Tippett Gas Plant - Executive Summary |
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KOCH MIDSTREAM PROCESSING COMPANY Tippett Gas Plant McCamey, Texas EXECUTIVE SUMMARY FOR THE RISK MANAGEMENT PLAN (RMPlan) Introduction and Policies Under the Koch Environmental Excellence Program (KEEP) at Koch Industries, Inc., we are committed to being associated with unmatched environmental performance as measured by our employees, customers, regulators, and the public. Our KEEP management philosophy goals are achieved by the personal commitment of our employees and contractors, and by open communication with our employees, customers, neighbors, and with regulators. The accidental release prevention and emergency response programs we have at our facilities are part of the high standards we strive for through KEEP. Our high standards are achieved by operating in compliance with all required environmental permits and regulations, by operating and maintaining our assets in such a manner that any unpermitted release will be unintentional and acknowledged as unacceptable, by re medying any shortcomings found during regular audits of our facilities, and by reporting promptly to regulators any shortcomings found during the course of our audits as required by the law. The Tippett Gas Plant is one of several facilities operated by Koch Midstream Processing Company (Koch). The plant receives well gas from the surrounding oil and gas fields, processes the gas by removing carbon dioxide and water and transports the natural gas liquids as well as the compressed natural gas through pipelines to third party customers. The only substance regulated under the Risk Management Program (RMP) that is present at the Tippett Gas Plant in amounts greater than threshold quantity is de-ethanized natural gas liquids which is reported as a flammable mixture. The facility is classified as Program Level 3 under the regulation. The purpose of this Risk Management Plan (RMPlan) is to provide information about our operations at the facility, our programs to prevent accidental chemic al releases, our emergency response plans in case an accidental release should occur, our 5 year accident history, and our planned changes to improve safety at the facility. Worst Case and Alternative Release Scenarios As specified by the U. S. Environmental Protection Agency (EPA) RMP Regulations, our worst case release would be the loss of all of the flammable mixture in our largest vessel causing a vapor cloud explosion. In the case of the Tippett Gas Plant, this would involve a 71,480 gallon bullet. Such a scenario is highly unlikely, however, using the EPA Offsite Consequence Analysis (OCA) methods, the distance that the resulting vapor cloud explosion could cause an overpressure of 1 psi would be approximately 0.6 miles (approximately 3,200 feet). An overpressure of 1 psi is EPA's threshold for measurable impacts. The alternative release scenario, characterized as a more likely scenario that would involve offsite damage, is calculated to reach approximately 0.30 miles (a pproximately 1,500 feet) from the release point. This distance calculation is also based on the EPA OCA methods, which are known to overpredict the impacts of any potential release from such a scenario. We selected the alternative release scenario based on a release of ethane vapors due to a temporary termination of product (natural gas liquids) delivery to the pipeline. Although no credit for any controls or mitigation measures was taken into account when evaluating this scenario, we have mitigation measures that would greatly reduce the chance that such an event could ever occur. The most important of these mitigation measures would involve heating up the plant, thereby keeping ethane in a gaseous state rather than storing it as a liquid. This would prevent the vapor pressure in the storage vessel from rising. The presence of this mitigation measure serves to prevent this scenario from occurring. We have discussed these potential releases with our employees and with local eme rgency response officials in Upton County, thereby further reducing the possibility of any impact on the public. Prevention Program The Tippett Gas Plant has been operating under the strict guidelines of the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) Program since Koch acquired it in 1997. Our ongoing analysis of the potential hazards of our process, detailed training of our employees, and constant emphasis on safety have helped us avoid any serious accidents over the last 5 years. Part of this program has also involved identifying and taking steps to avoid potential accidental chemical releases. A few examples of the additional prevention features implemented at this facility include: 7 We have installed "fire eyes", that sense UV waves, in the engine room to automatically shut down the compressors in case of fire. 7 We have installed pumps with dual seals and an alarm for primary seal failure. 7 We have installed a continuous natur al gas flare. 7 We have monitors connected to our fire water pump that will spray water onto equipment. 7 We have emergency shutdown valves for removing the product from the system during emergency situations along with automatic pump shutdown. 7 We provide safety orientation to all our employees to enhance personal safety. These safeguards as well as the vigilance of our trained employees have helped us operate safely at this facility since Koch acquired it in 1997. Five Year Accident History No incident having resulted in offsite or onsite impacts from a RMP regulated substance has occurred at the Tippett Gas Plant within the last five years. Although we take pride in that record, we also place daily emphasis on our prevention and safety programs to ensure this record continues. Emergency Response We will continue to conduct emergency response preparedness activities and coordinate any emergency response actions necessary for the Tippett Gas Plant with the McCamey Volunteer Fire Department and the Upton County Sheriff. The Tippett Gas Plant Foreman is responsible for coordinating all emergency actions. A specific Emergency Response Plan for the facility is in place and that plan has been coordinated with local officials, along with evacuation procedures, regular drills, and training. Our Emergency Response Program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Planned Changes to Improve Safety Diligent compliance with our RMP Prevention Program forms the framework on which we will continue to improve the level of safety at the Tippett Gas Plant. Some of the key components of the safety improvements we expect to achieve are as follows: 7 The Management of Change provisions ensure that we consider the potential safety and health impacts of any change we make to process chemicals, technology, equipment or procedures. 7 The Process Ha zard Analysis (PHA) provisions serve as a tool to ensure continual evaluation of potential hazards, thereby leading to continual improvements in our safety standards. 7 The Mechanical Integrity provisions ensure that process equipment and instrumentation are designed, constructed, installed and maintained to minimize the risk of hazardous releases, thereby serving as an integral part of our safety program. 7 Internal and third party compliance audits will ensure we maintain and increase our level of safety protection. 7 An ongoing dialogue with the Upton County Emergency Management Director or his designate will ensure a constant state of readiness to respond to any potential emergencies, as well as a means to implement improvements as the need develops. In this way, we shall bolster our strong commitment to the safety of our workers and the community. We encourage all interested citizens or community organizations to contact the Upton County Emergency Management Director for the lat est information on emergency response for the county. We plan to diligently integrate our response capabilities and personnel with those of the county on an ongoing basis. |