Marmarth - Executive Summary
BEAR PAW ENERGY, INC. |
Marmarth Gas Plant
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES
Bear Paw Energy 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. However, if a release does occur, gas plant trained personnel will respond to control and contain the release. The following is a statement from Bear Paw Energy Senior Management. Bear Paw Energy Inc. believes in maintaining a safe working environment for all employees. Our equipment and personnel reflect this belief, and our prime objective is to ensure the personal safety of every employee on the job-site and to safe guard company property through preventative measures. Employees of Be
ar Paw Energy Inc. are expected to be familiar with all company safety policies. Through continuing education, in-house training and management support, we will provide a safe and professional working environment for our employees as well as those whose lives and safety have been entrusted to us.
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES
The Marmarth Gas Plant, located in Slope Co., North Dakota, uses cryogenic fractionation to process wellhead gas into marketable natural gas and natural gas liquids (NGL). As a result of this operation, several EPA regulated flammable substances are processed, recovered, and stored at the facility (e.g., methane, ethane, propane, butane, pentane, and natural gas condensate). There is approximately 293,000 lbs of flammable product stored in various tanks on site. The Marmarth Gas Plant does not use or store any regulated toxic substances above the EPA set threshold levels. The facility is unmanned.
OFFSITE CONSEQUENCE ANALY
The worst-case scenario (WCS) associated with a release of flammable substances in Program Level 1 process at the Marmarth Gas Plant is a vapor cloud explosion (VCE) resulting from a release of 120,600 pounds of a flammable mixture from the stations largest storage vessel. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for administrative controls, or active or passive mitigation measures were taken into account in evaluating this WCS. The maximum distance to the 1-psi endpoint for this WCS is 0.4 mile. Zero public and zero environmental receptors were identified within the 0.4 mile radius.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM
The Marmarth Gas Plant complies with EPAs Accidental Release Prevention Rule and with all applicable state codes and regulations. The plant was designed and constructed in accordance with NFPA, API, ASME, and other codes and regulations. All of our operators have been thorou
ghly trained in plant operation, safety, process hazards, and emergency response.
FIVE-YEAR ACCIDENT HISTORY
We investigate every incident very carefully to determine ways to prevent similar incidents from recurring. We have had NO releases, associated with the plants EPA regulated substances, that resulted deaths, injuries, significant property damage, environmental damage, evacuations, or sheltering in place in the last five years.
EMERGENCY RESPONSE PROGRAM INFORMATION
The plant maintains a written emergency response plan, which is in place to protect worker and public safety as well as the environment. The plan consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion. Company employees receive training in these procedures as necessary to perform their specific emergency response duties. If an emergency were to occur, the stations emergency response plan provides instructions to employees for notification o
f the local fire authority Slope County Fire Departments and Sheriffs office.
The emergency response plan is updated when necessary based on modifications made to the plants operation or equipment, changes in receptors, or responders. The emergency response program changes are administered through the MOC process, which includes informing and/or training affected personnel in the changes.
PLANNED CHANGES TO IMPROVE SAFETY
Bear Paw Energy Inc. recognizes the value of the PSM standard as a way of safely conducting their business operations. Therefore we are currently implementing the PSM elements to our Non-PSM regulated processes and facilities.