"Red Cedar Gathering Company, Arkansas Loop Plant" - Executive Summary |
|
EXECUTIVE SUMMARY 1. Accidental release prevention and emergency response policies: Red Cedar Gathering Company's Arkansas Loop treating facility, removes water and carbon dioxide from methane gas. The EPA considers methane hazardous. The same properties making methane valuable as a fuel also makes it necessary to observe certain safety precautions. Procedures for handling methane to prevent unnecessary human exposure, to reduce the known risk to personnel, and to reduce the potential of high pressure releases, fire, or explosion, have been established and are routinely critiqued. Our policy is to adhere to established industry practices and comply with federal rules and regulations. Employee training and direct supervision assures adherence to safe work practices, maintenance of facility safety devices, and facility design and operating requirements. Our emergency response is based on a "Let it burn" or a "No heroes" approach to safety. Shutting-it-in, venting, and waiting fo r the escaping volumes to dissipate into the atmosphere, controls escaping methane. Local fire and police departments are notified to assist in controlling on-lookers and any fires that may occur in the surrounding forest or grassland. 2. The Stationary source and regulated substance handled. The purposes of this facility are to remove impurities from methane and compress it into transportation pipelines. The regulated substance handled and distributed is Methane. Methane is not stored in this facility. 3. The worst-case scenario, including administrative controls and measures to limit the distance. Worst-Case Scenario: Complete horizontal breach of the Plant No. 2 Gas Contactor. The methane would vent through the breach to the atmosphere. At a working pressure of 1,200 psig the pressure escaping from the breach would drop to 1 psi at less than 528 ft. Less than 5,000 pounds of methane will escape immediately (in less than 5 minutes) to the atmosphere. The area of the exp losive limit (5% to 15% for methane) in the escaping volume will decrease rapidly as the methane expands upwards into the atmosphere. This facility has an emergency shut down system that is activated manually for most emergencies (such as Worst-Case above) and automatically for fire (infrared sensors) or gas leak detection (LEL, % gas detectors). During an emergency shut down, the facility's inlet and outlet valves close automatically and strategically located vent valves automatically open to the atmosphere. The entire facility is designed to evacuate its methane to the atmosphere in 5 minutes or less. A methane release would not leave the facility's perimeter boundary and the atmosphere directly above the facility is not routinely used by aircraft. 4. The general accidental release prevention program and specific steps. This facility was constructed to comply with NFPA 101- Life Safety Code Standards, Chapters 1, 2, 5, 6, 7, 29, NFPA- 70, National Electrical Code and ASME B 3 1.3 Process Piping Standard and complies with sound engineering procedures and practices. The plant operators have been thoroughly trained in emergency procedures for handling methane gas releases. Personnel working in the facility are required to adhere to a site-access plan and are accounted for in any emergency. 5. Five-year accident history. There has never been an accidental release of methane that ignited or exploded. No one off-site or on-site has ever been injured due to an accidental release of methane. No property damages have occurred on-site or off-site due to an accidental release of methane. No highways or adjacent roadways have ever been closed due to an accidental methane release. 6. Emergency response. The facility's emergency response is based on OSHA's 1910.38 (Employee emergency plans and fire prevention). This facility does not have a fire brigade. Employees have been instructed to activate the Emergency Shut Down System and evacuate the facility in a n emergency. Animas La Plata fire district personnel will not enter this facility in a fire or explosion emergency but may be summoned to control on-lookers and any grass or shrub fires on the surrounding property. Fire district personnel will assist in caring for any resulting injuries. 7. Planned changes to improve safety: This facility was constructed in 1989 and has had no major safety up-grades. Being an OSHA 1910.119 PSM facility, constantly places all elements of the process under scrutiny. Safety issues are continuously addressed. |