Mustang Gas Plant - Executive Summary
Mustang Gas Plant Risk Management Plan: Executive Summary |
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE
The Mustang Gas Plant has a long-standing commitment to the safety of the neighboring community as well as employees and contractors on plant property. Conoco, operator of the Mustang Gas Plant, is dedicated to safety and environmental stewardship, which are two of the company's core values. Safety and protection of the environment are an integral part of Conoco's operations and corporate culture.
The Mustang Gas Plant adheres to all Conoco policies, which can be summarized as follows with regard to safety and environmental stewardship:
7 All Safety and Environmental incidents are preventable.
7 The Goal is Zero - Zero Significant Incidents, Period.
7 All employees and contractors are responsible for their personal safety.
Conoco Corporate policies are embodied in the numerous Safety, Health, and Environmental Policies & Procedures which apply globally to Cono
co operations. At the Mustang Gas Plant, these policies are outlined and implemented via the Mustang Gas Plant Safety, Health, and Environmental (SHE) Manual. This manual is available to all employees, and all employees have been trained in their specific responsibilities for Safety, Health, and Environmental compliance. In addition, the Mustang Gas Plant complies with the Process Safety Management (PSM) Program requirements, which are managed and implemented via the Natural Gas and Gas Products (NG&GP) Process Safety Management Program manual. This manual is also available to all employees, and all employees receive specific training on Process Safety Management and their role in the program. The Mustang Gas Plant also maintains an Incident Response Plan that details the complete Emergency Response program for the site.
The Mustang Gas Plant's dedication to safety is demonstrated in many ways. The Plant and Conoco have a safety record that is consistently among the very best in
the energy industry in the United States. To help ensure the safety of Conoco operations, the company invests significant resources in accident prevention. Accident prevention includes designing safe plants and operating facilities, conducting and providing safety training for employees and contractors, and developing and implementing safe work practices and procedures for the operation and maintenance of plants, processes, and operations facilities. Conoco's policies and dedication to safety and environmental stewardship help to prevent accidental releases. If, despite our best attempts to prevent such incidents, a release should occur, trained personnel will respond to, control, and contain the release in accordance with the plant's Incident Response Plan.
This document has been prepared in accordance with the EPA's new Risk Management Program (RMP) regulations (40 CFR Part 68), which were promulgated in the Federal Register on Thursday, June 20, 1996, Vol. 61, No. 120.
SCRIPTION OF THE FACILITY AND THE REGULATED SUBSTANCES
The Mustang Gas Plant, located in Tuttle, Grady County, Oklahoma, is jointly owned by Conoco (80 percent) and C&L Processors Inc.(20 percent), and operated by the Conoco NG&GP Department. The Mustang Gas Plant is a natural gas processing plant that recovers hydrocarbon liquids from unprocessed natural gas. Two natural gas inlet streams (Low Pressure System) are delivered via pipeline to the plant. The recovered hydrocarbon liquids are transported via pipeline to fractionation plants for further processing and eventual sales. After processing, the residue gas from which the hydrocarbon liquids are recovered is delivered to a gas pipeline for eventual sales. The Mustang Gas Plant operation includes inlet gas separation, dehydration, cryogenic gas processing (recovery of natural gas liquids), product surge capacity, and compression.
In accordance with the EPA's Risk Management Program (RMP) regulations (40 CFR Part 68)
, the Mustang Gas Plant's inventory of chemicals was evaluated to determine if any regulated flammable or toxic substances were on the plant site in quantities above the threshold quantities. [Note: The term "threshold quantity" is the quantity above which the EPA has decided that the substance will be regulated.] Our evaluation determined that the following listed flammable substances are handled by the plant in quantities above the substance's threshold quantity: Ethane-Propane-Butane-Condensate (EPBC)/Propane-Butane-Condensate (PBC) mix, condensate, and propane. There are no toxic substances above the threshold quantity at the plant. [Note: Condensate is exempt from threshold determination provisions of the regulation based on its National Fire Protection Association (NFPA) rating of 3.]
WORST-CASE AND ALTERNATIVE-CASE TOXIC RELEASE SCENARIOS
The Mustang Gas Plant does not have any toxic substances above threshold quantity. As the plant does not have any toxic substances, tox
ic release scenarios were not addressed.
WORST-CASE FLAMMABLE RELEASE SCENARIO
The RMP regulation requires the operator to model the worst-case release scenario, which the regulations define as the "release of the largest quantity of a regulated substance from a vessel or process line failure. For flammables, this hypothetical worst case assumes an instantaneous release and a vapor cloud explosion. These assumptions are required without regard to whether a scenario is realistic or improbable. PBC/ EPBC Mix was used in the model for the hypothetical worst-case flammable scenario. The worst-case scenario was modeled on the assumption of the instantaneous release of all of the PBC/EPBC in the largest PBC/EPBC vessel. Under the stipulated guidelines, this hypothetical release, if ignited, would have an off-site impact, as determined by the use of the OCA Guidance. [Note: The OCA Guidance is EPA's Off-Site Consequence Analysis Guidance document.]
Passive mitigation systems were not
applied because of the assumption for the scenario that the entire contents of the vessel be instantaneously released. We believe that a vessel failure such as this is extremely unlikely because the vessels are carefully designed with significant engineering safety factors. In addition, all pressure vessels are carefully inspected and pressure tested before they are placed in service, and the Mustang Gas Plant follows a rigorous Mechanical Integrity Program to ensure that all process equipment is properly maintained and inspected, to prevent leakage or failure.
ALTERNATIVE FLAMMABLE RELEASE SCENARIO
The RMP regulations require the operator to model a single "alternative release scenario" for all regulated flammable substances. For the Mustang Gas Plant, this hypothetical scenario was modeled on the basis of a seal failure on the PBC/EPBC Mix pipeline pump, which was assumed to last for ten minutes. Passive mitigation systems such as leak detection, gas detection, and emergency sh
utdown systems would enable the plant to isolate and eliminate such a release within that time-frame. The alternative release scenario has off-site impact, but there is no impact to any receptors (i.e., residential populations, industrial, etc.), as determined by the use of the OCA Guidance, the "Landview" program census data, and actual survey data.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND
CHEMICAL-SPECIFIC PREVENTION STEPS
The Mustang Gas Plant adheres to the policies and procedures provided in the Process Safety Management (PSM) Program. These policies and procedures include and embrace the requirements of 29 CFR 1910.119 and 40 CFR Part 68.
The following is a general overview of the main elements of the Risk Management Program that are currently in operation at the Mustang Gas Plant. The Mustang Gas Plant has aligned and integrated its safety management programs at a high level with the Occupational Safety & Health Administration's (OSHA) Process Safety Management (
PSM) program regulations for consistency and effectiveness. As a result, this overview describes the safety management system that is in place for each of the safety management program elements, which also make up the Risk Management Program.
All employees (and contractors) at the Mustang Gas Plant are involved and participate in all facets of Process Safety Management (PSM) and accident prevention. Examples of Employee Participation include, among other things:
7 implementing Conoco policies and procedures concerning employee and public safety and environmental protection,
7 preparing and/or updating technical documents such as operating and maintenance procedures,
7 working in accordance with standard operating procedures and safe work practices,
7 participating in safety meetings,
7 participating in training,
7 participating in the Management of Change (MOC) process,
7 participating in the Process Safety Management (PSM) audit process or a Process Hazard
s Analysis (PHA) team.
Employees have access to, are aware of, and are trained about the existence and location of all of the information that is included in the facility's Risk Management Program. More specific ways that employees can be involved in the Risk Management Program are documented in an Employee Participation Plan that is maintained at the plant.
In addition, employees and management have a number of initiatives in place that are designed to improve safety at the plant. These initiatives are focused on both the plant processes and general worker safety (including slips, trips, and falls), and even off-the-job safety.
Process Hazard Analysis (PHA)
The Mustang Gas Plant has a comprehensive program to help ensure that potential hazards associated with the plant's operations and processes are identified and minimized. This is a systematic procedure in which each part of the process is systematically examined to identify all of the potential hazards associated with the
process, and to ensure that appropriate recommendations are developed and implemented to eliminate or control the potential hazards.
The Process Hazards Analysis procedure utilized at the Mustang Gas Plant is carried out by a team of functional experts from engineering, operations, maintenance, and safety, who work with a PHA Facilitator to identify and evaluate all of the potential hazards that could possibly result in a release of a regulated substance. The team also evaluates potential mitigation measures and accident prevention measures for each potential process hazard at the facility. The final part of the procedure requires the team to make specific suggestions for management consideration to address or mitigate each identified hazard.
The PHA team's findings and suggestions are provided to plant management for further evaluation and resolution. All approved mitigation options are then tracked as part of the process until they are completed. The final resolution of each fi
nding is documented and retained.
To help ensure that the process controls and/or process hazards are continuously evaluated and maintained in a safe condition, the plant periodically updates and revalidates the Process Hazard Analysis. These periodic reviews are conducted every 5 years and will continue at this frequency as long as the plant is in operation. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration, and final resolution of the findings is documented and retained.
Process Safety Information
The Mustang Gas Plant maintains a variety of technical data that is used to ensure safe operation of the processes. These data and documents include written data and engineering drawings on the design of the facility, the chemistry of the process and associated hazards, safe operating limits for key process parameters, specific chemical inventories, and equipment design basis/configurat
ion information. Specific personnel within the gas plant are assigned responsibility for maintaining up-to-date process safety information.
Safety data are maintained for all chemicals that are used, handled, or produced at the facility. These data include permissible exposure limits, physical data, reactivity and corrosive information, thermal and chemical stability, toxicity data (if applicable), personal protective equipment, and measures to be taken in the event of physical contact or airborne exposure to a chemical. This information is maintained in Material Safety Data Sheets (MSDS), as part of the Hazard Communication Program at the plant.
For specific process areas, the Plant has documented the safe operating limits for specific process parameters (e.g., temperature, pressure, level, etc.). The Plant ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems su
ch as automatic shutdown systems.
The Plant also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes design flow rates, fluid properties, pressures and temperatures that were the basis of the sizing of the different subsystems or individual pieces of equipment. The information on the process design also includes the materials of construction, design pressure and temperature ratings, and electrical ratings of equipment. The engineering data maintained at the plant includes a Plot Plan, Piping and Instrumentation Diagrams (P&IDs), Process Flow Diagrams (PFDs), Electrical Area Classification drawings, Safety Analysis and Function Evaluation (SAFE) Charts, Cause and Effect (C&E) Charts, and equipment specification/data sheets. 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.
The Mustang Gas Plant developed and maintains written operating procedures that provide plant operators with a clear understanding of the tasks involved in the safe operation of the facility. Operating procedures that address various modes of process operations are maintained, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures provide the basis for consistent training of new operators, and they provide good reference materials for experienced operators. These procedures are periodically reviewed and certified as current and accurate. Whenever a process modification is made, the procedures are revised as appropriate to cover the modification. The procedures are kept current by revising them as necessary to reflect changes
made through the management of change process.
These procedures are used in employee training, and are readily available to employees to use as necessary to safely perform their job tasks.
The Mustang Gas Plant employs a comprehensive training program for all employees at the plant. New employees receive job-specific basic training in gas plant operations. All operating and maintenance personnel receive facility-specific process overview training. Each employee receives training on, among other things, (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to ensure that they can perform their jobs in a safe manner. They are thereby trained in the specific knowledge, skills, and procedures needed to safely conduct their work. In addition, each operator receives facility-specific training on how to operate the plant, including detailed training on the ope
rating procedures, including startup, shutdown, normal operations, temporary operations, and emergency operations. As part of this training, an operator in training is paired with an experienced operator to learn process-specific duties and tasks. After operators demonstrate (through tests and skills demonstration) the knowledge to perform the duties and tasks in a safe manner on their own, only then can they work independently. In addition, all operators periodically receive refresher training to ensure that their skills and knowledge are maintained at a high level. This refresher training is provided as often as necessary, and no less than every 3 years. All of this training is documented for each operator, including the means used to verify that the operator understood the training.
The Mustang Gas Plant uses contractors to perform many project-specific activities and supplement the plant workforce during periods of increased maintenance or construction periods.
For those contractors who work on or near process equipment, the plant has procedures in place, that when followed, ensure that these contractors:
7 perform their work in a safe manner,
7 have the appropriate knowledge and skills to work safely around the process,
7 are aware of the hazards in their workplace,
7 understand what they should do in the event of an incident,
7 understand and follow site safety rules, and
7 inform gas plant personnel of any hazards that their work brings and/or that they find during their work.
The Mustang Gas Plant has developed and implemented safe work practices and procedures to control the entrance, presence, and exit of contract employers and employees in covered process areas.
Each contract employee is provided with site-specific training on the hazards that may exist at the plant. Each contract employee is provided an orientation on the known potential fire, explosion, or release hazards related to the contractor's work and the process, as well
as the applicable provisions of the incident response plan.
Contractor safety programs and safety performance are evaluated and become part of Conoco's contractor selection process. Conoco personnel periodically monitor contractor safety programs and performance records.
Management of Change (MOC)
Throughout the life of any operating facility, changes will often be necessary for example, to meet changing circumstances, to make needed improvements, or to alter the technology of the process. The Mustang Gas Plant has a comprehensive system in place to manage and document any such changes to the plant's processes. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, or other changes be properly reviewed and authorized by a number of people with different functional expertise before being implemented. This system of managing facility modifications is called Management of Change (MOC). This
system consists of a set of written procedures that are used to identify and eliminate hazards associated with a change to the facility's processes. MOC ensures that facility modifications are formally reviewed and approved before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been negatively affected by the change. A part of the MOC process ensures that any chemical hazard information, process operating limits, equipment information, and/or procedures are updated as appropriate to incorporate the effects of the modification. A critical piece of the MOC process ensures that operating and maintenance personnel are provided any necessary training regarding the process modification.
Pre-Startup Safety Reviews (PSSRs)
The Mustang Gas Plant conducts a Pre-Startup Safety Review (PSSR) for any modification that requires a change in the process safety information. The pur
pose of the PSSR is to ensure before startup of the modified process or unit that the modification was completed in accordance with design specifications. The PSSR is also intended to ensure that safety features, procedures, personnel, and equipment are properly prepared for startup before the modified equipment is put in service. Another key purpose of the PSSRs is to ensure that all personnel have been trained on the modification, including any revisions to the operating procedures or to the safety systems and controls. This review provides one additional check to make sure that all personnel and supporting systems are operationally ready to operate the newly-modified process or equipment. 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, Process Safety Management Program, and Risk Management Program requiremen
ts are properly implemented.
The Mustang Gas Plant has well-established practices and procedures to maintain process equipment in a safe operating condition. This mechanical integrity program includes pressure vessels, piping systems, relief and vent systems, controls, pumps, compressors, and emergency shutdown systems, among other items. 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.
As stated above (under Training), maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) incident response plans, and (5) applicable safe work practices to help ensure that they can perform their jobs in
a safe manner. In addition to being used in training, written procedures are intended to ensure that maintenance work is performed in a consistent manner.
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 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.
An integral part of the mechanical integrity program is quality assurance. Quality assurance measures are incorporated into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that the proper materials and spare parts are used when repairs are made.
Safe Work Practices
As part of the design and startup of the
facility, the Mustang Gas Plant developed safe work practices designed to ensure worker and process safety and these safe work practices are followed to ensure that operations and maintenance activities are performed safely. Examples of safe work practices 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 the safe removal of hazardous substances before process piping or equipment is opened,
4. a permit and procedure to control spark-producing activities (i.e., hot work permit),
5. a permit and procedure to ensure that adequate precautions are in place before entry into a confined space,
6. use of appropriate site-specific and job-specific personal protective equipment, and
7. a methodical procedure termed a Job Safety Analysis (JSA) for ensuring that the proper precautions are in place prior to undertaking any non-routine tasks.
fe work practices and procedures, along with training of affected personnel, form a system designed to ensure that operations and maintenance activities are performed safely at all times.
The Mustang Gas Plant promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire or explosion, gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and underlying cause(s) of the incident to develop corrective actions and implement steps to prevent a recurrence of the incident and prevent similar incidents. The investigation team documents its findings, develops recommendations to prevent similar incidents, and forwards these results to management for further action. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are fully implemented. The final resolution of each finding or recommendat
ion is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations.
To ensure that the Risk Management Program is functioning properly, the Mustang Gas Plant periodically conducts audits to verify that the policies, procedures and practices required by the Risk Management Program are being implemented properly and fully, to evaluate the effectiveness of the program, and to develop ideas for improving the program. These audits are independent, site-specific, and methodical. Compliance audits are conducted every 3 years. The findings of the audit are forwarded by the audit team to plant management for priority 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 d
ocumented, and the two most recent audit reports are retained for future review.
CHEMICAL-SPECIFIC ACCIDENT PREVENTION STEPS
The processes at the Mustang Gas Plant involve regulated substances that are controlled to ensure the continuous safe operation of the plant. The following is a description of existing safety features in place to prevent accidental releases of regulated substances at the facility.
Universal Prevention Activities
The Risk Management Program summarized above is applied throughout the Mustang Gas Plant. Collectively, these prevention program activities work to prevent potential accident scenarios that could be caused by equipment failures or human errors.
Specialized Safety Features
The Mustang Gas Plant has safety features throughout the facility to:
7 contain/control a release,
7 quickly detect a release, and
7 reduce the consequences of a release in the unlikely event of an accidental release.
The following types of safety features are used in the plan
Release Detection, including:
7 Hydrocarbon gas detectors with alarms
Release Containment/Control, including:
1. Process relief valves that discharge to a flare system to contain and incinerate releases;
2. Valves to permit isolation of the process (manual or automated);
3. Automated shutdown systems for specific process parameters (e.g., high pressure or temperature);
4. Curbing or diking to contain liquid releases;
5. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system); and
6. Pressure safety relief devices.
Release Mitigation, including:
1. Fire detection, suppression, and extinguishing systems, including portable fire extinguishers all around the plant, in addition personnel are trained in operating this equipment.
2. Personnel trained as First Responders;
3. Emergency Shut-Down (ESD) System to immediately isolate and shut down the process to minimize the release;
4. Immediate access to and communication with
local emergency response organizations, including the fire department, police, and other local emergency response organizations;
5. Incident Response Plan, which is a detailed emergency action plan that includes detailed procedures for responding to accidental releases; and
6. Incident Response Drills to simulate an accidental release to practice actual implementation of the Incident Response Plan and to coordinate response activities with the local emergency response organizations mentioned above.
THE FIVE-YEAR ACCIDENT HISTORY
No deaths, injuries, or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage have resulted from any activities or incidents at the Mustang Gas Plant for the past five years.
THE EMERGENCY RESPONSE PROGRAM
The Mustang Gas Plant maintains a written Incident Response Plan, which is in place to protect public safety and worker safety (both employees and contractors),
as well as the environment, and to minimize any effects in the unlikely event of an emergency. The plan consists of detailed procedures for responding to accidental releases, as well as procedures for responding to fires that might occur in the unlikely event of a release of a flammable substance. These response procedures address the following aspects of emergency response, and more:
7 proper first aid and treatment for any exposures;
7 evacuation plans which include provisions for accounting for all personnel (employees, contractors, and visitors) after an evacuation;
7 notification to appropriate emergency response agencies; and
7 post-incident cleanup and decontamination requirements.
The Plant has procedures that address maintenance, inspection, and testing of incident response equipment intended to ensure that the equipment will work as designed in the event of an emergency. Training is conducted to ensure the proper use of emergency response equipment, such as fire-figh
ting equipment. Employees are assigned specific roles that they would fill in the event of an emergency, and all employees receive specific training to enable them to fulfill their roles in an emergency. The incident response plan is updated when necessary based on legal requirements and modifications made to plant processes.
The overall incident response program for the Mustang Gas Plant is coordinated with the Tuttle Fire Department. This coordination includes periodic meetings of the committee to review incident response plans and facilitate communications and planning. Personnel are at the Plant, Monday-Friday, from 7:30 A.M. to 4:00 P.M. On Saturday and Sunday, personnel are there from 7:30 A.M. to 11:30 A.M. After hours emergency contact Number is 1- (405) 787-4212.
PLANNED CHANGES TO IMPROVE SAFETY
Rather than implement improvements in an ad hoc manner, the Mustang Gas Plant has processes in place that are employed to improve safety on a continuing and ongoing basis, to e
nsure that the safety programs are continuously improved. These processes include the following:
7 Incident response drills involving off-site emergency responders.
7 Process Hazards Analysis revalidations.
7 Management of change.
7 Mechanical Integrity & Quality Assurance.
7 Compliance audits.
7 Continued focus on the "The Goal is Zero" for injuries and incidents.
SAFETY IS A JOB REQUIREMENT FOR ALL EMPLOYEES AND CONTRACTORS.
AT CONOCO, OUR WORK IS NEVER SO URGENT OR IMPORTANT THAT WE CANNOT TAKE THE TIME TO DO IT SAFELY.