Milfay Gas Processing Plant - Executive Summary

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Milfay Gas Plant 
Executive Summary 
The Milfay Gas Plant 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 Milfay Gas Plant, located in Milfay, Oklahoma, near Stroud, Oklahoma, uses cryogenic fractionation to separate ethane and heavier hydrocarbons from raw wellhead gas to produce marketable natural gas.  As a result of this operation, several EPA regulated flammable substances are processed, recovered, a 
nd stored at the facility (e.g., methane, ethane, propane, iso-butane, n-butane, iso-pentane and n-pentane).  The Milfay plant does not use or store any regulated toxic substances above the EPA set threshold levels. 
There is no worst-case scenario (WCS) associated with toxic substances in the Program Level 3 process at the gas plant.  The plant does not use or store any regulated toxic substances at or above the EPA set threshold levels.  
The worst-case scenario (WCS) associated with a release of flammable substances in the Program Level 3 process at the gas plant is a vapor cloud explosion (VCE) resulting from a release of 197,392 pounds (100% of tank capacity) of liquid butane from the plant's largest storage vessel, the B-G Storage Tank (V-1001).  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 was taken into account in  
evaluating this WCS.  The maximum distance to the 1-psi endpoint for this WCS is 0.5 miles.  
The selected alternative release scenario (ARS) for flammable substances at the gas plant is a vapor cloud explosion resulting from the release of 12,501 pounds per hour of processed natural gas (outlet gas) due to a failure of the Koch High Pressure Outlet Line.  The maximum distance to the 1-psi endpoint for this ARS is 0.2 miles.  This event was selected as being a practical scenario for use in emergency planning and response.   
The following is a summary of the accidental release 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 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 describe 
s the management system in place to implement the accident prevention program. 
Employee Participation 
The Milfay 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 process safety information to participation as a member of a process hazard analysis (PHA) team.  Employees have access to all information created as part of the gas plant's PSM and accident prevention programs.  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 element of the accident prevention program.  In addition, the gas plant has a number of initiatives under way that address process safety and employee safety issues.  These initiatives include plant safety meetings and safety training to promote both process and personal safety.   
Process Safety Inform 
The Milfay 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 information.  The Safety Department, in conjunction with plant personnel, is assigned the responsibility for maintaining up-to-date process safety information.  A PSM and EHS Files list has been prepared to help employees readily locate any necessary process safety information. 
Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDS).  This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals.  For specific process areas, the gas plant has documented safety-relat 
ed limits for specific process parameters (e.g., temperature, level, pressure) in the plant's Operating Procedures.  The gas plant ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems). 
The gas plant also maintains numerous technical documents that provide information about the design and construction of process equipment.  This information includes material of construction, design pressure and temperature ratings, and electrical rating of equipment.  This information, in combination with 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 Milfay Gas Plant has a comprehensive program to help ensure that hazards associated with the va 
rious 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 Milfay Gas Plant primarily uses the What-if/Check list analysis technique to perform these evaluations.  OSHA and the EPA recognize the What-if/Checklist analysis technique as an approved method for conducting PHAs.  Plant PHAs are conducted using a team of people who have operating and maintenance experience as well as engineering and safety expertise.  The 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 forwarded to the company's corporate Safety Department for resolution.  Implementation of mitigation options in response to PHA findings is based on a relative r 
isk 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 these updates are documented and retained.  Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained. 
Operating Procedures 
The Milfay Gas Plant maintains written procedures that address var 
ious 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. 
In addition, Milfay Gas Plant's Operating Procedures provide guidance on how to respond to process equipment operating outside their upper or lower limits.  Operating Procedures are readily available to operators and other personnel to use as necessary to safely perform their job tasks. 
To complement the written procedures for process operations, the Milfay Gas Plant has implemented a comprehensive training program for all 
employees involved in operating a process.  New employees receive basic training in gas plant operations if they are not already familiar with such 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. 
The Milfay Gas Plant uses contractors to supplement its workforce during periods of increased maintenance or construction ac 
tivities.  Because some contractors work on or near 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) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to their beginning work.  In addition, the Milfay Gas Plant evaluates contractor safety programs to generate an approved contractor list.  Gas plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. 
Pre-startup Safety Reviews (PSSRs) 
The Milfay Gas Plant con 
ducts a PSSR for any new facility or facility modification that requires a change in the process safety 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. 
Mechanical Integrity 
The Milfay Gas Plant has 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 basi 
c aspects of this program include:  (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.  Equipment manufacturers' 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 d 
eficiency before placing the equipment back into service (if possible), or 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 Milfay Gas Plant incorporates quality assurance measures into equipment purchases and repair.  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 Milfay Gas Plant has long-standing safe work practices in place to help ensure worker and process safety.  Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous substances before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and 
(5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space.  These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. 
Management of Change 
The Milfay Gas Plant has a comprehensive system to manage changes to all covered processes.  This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes to 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 mai 
ntenance personnel are provided any necessary training on the change. 
Incident Investigation 
Duke Energy's Safety Department promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury.  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 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 f 
or 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, the Milfay Gas Plant periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented.  Compliance audits are conducted at least every 3 years.  Audit findings are forwarded to the company's Safety Department for resolution.  Both hourly and staff personnel participate in the audits. Corrective actions taken in response to the audit finding are tracked until they are complete.  The final resolution of each finding is documented and the two most recent audit reports are retained. 
The processes at the Milfay 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 accide 
ntal releases of regulated substances in the facility. 
Universal Prevention Activities 
The accidental release prevention program summarized previously is applied to all RMP-covered processes at the Milfay 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 Milfay 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 (mitigate) a release.  The following types of safety features are used in the covered processes: 
   Release Detection 
1. Routine operator inspection. 
2.  Fire detectors. 
   Release Containment/Control 
1. Process relief valves that prevent vessel over pressurization. 
2. Valves to permit isolation of the process (manual or automated). 
3. Automated shutdown systems for specific process parameters (e.g., high temperature). 
4. Curbin 
g or diking to contain liquid releases. 
5. Redundant equipment and instrumentation. 
   Release Mitigation 
1. Fire suppression and extinguishing systems. 
2. Trained emergency response personnel.  
3. Personal protective equipment (e.g., hard hat, safety glasses, protective clothing). 
The Milfay Gas plant has an excellent record of accident prevention over the past 5 years.  The plant has not experienced any reportable accidents in this timeframe.  Releases that did occur at the plant involving regulated substance were quickly contained and resulted in no deaths, injuries, significant property damage, environmental damage, evacuations, or sheltering in place.  We investigate every incident very carefully to determine ways to prevent similar incidents from recurring.  
The Milfay Gas 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 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 plan is updated when necessary based on modifications made to Milfay Gas Plant processes or other Duke Energy facilities.  Personnel are in 
formed of and trained in any changes to the emergency response plan. 
The overall emergency response plan for the Milfay Gas Plant is coordinated with the Sapulpa Office of Civil Defense, the agency serving as the Local Emergency Planning Commission (LEPC).  This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives.  The Milfay Gas Plant has effective communications capability with appropriate the Office of Civil Defense 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.  In addition to periodic Office of Civil Defense meetings, the Milfay Gas plant conducts periodic emergency drills, and the gas plant provides periodic refresher training to local emergency responders regarding the hazards of regulated substances in the gas  
The Milfay Gas Plant resolves all findings from PHAs, some of which result in modifications to the process.  Various types of changes are planned over the next few years in response to PHA, safety audit, and incident investigation findings.
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