MarkWest Hydrocarbon, Inc. - Kenova Facility - Executive Summary |
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Risk Management Plan Executive Summary MarkWest Hydrocarbon, Inc. - Kenova, West Virginia Facility 1. Accidental Release Prevention and Emergency Response Policies The MarkWest Hydrocarbon, Inc. - Kenova, West Virginia (MarkWest) facility is strongly committed to employee, public, and environmental safety. This commitment is inherent to a comprehensive accidental release prevention program. The program in place at the Kenova facility encompasses such areas as design, installation, operating procedures, maintenance, and employee training associated with the processes at the facility. It is the policy of MarkWest to implement appropriate controls to prevent the possible release of regulated substances. Unforeseeably, if such a release does occur, MarkWest is completely coordinated with the Cabell/Wayne County Local Emergency Planning Committee which provides emergency response personnel to control and mitigate the effects of the release. 2. The Stationary Source and the Regulate d Substance Handled The primary function of the MarkWest facility encompasses natural gas liquid (Y-Grade) extraction. Y-Grade is the one substance present at the facility regulated by Risk Management Plan (RMP) regulations. This flammable substance is a mixture comprised of propane, normal butane, isobutane, and natural gasoline (pentanes and hexanes). The Y-Grade is extracted from a natural gas transmission pipeline. Once extracted, the Y-Grade is stored in a 42,000-gallon capacity pressure vessel (D-5). The Y-grade is then transferred via pipline to a fractionation facility. The total quantity of product stored in the 42,000-gallon capacity vessel D-5 is administratively controlled to ensure that the vessels are not filled above 90% of full capacity. Additionally, pressure relief devices provide added assurance that the vessels are not over-filled to pressures above 250 pounds per square inch (psi). These controls are in place to prevent the potential for over-pressurizat ion which could cause structural damage to the vessels and lead to a release. Based on the administrative controls described above, the maximum inventory present in D-5 and at the facility would be equal to 90% of the total 42,000-gallon capacity: 37,800 gallons (the equivalent of 171,519 pounds) of Y-Grade. 3. The Worst Case Release Scenario and Alternative Release Scenario The parameters of the offsite consequence analyses for this MarkWest facility were based on the requirements set forth in the RMP rules outlined in 40 CFR 68.25 (e), Worst-case release scenario-flammables and 40 CFR 68.28, Alternative release scenario analysis. The worst case and alternative case radii of effect were determined utilizing RMP*Comp software provided by the EPA. The following describes details of the chosen scenarios. The worst case scenario for Program 3 flammable substances as a class involves a catastrophic release from vessel D-5. The scenario involves the release of the entire quantity o f the vessel, approximately 37,800 gallons (171,519 lbs) of propane. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions (wind speed of 3.4 miles per hour), the maximum distance of 0.4 miles is obtained corresponding to an endpoint of 1 pound per square inch (psi) overpressure. Utilizing Landview III and Marplot software, the worst case scenario radius of 0.4 miles is illustrated in the graphic file kenovawc.jpg (electronic version) and in the attached map (provided in non-electronic versions only). Two major industrial facilities, Columbia Gas Transmission and Marthon-Ashland, are located within this radius. Based on Landview III 1990 census data utilizing the block group proration method, 41 households and 121 people are located within the 0.4 mile radius. The alternative release scenario submitted for Program 3 flam mable substances involves a release of Y-Grade from vessel D-5. The scenario involves the release of 20 percent of the entire quantity of the vessel, approximately 7,560 gallons (34,304 lbs) of Y-Grade. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in the vapor cloud explosion. Utilizing this data, the maximum distance of 0.3 miles is obtained corresponding to an endpoint of 1 psi overpressure. The alternative case scenario radius of 0.3 miles is illustrated in the attached map (provided in non-electronic versions only). Two major industrial facilities, Columbia Gas Transmission and Marathon-Ashland Refinery are located within this radius. Based on Landview III 1990 census data utilizing the block group proration method, 23 households and 63 people are located within the 0.3 mile radius. 4. The General Accident Release Prevention Program and the Chemical-Specific Prevention Steps MarkWest has taken all the necessary steps to comply with accidental release prevention requirements set forth under 40 CFR Part 68 of the RMP regulations. The natural gas liquid extraction and storage process at MarkWest is also subject to the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) standard under 29 CFR 1910.119. The following briefly describes the elements of the release prevention program in place at the MarkWest Kenova facility. Process Safety Information MarkWest maintains a detailed record of written safety information that describes the chemical hazards, operating parameters, and equipment designs associated with all processes. Process Hazard Analysis MarkWest conducts comprehensive studies to ensure that the hazards associated with the processes at the facility are identified and controlled efficiently. The HAZOP methodology is used to carry out these analyses. The studies are undertaken by a team of qualified person nel in engineering and process operations and are revalidated at regular intervals. Any findings related to the hazard analyses are addressed in a timely manner. Operating Procedures For the purpose of safely conducting activities within covered processes, MarkWest maintains written operating procedures. These procedures address various modes of operation such as initial start up, normal operations, temporary operations, emergency shutdown, normal shutdown, and startup after turn around. The information is regularly reviewed and is readily accessible to operators involved with the process. Training MarkWest has a comprehensive training program in place to ensure that the employees operating processes are completely competent in the operating procedures associated with the processes. New employees receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently. Refresher training is provided as needed. Mecha nical Integrity The integrity of mechanical operations at MarkWest is ensured through documented maintenance checks on process equipment. Process equipment examined by these checks include among others: pressurized storage vessels, piping systems, relief and vent systems, emergency shutdown systems, controls, and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at MarkWest to manage changes in process chemicals, technology, equipment, and procedures. Process operators, maintenance personnel, or any other employees whose job tasks are affected by a modification in process conditions are promptly made aware of and are trained on the specifics of the modification. Pre-Startup Reviews Pre-startup safety reviews related to new processes and to modifications in established processes are conducted as required. These reviews are conducted to confirm that construction, equipment, operating, and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits MarkWest conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out every three years as required by the RMP regulations (40 CFR 68.58) and any corrections required as a result of the audits are undertaken in a safe and timely manner. Incident Investigation MarkWest investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident, as well as any corrective actions needed to prevent the release from reoccurring. All reports are retained for a period of five years. Employee Participation MarkWest believes that successful RMP, PSM, and accident prevention programs require a team effort. Company employees are encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, MarkWest employees have access to all information created as part of the facility's implementation of the RMP program, in particular, information relating to and resulting from process hazard analyses. Contractors Periodically, MarkWest hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of the safety performance of the contractor is undertaken. MarkWest has a strict policy of informing contractors of known potential hazards relating to the contractor's work and the associated processes. Contractors are also informed of all procedures for emergency response should an accidental release of a regul ated substance occur. 5. Five Year Accident History MarkWest has had an excellent record of preventing accidental releases over the last five years. Due to stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Action Plan A written emergency action plan to deal with accidental releases of regulated substances is retained at the MarkWest facility. The plan includes all aspects of emergency response including medical treatment, evacuations, and notification of local emergency response agencies and the public. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within processes that would require a modified emergency response. MarkWest has fully coordinated this RMP and our emergency response plan with the Cabell/Wayne County local emergency planning committee (LEPC). 7. Planned Changes to I mprove Safety MarkWest will continue to monitor the implementation of the RMP program at the Kenova facility to ensure that an accidental release of Y-Grade does not occur. To date, no operational changes have been identified or deemed necessary to improve safety at the facility. 8. Conclusion MarkWest Hydrocarbon, Inc. has taken all necessary measures as required by EPA and OSHA regulations to ensure the continued safe operation of the MarkWest - Kenova facility. The Risk Management Plan provided herein summarizes the active release prevention program that is currently in place at the facility. This risk management program illustrates MarkWest's commitment to employee, public, and environmental safety. In the unforeseeable event that a release does occur, MarkWest's emergency action plan combined with the assistance of the Cabell/Wayne County LEPC provide assurance that such an event will be successfully and safely mitigated. Page 1 Page 1 |