Hainesville Gas Processing Plant - Executive Summary
Risk Management Plan |
Hainesville Gas Processing Plant
June 3, 1999
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES
The Hainesville Gas Processing Plant is committed to protecting the health and safety of company personnel and contractors working in the facility, neighbors in the surrounding area, and the environment. This commitment is strongly supported by company management and is demonstrated by the resources invested in accident prevention, which include, but are not limited to training and safety in the operation, and maintenance of the plant. The facility implements both administrative and engineering controls to minimize the risk of an uncontrolled release of a flammable substance. An uncontrolled release is not anticipated. In the event such a release should occur, the personnel at the plant, in cooperation with local response agencies, are able to respond, minimize and/or eliminate any exposure that could occur to protect employees, contrac
tors, and the surrounding area.
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES
The Hainesville Natural Gas Processing Plant receives raw natural gas from producing wells. The raw natural gas enters the processing plant by pipeline where it is treated to remove water and other contaminants. Residue gas in the form of methane leaves the plant by pipeline to sales. Natural gas liquids and condensate are stored at the plant site prior to sales. Propane is also stored at the plant. Listed flammable components of the stored natural gas liquids include methane, ethane, propane, butane, isobutane, pentane and isopentane. These llisted components, along with 2,2-dimethylpropane, also a flammable, make up the condensate. Natural gas liquids and condensate leave the plant by transport vehicles. There are no regulated toxic substances stored at the plant. Operators are knowledgeable as to the activation of the emergency shutdown, which will limit the exposure of any relea
se to the surrounding public.
OFFSITE CONSEQUENCE ANALYSIS RESULTS-Worst Case Scenario
The Worst Case Scenario would be the release of natural gas liquids stored on site in one 30,000-gallon storage tank. The assumption is made that the entire contents of the tank is released at once. The release scenario was calculated using the Environmental Protection Agency's RMP*COMP(TM). Employees visually inspect the plant each day and provide any necessary maintenance, thereby decreasing the possibility of any release to the outside environment. A preventive maintenance program further reduces the possibility of a release equal to the Worst Case Scenario.
OFFSITE CONSEQUENCE ANALYSIS RESULTS-Alternative Release Scenario
The Alternative Release Scenario is the assumption of a release of the natural gas liquids contained within one 30,000-gallon tank over a ten-minute period. The release scenario was calculated using the Environmental Protection Agency's RMP*COMP(TM). Employees visua
lly inspect the plant each day and provide any necessary maintenance, thereby decreasing the possibility of any release to the outside environment. A preventive maintenance program further reduces the possibility of a release equal to the Alternative Release Scenario.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM
The Hainesville Plant is regulated by many Occupational Safety and Health Administration (OSHA) Standards and Regulations. It also complies with regulations governed by the Environmental Protection Agency (EPA). Among many regulations, this facility is regulated by Title 29 of the Code of Federal Regulations, Section 1910.119 (Process Safety Management of Highly Hazardous Chemicals), and Section 1910.38 (Employee Emergency Plans). It is also governed by Title 40 of the Code of Federal Regulations, Section 112 (Spill Prevention Control and Countermeasure). It also complies with federal Emergency Planning and Community Right to Know Regulations, in addition to state reg
ulations which aim to reduce the potential for a release of chemicals to the environment. These regulations include the control of emission releases outlined in the Texas Natural Resource Conservation Commission Air Regulations and the Statewide Rules for Oil, Gas and Geothermal Operations governed by the Railroad Commission of Texas.
The facility Accident Prevention Program incorporates all of the requirements of Process Safety Management of Highly Hazardous Chemicals and EPA's Risk Management Program. Other safety practices followed at the plant are found in the many plans, procedures and documents maintained on site. This information, along with the employee and contractor training program, is used for the prevention, or mitigation of any chemical release. The Accident Prevention Program is used in the identification, evaluation, prevention or mitigation of chemical releases resulting from a failure in processes, procedures or equipment. The Employee Participation Program r
esults in the development of the necessary expertise, experience, judgement and initiative within the workforce.
Employees have received comprehensive training. The training program is on-going, and incorporates information for the handling of on-site, listed RMP chemicals. Employees have received training about the process, including operations and maintenance procedures and safe work practices.
Safe work practices have been developed to ensure safe operations consistent with industry practice and meet regulatory requirements. These practices include lock-out/tag-out, line breaking, confined space entry and hot work permits to ensure the safe operation of the facility and the protection of employees, contractors, and the surrounding area.
An incident investigation will be conducted in the event that such a situation occurs. The results of the investigation will be used to enhance the safe operation of the facility.
Audit procedures have been established and are followed to
ensure the continued integrity of the prevention program, and the safety of employees, contractors and the protection of the surrounding environment.
FIVE-YEAR ACCIDENT HISTORY
The Plant has had no release of chemicals that caused any on-site, or off-site consequences during the past five years.
EMERGENCY RESPONSE PROGRAM INFORMATION
The Hainesville Plant maintains a written Emergency Response Plan, which is in place to protect employees and contract workers, ensure public safety, and to protect the environment. The plan details procedures for contacting responders for mitigation of a release of a regulated substance. The plan addresses aspects of emergency response by outside experts, and includes instructions for communication, first aid, evacuation, accounting for personnel, company and agency notification procedures, and post incident cleanup and decontamination. In addition, the Plant has procedures that address maintenance, inspection, and testing of any emergency response
equipment maintained on site, as well as instructions that address the use of emergency protection equipment. Employees receive appropriate training in procedures necessary to perform their specific emergency response duties which includes contacting trained responders. The Emergency Response Plan is updated when necessary based on modifications made to plant processes or other facilities within the plant. Changes to the plan include informing and/or training affected personnel of the changes.
PLANNED CHANGES TO IMPROVE SAFETY
No changes have been identified that would improve the safety record. The Plant maintains an ongoing safety training program so that employees and contractors have current information. Any new or modified equipment will be designed with appropriate safety controls and devices.