Aurelius Gas Plant - Executive Summary

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EXECUTIVE SUMMARY 
Risk Management Plan 
Aurelius Gas Plant 
Ingham County, Michigan 
 
 
I    Accidental Release Prevention and Response Policies 
 
Aurelius Gas Plant (AGP) 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 safety in the operation and maintenance of the plant.  The company's policy is to implement reasonable measures to prevent foreseeable releases of regulated substances.  However, if a release does occur, trained gas plant personnel will respond to effectively control, contain and mitigate the release. 
 
II.    Description of the Stationary Source and Regulated Substances 
 
AGP operates a process to remove liquids from natural gas.  The plant has regulated flammables, such as butane and propane.  The plant does not have any regulated toxic substances. 
 
III.    Offsite Consequence Analysis Results 
 
The worst case scenario (WCS) associated with a release of flamma 
ble substances at AGP is a vapor cloud explosion (VCE) involving the full inventory of the largest storage tank containing natural gas liquid (NGL).  The tanks have a capacity of 40,000 or approximately 185,000 lbs. of butane and 30,000 gal., or approximately 125,000 lbs. of propane.  The inventory of a single tank is assumed to release and ignite, resulting in a VCE.  The maximum distance to the 1-psi endpoint for this WCS is 0.5 miles for butane and 0.4 miles for propane.  No credit for passive mitigation measures was taken into account in evaluating this WCS. 
 
The alternate release scenario (ARS) for flammable substance at AGP is a VCE from the release of butane or propane resulting from a line failure during truck loading.  For the release is was assumed that either 20 lbs. of butane or propane are released.  The maximum distance to the endpoint for this event is less than 0.1 mile based on Lower Flammability Limit for a vapor cloud fire.  This event was selected as a practical sce 
nario for use in emergency planning and response. 
 
IV. General Accident Release Prevention Program and Chemical Specific Prevention Steps 
 
The accident prevention program in place at AGP includes the following: 
 
(1) Employee Participation in development, review and implementation aspects of process safety management and accident prevention. 
 
(2) Process Safety Information documents that are used to ensure safe operation of the processes. 
 
(3) Process Hazard Analysis (PHA) to ensure that hazards associated with the processes at the plant are identified and controlled. 
 
(4) Operating Procedures and manuals that address various modes of process operations, such as unit startup, normal operations, normal shutdown, temporary operation, emergency operations, emergency shutdown, and initial startup of a new process.  Mechanical devises to limit accidental and specific chemical releases include relief valves, check valves, flares, manual shut-offs, automatic shut-offs, interlocks, grounding eq 
uipment and excess flow devises. 
 
(5) Comprehensive and effective training program for all employees involved in operating a process. 
 
V. Five-year Accident History 
 
During the past five years there have been no accidents and in fact none have occurred since the plant was constructed in 1972. 
 
VI. Emergency Response Program Information 
 
AGP has developed and implemented a written emergency response program to protect worker and public safety as well as the environment.  The program consists of procedures for responding to a release of a regulated substance potentially resulting from a fire or explosion, severe weather, environmental spill, and pipe failure.  The procedures address emergency response, including proper first aid and medical treatment, evacuation plans, notification of local emergency response agencies and the public.  The emergency response program is updated when necessary based on factors such as modification made to the plant process or operating procedures. 
 
VII. Pla 
nned Changes to Improve Safety 
 
The possible modification of the AGP from a lean oil facility to a JT facility which would result in less piping and process equipment and reduced levels of NGL's produced. The Company will continue to upgrade our process control systems and maintain our training program to enhance safety.
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