Martin County Plant - Executive Summary |
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GPM Martin County Gas Processing Plant Executive Summary ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES Martin County gas processing 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 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. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES This program level 1 GPM gas processing plant operates a variety of processes to produce petroleum products (e.g., natural gas, natural gas liquids, and condensate) from raw natural gas. This plant has two regulated flammables: Propane and NFPA 4 flammable mixtures. OFFSITE CONSEQUENCE ANALYSIS RESULTS The WCS associated with a release of flammable substances in this program level 1 gas plant is a vapor cloud explosion (VCE) involving the full inventory of the largest storage tank containing a NFPA 4 flammable mixture (product surge tank). The maximum distance to the 1-psi endpoint for this WCS is 0.40 mile. Although we have 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. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM The following is a summary of the accident prevention program in place at the plant. Although the processes at the plant are regulated by the Environmental Protection Agency's (EPA's) risk management program (RMP) regulation, they are not subject to the Occupational Safety and Health Administration's (OSHA's) process safety management (PSM) standard. However, this summary describes several management system elements in place to improve the accident prevention program. Employee Participation This program level 1 GPM gas plant encourages employees to participate in all facets of accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of incident investigation teams. Employees have access to all information created as part of the gas plant accident prevention program. In addition, the gas plant has a number of initiatives under way that 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 plant, including operations, maintenance, engineering, and plant management. Process Safety Information This program level 1 GPM gas plant 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 eq uipment design basis/configuration information. Chemical-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. The gas plant utilizes process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems) to maintain safe conditions. 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 and temperature ratings, and electrical rating of equipment. This information, in combination with trained personnel, provides a basis for establishing inspection and maintenance activities, as well as f or evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. Training This program level 1 GPM gas plant has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in gas plant 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 (e.g., through tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. Contractors This program level 1 GPM gas plant uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the gas plant has procedures in place to ensure that contr actors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform gas plant personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) information about safety and health hazards, (2) emergency response plan requirements, and (3) safe work practices prior to their beginning work. In addition, this program level 1 GPM gas plant evaluates contractor safety programs and performance during the selection of a contractor. Gas plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-startup Safety Reviews (PSSRs) This program level 1 GPM gas plant conducts a PSSR for any new facility or facility modification that requires a change in the process. The purpose o f the PSSR is to ensure that safety features, 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 a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. Mechanical Integrity This program level 1 GPM 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 condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) performing inspections an d 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) safety and health hazards, (2) applicable maintenance procedures, (3) emergency response plans, and (4) 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). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), 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. This program level 1 GPM gas plant 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 This program level 1 GPM gas plant has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include (1) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (2) a procedure for safe removal of hazardous substances before process piping or equipment is opened, (3) a permit and procedure to control spark-producing activities (i.e., hot work), and (4) a permit and procedure to ensure that adequate precautions are in place 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. Incident Investigation This program level 1 GPM gas plant 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 determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to gas plant management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) wh o could be affected by the findings. Compliance Audits To help ensure that the accident prevention program is functioning properly, this program level 1 GPM gas plant 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 audit team develops findings that are forwarded to gas plant 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 this program level 1 GPM gas plant have hazards that must be managed to ensure continued safe operation. The following is a description of existing safety features applicable to prevention of accid ental releases of regulated substances in the facility. Universal Prevention Activities The accident prevention program summarized previously is applied to all processes at this program level 1 GPM gas plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. Specialized Safety Features This program level 1 GPM 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 Containment/Control 7 Process relief valves that discharge to a flare to capture and incinerate episodic releases 7 Valves to permit isolation of the process (manual or automated) 7 Automated shutdown systems for specific process parameters (e.g., high temperature) 7 Curbing or diking to contain liquid releas es 7 Redundant equipment and instrumentation 7 Atmospheric relief devices. Release Mitigation 7 Trained emergency response personnel 7 Personal protective equipment (e.g., chemical protective clothing, self-contained breathing apparatus). FIVE-YEAR ACCIDENT HISTORY This program level 1 GPM gas plant has an excellent record of accident prevention over the past 5 years. There has been a decreasing trend in the frequency of accidental releases. None of the incidents that have occurred in the past 5 years resulted in offsite effects. We investigate every incident very carefully to determine ways to prevent similar incidents from recurring. EMERGENCY RESPONSE PROGRAM INFORMATION This program level 1 GPM gas plant 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 plant has procedures that address maintenance, inspection, and testing of emergency response equipment, 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 gas plant processes or other GPM gas plant facilities. This program level 1 GPM gas plant conducts periodic emergency drills that may involve the LEPC and emergency response organizations, and the gas plant provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the gas plant. PLANNED CHANGES TO IMPROVE SAFETY This program level 1 GPM 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 Revisions to personnel training programs 7 Improved equipment reliability program |