Fort Lupton Gas Processing Plant - Executive Summary |
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NARCO Natural Gas Liquids Extraction Facility - RMP Plan Executive Summary EXECUTIVE SUMMARY This executive summary is a brief overview of the Risk Management Program and the associated policies at the North American Resources Corporation (NARCO) Fort Lupton Gas Plant. Prevention and Response Policies The accidental release prevention and emergency response policies are represented in the Emergency Planning and Response Sections of the NARCO PSM/RMP manual for the plant systems. NARCO takes an active role in preventing accidental releases at all of its facilities by ensuring that its employees are properly trained in the safe operation of covered processes and the safe handling of regulated chemicals. As for emergency response, NARCO has established and maintained procedures for emergency notification and response. These are reviewed with employees on a periodic basis and revised to accommodate changes in staffing when they occur. NARCO management understands its duty to provide a safe working environment and to take measures to prevent accidents that may have an effect on the surrounding community. This understanding is reflected in procedures described and referenced in the PSM/RMP manual. Stationary Source and Regulated Substances. NARCO is a natural gas liquid recovery facility designed to process 65 mmscfd of natural gas. The purpose of the NARCO Ft. Lupton Gas Plant is to recovery natural gas liquid products from the incoming gas. The gas is then sold on a BTU basis to three outlet pipelines. The liquid is further processed to remove carbon dioxide and water. The NGL can then be taken out of the plant by liquid pipeline or fractionated into its separate components to be sold into trucks as a propane, butane, and/or gasoline product. Release Scenarios - The PSM/RMP-regulated substance handled at this facility is a flammable mixture comprised of ethane, propane, isobutane, butane, isopentane, and pentane. Worst-case and alternative release scenari os have been determined after careful review of the regulation and consideration of the storage vessel configuration at the facility. For worst-case release scenario, the regulation is clear. The assumption is that the single largest container of a regulated substance (the 42,000-gallon butane storage tank or 162,140 pounds of butane) is released over a ten-minute period. No active mitigation may be considered. RMP Comp was used to determine the distance to overpressure of 1.0 psi for a vapor cloud explosion of hydrocarbon product. A distance of 0.4 miles to the flammable endpoint was determined for a release of 162,140 pounds in ten minutes. The alternative release scenario was developed based on discussions at the process hazard analysis and consists of a release of 2,077 pounds of propane from the propane product hose over a two-minute period due to a propane product truck driving off without unhooking the product hose. No active mitigation devices were considered to influence the release scenario. The RMP Comp model was used to determine the volume of LPG that would be released in 2 minutes and was used to calculate the distance to overpressure of 1.0 psi. A distance of 0.06 miles to the flammable endpoint was determined. Prevention Program The prevention program and chemical-specific prevention steps are described in detail in the NARCO PSM/RMP manual. The prevention program includes the Program 3 elements: 7 Employee participation, which includes provisions for active participation by plant employees in the development and implementation of the facility PSM/RMP program, as well as ready access to program information 7 Process safety information, which has been collected in the Plant Engineer's office, control room and is summarized in the PSM/RMP manual 7 Operating procedures for the facility operations, which are included in the Control Room 7 Training for all plant personnel involved in the operation and maintenance of the plant operations 7 Contractor management program, which includes provisions for the evaluation and selection of contractors to work on the regulated process, exchange of hazard information, system access control, and oversight during work activities on site 7 Pre-startup safety review procedure for implementation for significant system changes to ensure that the construction and equipment installation is according to design specifications, appropriate procedures are in place and accurate, a PHA has been done when required and the recommendations resolved, and employees are trained prior to startup of the modified system 7 Mechanical integrity program to ensure that the system equipment is maintained in good and safe working condition 7 Hot work procedures to require controls as specified in the Gas Standards Manual before hot work is performed within the plant premises 7 Management of change program to ensure that proposed system changes are comprehensively evaluated before implementing the change 7 Incident investigation procedures for the investigation of any catastrophic (or potentially catastrophic) incident associated with the covered processes 7 Compliance audits are to be conducted at least once every three years to ensure the continued compliance of the NARCO RMP program. 7 Process hazard analysis (PHA) is a systematic approach to identifying and determining the level of hazards of covered plant systems. Recommendations are made and a follow-up system is in place to ensure follow-up occurs. NARCO chose the Hazop method of was selected for the Ft. Lupton Gas Plant. Emergency Response Program This facility has established and maintains an emergency response program that is coordinated with local response agencies. The goals of the program are to protect onsite employees from the hazardous effects of chemical releases and to minimize the effects of releases on the general public. The program is routinely reviewed and updated to reflect personnel and regulatory change s. The plant has scheduled is planning emergency response training refresher for July of 1999. Planned Changes for Improved Safety Ideas for changes to improve safety are actively sought from employees. Employee safety meetings that focus on process safety issues are held regularly at this facility. Employees are encouraged and trained to recognize hazards and present ideas to eliminate them or to minimize the potential consequences of those hazards. During the development of the NARCO PSM/RMP program, process hazard analyses are conducted with key employees to meet the prevention program requirements. During these sessions, recommendations were made for the purpose of improving safety and preventing accidental chemical releases. Each recommendation has been or will be considered for implementation. Though not all recommendations may be implemented, all will be considered. The exercise has provided all affected employees with a heightened awareness of safety issues related to the covered processes. |