analysis: Fault Tree Analysis: Other technique used: PHA change completion date (The expected or actual date of completion of all changes resulting from last PHA or PHA update): 01-FEB-1999 Major Hazards Identified Toxic release: Fire: YES Explosion: YES Runaway reaction: Polymerization: Overpressurization: Corrosion: Overfilling: YES Contamination: Equipment failure: YES Loss of cooling, heating, electricity, instrument air: Earthquake: Floods (flood plain): Tornado: Hurricanes: Other major hazard identified: Process Controls In Use Vents: YES Relief valves: YES Check valves: YES Scrubbers: YES Flares: YES Manual shutoffs: YES Automatic shutoffs: YES Interlocks: YES Alarms and procedures: YES Keyed bypass: Emergency air supply: YES Emergency power: YES Backup pump: YES Grounding equipment: YES Inhibitor addition: Rupture disks: Excess flow device: YES Quench system: Purge system: None: Other process control in use: Mitigation Systems In Use Sprinkler system: Dikes: Fire walls: Blast walls: Deluge system: Water curtain: Enclosure: Neutralization: None: YES Other mitigation system in use: Monitoring/Detection Systems In Use Process area detectors: YES Perimeter monitors: None: Other monitoring/detection system in use: Alarms and Shutdowns Changes Since Last PHA Update Reduction in chemical inventory: Increase in chemical inventory: Change process parameters: Installation of process controls: Installation of process detection systems: Installation of perimeter monitoring systems: Installation of mitigation systems: None recommended: None: YES Other change since last PHA or PHA update: Review of Operating Procedures Operating procedures revision date (The date of the most recent review or revision of operating procedures): 04-FEB-1999 * Training Training revision date (The date of the most recent review or revision of training programs): 23-JUL-1998 The Type of Training Provided Classroom: YES On the job: YES Other type of training provided: The Type of Competency Testing Used Written test: YES Oral test: Demonstration: Observation: Other type of competency testing used: * Maintenance Maintenance procedures revision date (The date of the most recent review or revision of maintenance procedures): 19-MAY-1995 Equipment inspection date (The date of the most recent equipment inspection or test): 15-DEC-1998 Equipment tested: (Equipment most recently inspected or tested) TEG Unit * Management of Change Change management date (The date of the most recent change that triggered management of change procedures): 10-OCT-1997 Change management revision date (The date of the most recent review or revision of management of change procedures): 10-OCT-1997 * Pre-Startup Review Pre-startup review date (The date of the most recent pre-startup review): 10-OCT-1997 * Compliance Audits Compliance audit date (The date of the most recent compliance audit): 07-OCT-1998 Compliance audit change completion date (Expected or actual date of completion of all changes resulting from the compliance audit): 08-JAN-1999 Incident Investigation Incident investigation date (The date of the most recent incident investigation (if any)): Incident investigation change date (The expected or actual date of completion of all changes resulting from the investigation): * Employee Participation Plans Participation plan revision date (The date of the most recent review or revision of employee participation plans): 19-MAY-1995 * Hot Work Permit Procedures Hot Work permit review date (The date of the most recent review or revision of hot work permit procedures): 19-SEP-1996 * Contractor Safety Procedures Contractor safety procedures review date (The date of the most recent review or revision of contractor safety procedures): 19-SEP-1996 Contractor safety performance evaluation date (The date of the most recent review or revision of contractor safety performance): 01-AUG-1997 * Confidential Business Information CBI claimed: ***** Section 9. Emergency Response ***** * Written Emergency Response (ER) Plan Community Plan (Is facility included in written community emergency response plan?): YES Facility Plan (Does facility have its own written emergency response plan?): YES Response Actions (Does ER plan include specific actions to be taken in reponse to accidental releases of regulated substance(s)?): YES Public Information (Does ER plan include procedures for informing the public and local agencies responding to accidental release?): YES Healthcare (Does facility's ER plan include information on emergency health care?): YES * Emergency Response Review Review Date (Date of most recent review or update of facility's ER plan): 03-DEC-1998 * Emergency Response Training Training Date (Date of most recent review or update of facility's employees): 08-OCT-1998 * Local Agency Agency Name (Name of local agency with which the facility ER plan or response activities are coordinated): Worland Fire Department Agency Phone Number (Phone number of local agency with which the facility ER plan or response activities are coordinated): (307) 347-3679 * Subject to: OSHA Regulations at 29 CFR 1910.38: YES OSHA Regulations at 29 CFR 1910.120: YES Clean Water Regulations at 40 CFR 112: YES RCRA Regulations at CFR 264, 265, and 279.52: OPA 90 Regulations at 40 CFR 112, 33 CFR 154, 49 CFR 194, or 30 CFR 254: State EPCRA Rules or Laws: YES Other (Specify): TSCA |