Holland Plant - Executive Summary |
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EXECUTIVE SUMMARY 1. The stationary source and regulated substances handled. The primary function of this facility is twofold. The Holland Plant serves as a compression station for natural gas gathered from surrounding leases. The second function is the removal of liquid hydrocarbons from the gas stream through the use of a "Mixed Refrigeration Plant". The liquids removed include ethane, propane, butane and natural gasolene. The primary storage vessel is a pressurized 42,000 gallon horizontal tank. A 12,000 gallon pressurized tank and non pressurized 8,820 gallon steel tank also serve as temporary storage for the process. Liquids removed and stored are transported from the site via pressurized transports. The dry gas is moved by pipeline from the plant site. Access to this site is restricted to company employees and authorized contractors. The maximum amount of propane/butane mix stored on site is limited to 136,000 pounds. 2. Accidental release prevention and emergency response po licies. In this separation and compression facility, we handle both propane and butane which are considered hazardous by EPA. The same properties that make propane and butane valuable as a fuel also make it necessary to observe certain safety precautions in handling propane and butane to prevent unnecessary human exposure, to reduce the threat to our own personal health as well as our co-workers, and to reduce the threat to nearby members of the community. It is our policy to adhere to all applicable Federal and state rules and regulations. Safety depends upon the manner in which we handle the product, combined with the safety devices inherent in the design of this facility, combined with the safe handling procedures that we use and the training of our personnel and contractors. Our emergency response plan considers the safety of our employees, contractors and the public as our number one priority. Preservation of the plant equipment is secondary. We, therefore, are prepared to isola te and abandon the plant site in the event of a major release or fire. Minor leaks or spills will be handled as required by our employees. Provisions have been made to sever the flow of natural gas and associated liquids to the plant from safe remote locations. A lack of firefighting water limits the ability of emergency responders. 3. The worst-case release scenario and the alternate release scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario. Worst case scenario - Failure of the largest storage tank when filled to the greatest amount allowed would release 32,000 gallons of propane/butane/gasolene mix. Approximately 68 percent of the mix is propane and butane. Of the 68 percent, the tables indicate that 38 percent, or 35,143 pounds would immediately flash into vapor. A certain amount of the propane, butane, gasolene mix would be included as aerosol and spray. In order to include the aerosol and spray, the 35,142 pound s is doubled and 70,284 pounds are considered in the vapor cloud explosion calculations. The distance to a 1 psi overpresure is .33 miles or 1760 feet. There are no public receptors within the calculated 1 psi overpressure distance. Alternative scenario - A more realistic scenario would be the rupture of a loading hose during truck loading. An estimated maximum release of 500 pounds of product would result in a pooling of the heavier liquid on location, or in a drainage ditch west of the loading rack, with the remaining vapor traveling to the lower flammability limit. Should a vapor cloud explosion occur, the maximum distance to a 1 psi overpressure would not exceed .1 mile or 572 feet. The transport trailer is protected by excess flow valves designed to halt the flow. 4. The general accidental release prevention program and the specific prevention steps. This liquid separation facility complies with EPA's Accidental Release Prevention Rule and with al l applicable state codes and regulations. This facility was designed and constructed in accordance with good engineering practice. Plant operators have been trained in the operation of the plant to insure that design parameters are not exceeded. 5. Five Year History The Holland Plant was constructed and came on line in 1991 and has operated since that time without an accidental release of a regulated substance where exposure to the substance, its reaction products, overpressure generated by and explosion involving the substance, or radiant heat generated by a fire involving the substance led to any of the following offsite: (i) Death (ii) Injury or (iii) Response or restoration activities for an exposure of an environmental receptor 6. The emergency response program. This facility's emergency response program is based on prior hazmat training and discussion with the emergency responders from the town of Gordon, Strawn and the City of Mineral Wells. 7. Planned changes to imp rove safety. Training will be extended to all company employees who operate in the Holland Plant area. Training will center on steps necessary to isolate and restrict the flow of gas and liquids to the plant. Operating parameters will be discussed. This will enable an employee to immediately recognize an unsafe situation and react accordingly. Additional dikes will be constructed to better contain the heavy liquids on location. |