Kentucky Hydrocarbon- Dwale Plant - Executive Summary |
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Kentucky Hydrocarbon Dwale Plant is a natural gas liquids extraction facility located in a semi-rural section of Floyd County near Allen, Kentucky. At this location, we extract approximately 33,000 gallons of y-grade natural gas liquid product per day which is continuously pumped to a three-inch pipeline system destined to the Marathon-Ashland Refinery in Catlettsburg, Kentucky. This product primarily consists of liquid propane with smalller quantities of liquid butane, pentane, iso-butane, iso-pentane, hexane-plus, ethane and methane. This mixture of NGL product is flammable and is considered to be hazardous by the U.S. Environmental Protection Agency. The storage facility for this product consists of one 10,000 gallon horizontal tank. Also on site, we have a storage facility for 10,000 gallons of liquid propane which is used in the refrigeration of natural gas liquids. The liquid propane is delivered to the plant by transort truck as needed. These two storage tanks a re located in the same proximity and are considered the same process. It is our policy to take a proactive approach to the safe handling of these products to prevent unnecessary human exposure, reducing the threat to our own personal health and to nearby members of the community. We comply with all applicable Federal and State rules and regulations including OSHA Process Safety Management. These regulations require specific actions to identify potential hazards in the process, to train operators in procedures to reduce potential releases of highly hazardous chemicals, and to take appropriate measures all designed to reduce the likelihood of uncontrolled process releases. Due to diligence in our safety and prevention program, there have been no reportable accidental releases of highly hazardous chemicals at this plant for the last five years. In the event of an accicental release of chemicals, we are trained to respond to the circumstances involved in potential occurrences by means of an Emergency Action Plan. This includes a step by step plan for protecting plant personnel and the general public in the event of an unwanted, uncontrolled release of a hazardous material by providing established response and evacuation procedures. The Emergency Action Plan also involves the participation of the Allen Fire Department. Members of the Fire Department visited the plant on May 3, 1999 and were issued copies of Kentucky Hydrocarbon's Emergency Action Plan and copies of the list of plant safety systems and their functions. After a discussion of the responsibilities of plant personnel and the role the Fire Department would take in the event of a release of highly hazardous chemicals, the members were given a tour of the plant. At the Dwale Plant, prevention is our first priority as is reflected by our history of safe operations. Even so, we must look at the possibility of a worst-case scenario. In this scenario, we look at the potential of an aircraft cra sh or earthquake. If either were to happen, it is possible that our product storage tank and liquid propane storage tank, that are located in the same general vicinity, could fail. This resulting failure could release 82,000 pounds of a regulated flammable mixture into the atmosphere as a vapor cloud and could travel approximatelaly 0.4-mile to the endpoint of 1 psi and ignite. The estimated residential population within this distance is apprroximately 156. In a more plausible alternate case scenario, we will examine the possibility of a release of liquid propane due to a severed fill hose on the propane transport truck. This particular situation could occur if the driver pulls away from the unloading terminal with the fill hose still attached. The pull-away would cause the failure of an 18-foot length of two inch inside diameter hose and the resulting unconfined vapor could travel to its lower flammable limit. Due to operation of the excess flow and check valves, on ly 12 pounds of liquid propane would be dispersed. The distance to the endpoint of 1-psi lower flammability limit is an estimated 53 feet and would not extend beyond the facility boundary. Mitigating and administrative controls, such as the aforementioned excess flow valves and check valves, truck driver training in Process Safety Management Propane Unloading Procedures, and operator training and awareness will reduce the possibility of this scenario becoming an eventuality. |