Longview Gas Plant - Executive Summary |
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KOCH MIDSTREAM SERVICES COMPANY Longview Gas Plant Longview, 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 commitments 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 law. The Longview Gas Plant is one of many facilities operated by Koch Midstream Services Company (Koch). At the facility, we receive wellhead gas from wells via pipeline. We separate the liquid hydrocarbons out by employing the cryogenic/turbo-expander/demethanizer process. The demethanized residue gas is either sold to customers as low pressure gas or recompressed employing two turbine compressors for sale to customers as high pressure gas. The liquid hydrocarbons (Natural Gas Liquids) separated in the cryogenic/turbo-expander/demethanized process are fed into a 200,000-gallon per day capacity fractionation process. In the fractionation process, the natural gas liquid (NGL) is fractionated into E-P Mix (mixture of ethane and propane) and the residue hydrocarbon liquid containing butane and heavier h ydrocarbons. The residue hydrocarbon liquid (Butane+) is stored in two 30,000 - gallon storage tanks prior to distribution by pipeline to the customers. The E-P Mix is further treated in an amine system and a triethylene glycol system to remove carbon dioxide and water respectively prior to distribution by pipeline to the customers. Two flammable mixtures are reported as present at the facility in greater than threshold quantities. They are Butane+ (Butane and heavier hydrocarbons) and Natural Gas Liquids (or demethanized raw feed). There are no toxic substances present at the plant. 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 chemical 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. W orst Case and Alternative Release Scenarios As specified by the U. S. Environmental Protection Agency (EPA) RMP Regulations, our worst case release scenario for flammables would be the loss of all of the butane in our largest vessel causing a vapor cloud explosion. In the case of the Longview Gas Plant, this would involve our 30,000-gallon butane tank. 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 0.4 miles (approximately 2,100 feet). An overpressure of 1 psi is EPA's threshold for measurable impacts. Although we have numerous controls to prevent such releases (high level alarms, emergency shutdown, etc.) and to manage their consequences, no credit for any controls or mitigation measures was taken into account when evaluating this scenario. The alternative release scenario characterized as a more likely scenario that would involve offsite consequences is calculated to reach approximately 0.3 miles (approximately 1,600 feet) from the release point. This distance calculation is also based on the EPA OCA methods, which are known to be highly conservative and should overpredict any potential release from such a scenario. We have selected the alternative release scenario based on a release from our butane bullet due to a failure of the 4" relief valve on the vessel. We have several mitigation measures in place to greatly reduce the chance that such an event could ever occur. These measures include the following: 1) We carryout annual testing and repair of all the relief valves; 2) We keep the operating pressure of the bullet (35 psig) at well below the set pressure of the relief valve (250 psig); 3) We continuously monitor the liquid level in the bullet from our control room; 4) We provided a sight glass on the bullet for visual observation of the liquid level; and 5) We provided an autom atic emergency shutdown switch to shutdown all product movement in case the liquid level in the bullet gets too high. The presence of these mitigation measures serves to either prevent this scenario from occurring or minimize its impact if it does occur. We have discussed these potential hydrocarbon releases with our employees and with local emergency response officials in Gregg County, thereby further reducing the possibility of any impact on the public. Prevention Program The Longview Gas Plant has been operating under the strict guidelines of the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) Program since 1992. 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 provided manual emergency shutdown (ESD) buttons at several locations within the facility in order to shutdown the entire facility during emergency situations. The ESD system will also isolate the facility from the incoming feed pipeline and outgoing product pipelines. 7 We installed Lower Explosive Limit monitors in the turbine cubicles in order to detect flammable hydrocarbon vapors. 7 We provided dual seals on the plant feed pumps with an alarm in the control room to detect any leakage from the primary seal. We also provided dual seals on the hot oil pumps. 7 We provided high pressure and low-pressure shutdown switches on our E-P Mix and butane product pipelines. 7 We provided fire extinguishers throughout the facility for extinguishing incipient fires. These safeguards as well as the vigilance of our trained employees have helped us operate safely at this facility since we acquired it in 1997. Five Year Accident History No incident resulting in onsite or offsite impacts from a hydrocarbon release has occurred at the Longview 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 Program We will continue to conduct emergency response preparedness activities and coordinate any emergency response actions necessary for the Longview Gas Plant with the Elderville Volunteer Fire Department. Also involved in emergency response for the facility would be the Longview Volunteer Fire Department, the Lakeport Police Department, the Gregg County Sheriff, the Good Shepherd Hospital, and the Texas Department of Public Safety. The Longview Gas Plant Manager 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 offic ials, along with evacuation procedures, regular drilling, 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 Longview Gas Plant. Some of the key components of the safety improvements we expect to achieve are as follows: 7 The Management of Change provisions ensures that we consider the potential safety and health impacts of any change we make to process chemicals, technology, equipment or procedures. 7 The Process Hazard 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 des igned, 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 Gregg County LEPC Chairman 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 Gregg County LEPC Chairman for the latest 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. |