Vastar Resources, Inc. - Grand Chenier Gas Plant - Executive Summary |
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25999 LDEQ Facility ID Number Grand Chenier Gas Plant Risk Management Plan Executive Summary ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES Vastar Resources, Inc.s (Vastars) policy is to manage all operations in a manner that protects the environment and the health and safety of employees, customers, contractors, and the public. This 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. While prevention is our goal, if a release does occur, trained personnel will respond to control and contain the release. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES Vastars Grand Chenier Gas Plant, located in Grand Chenier, Louisiana, operates a variety of processes to extract natural gas liquids from natural gas. The plant has hydrocarbon mixtures containing regulated flammable substances including methane, ethane, propane, n-b utane, iso-butane, n-pentane, and iso-pentane. The plant does not have threshold quantities of any regulated toxic substances. OFFSITE CONSEQUENCE ANALYSIS (OCA) RESULTS The worst-case scenario (WCS) is failure of a 120,000-gallon storage tank containing natural gas liquids (NGL) resulting in a vapor cloud explosion (VCE). Based on the TNT equivalency method contained in EPAs RMP Offsite Consequence Analysis Guidance, the WCS would impact public receptors. The alternative release scenario (ARS) is a VCE resulting from the release of 18,400 gallons of NGL, which is the normal inventory of the 120,000-gallon storage tank. (The NGL storage tanks are almost never filled to capacity.) Based on flash formation factors from EPAs RMP Offsite Consequence Analysis Guidance and a yield factor of 0.03, the ARS would impact public receptors. While vapor cloud explosions are generally considered unlikely events, this ARS is more likely than the WCS and satisfies the ARS requirement o f impacting public receptors. As such, it represents a more practical scenario for emergency planning. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM The following is a summary of the accident prevention program in place at the plant. Because processes at the gas plant that are regulated by the Environmental Protection Agency's (EPA's) risk management program (RMP) regulation are also subject to the Occupational Safety and Health Administration's (OSHA's) process safety management (PSM) standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. Employee Participation The Grand Chenier gas plant encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team. E mployees have access to all information created as part of the gas plant accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that is maintained at the gas plant and addresses each accident prevention program element. In addition, the gas plant has a number of initiatives under way that address process safety and employee safety issues. These initiatives include an area safety committee to promote both process and personal safety. The teams typically have members from various areas of the plant, including operations and maintenance. Process Safety Information The Grand Chenier 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 equipment design basis/configuration inform ation. The Management of Change process insures process safety information is kept up to date. 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. Plant specific operating procedures contain safety-related limits for specific process parameters (e.g., temperature, level, composition). The gas plant ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and safety systems. 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 electr ical rating of equipment. 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. Process Hazard Analysis (PHA) The Grand Chenier gas plant has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. The Grand Chenier gas plant primarily uses checklists to perform these evaluations. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and the team makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team findings are resolved by local management. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options in response to PHA team findings are tracked until they are completed. The final resolution of each finding is documented and retained. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the plant periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. The results and findings from thes e updates are documented and retained. Once again, the team findings are resolved by local management, and the final resolution of the findings is documented and retained. Operating Procedures The Grand Chenier gas plant maintains written procedures that address various modes of process operations, 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 can be used as a reference by experienced operators and provide a basis for consistent training of new operators. These procedures are periodically reviewed and annually certified as current and accurate. The procedures are kept current and accurate by revising them as necessary to reflect changes made through the management of change process. Training To complement the written procedures for process operations, the Grand Chenier gas plant has implemented a comprehensive training program for all emplo yees involved in operating a process. New employees receive basic training in gas plant 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. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every 3 years. All of this training is documented for each operator, including the means used to verify that the operator understood the training. Contractors The Grand Chenier gas plant uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or ne ar process equipment, the gas plant has procedures in place to ensure that contractors (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) safety orientations , (2) pre-job safety meetings, and (3) a work permitting system. In addition, the Grand Chenier gas plant evaluates contractor safety programs and performance prior to 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) The Grand Chenier gas plant conducts a PSSR for any new facility or facility modification that requires a change in the process s afety information. The purpose of the PSSR is to ensure that safety features, procedures, 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. This is part of the management of change process. Mechanical Integrity The Grand Chenier 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 inc lude: (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. Maintenance personnel receive training on (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 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. The Grand Chenier 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 The Grand Chenier gas plant uses the Vastar Resources safety and health manual as a guideline to help ensure worker and process safety. The safety manual contains minimum safety standards for the following operations (1) fire and safe work permits, (2) lockout/tagout, (3) tagging & flagging, (4) blinding (5) vessel & confined space entry, (6) excavating & trenching, (7) inservice welding and hottapping. These procedures, along with training of personne l, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change The Grand Chenier gas plant has a comprehensive system to manage all non-like-kind changes within the covered processes. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized 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 compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change. Incident Investigation The Grand Chenier gas plant promptly investigates all inc idents. 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) who could be affected by the findings. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations. Compliance Audits To help ensure that the accident prevention program is functioning properly, Vastar Resources periodically conducts an audit to determine whether the procedures and practices re quired by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. Both hourly and staff personnel may 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 the Grand Chenier 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 accidental releases of regulated substances in the facility. Universal Prevention Activities The accident prevention program summarized previously is applied to all RMP-covered processes at the Grand Chenier 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 The Grand Chenier 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 a release. The following types of safety features are used in the covered processes: Release Detection 1. Hydrocarbon detectors with alarms. 2. Facility is manned 24 hours per day. Release Containment/Control 1. Process relief valves that discharge to a flare to capture and incinerate releases 2. Valves to permit isolation of the process (manual and automated) 3. Automated shutdown systems for specific process parameters (e.g., high temperature) 4. Curbing or diking to contain liquid releases 5. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system, backup firewater pump) 6. Atmospheric relief devices. Release Mitig ation 1. Fire suppression and extinguishing systems 2. Personnel are trained in their emergency response duties 3. Personal protective equipment FIVE-YEAR ACCIDENT HISTORY Vastar became operator of the Grand Chenier Gas Plant in May, 1995. Prior to this, Vastar already had an ownership interest in the plant. During the period that Vastar has operated the plant, there have been no incidents resulting from RMP regulated substances in covered processes that have caused either: (1) onsite deaths, injuries, or significant property damage, or (2) offsite deaths, injuries, property damage, evacuations, sheltering in place, or environmental damage. To Vastars knowledge, there were no such incidents during the balance of the five year period; that is, the year or so prior to Vastar becoming operator. EMERGENCY RESPONSE PROGRAM INFORMATION The Grand Chenier gas plant maintains a written emergency response program, which is in place to protect both plant personnel and the public . The program consists of procedures for responding to an incident, 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. Affected personnel or informed and/or trained, as appropriate, r egarding the changes. The overall emergency response program for the Grand Chenier gas plant is coordinated with the Cameron Parish Civil Defense Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings with local emergency response officials. The Grand Chenier gas plant has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. The Grand Chenier gas plant conducts periodic emergency drills that involve the LEPC and emergency response organizations. PLANNED CHANGES TO IMPROVE SAFETY The Grand Chenier 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: 1. Upgraded process control system to use distributed computerized control system, 2. Revised personnel training programs, and 3. Revised written operating procedures. |