Ragley Processing Plant - Executive Summary |
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HSR Ragley Gas Plant - RMP Plan Executive Summary EXECUTIVE SUMMARY This executive summary is a brief overview of the Risk Management Program and the associated policies at the HSR (HSR) Ragely 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 HSR RMP manual for the gas processing and storage systems. HSR 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, HSR 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. HSR management understands its duty to provide a safe working environment and to take measures to prev ent accidents that may have an effect on the surrounding community. This understanding is reflected in procedures described and referenced in the RMP manual. Stationary Source and Regulated Substances. HSR is a natural gas liquids extraction facility designed to process 10 mmscfd of natural gas. The purpose of the HSR NGL Ragely Gas Plant is to reduce the Btu of the gas to a level that is acceptable for pipeline transmission. Control of the Btu is critical since the incoming gas is liquid-saturated. In order to reduce the Btu of the gas, the inlet gas is dehydrated and then chilled using a gas refrigeration system. This process allows the heavy hydrocarbons to condense out of the process flow. The low the plant temperature, the greater the volume of natural gas liquids (NGLs) produced. The condensed NGLs are then stored in an 18,000 gallon pressurized tank for eventual sale. The residual gas leaves the plant and is then delivered to the transmission pipeline. Release Scenari os - The RMP regulated substance handled at this facility is a flammable mixture Worst-case and alternative release scenarios 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 18,000-gallon of the product storage tank or 59,000 pounds ) 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 0.3 miles to the flammable endpoint was determined for a release of 59,000 pounds in ten minutes. The alternative release scenario was developed based on discussions at the process hazard analysis and consists of a release of 127 pounds of product from the product hose over a two-minute period due to a product truck dri ving off without unhooking the product hose. 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 0.04 miles to the flammable endpoint was determined. Prevention Program The prevention program and chemical-specific prevention steps includes the Program 2 elements: 7 The safety information including operating procedures are complied in the operators manual 7 Conducted the hazard review including reiw of process hazards, chemical hazards, potential for equipment malfunction or human error that could lead to a release, engineering and administrative controls to minimize hazards. Operating procedures and conditions are found in the operators manual. 7 Training certification for all plant personnel involved in the operation and maintenance of the plant operations. Continued training to ensure the effectiveness of the training program will be conducted. 7 Ma intenance program to ensure that the system equipment is maintained in good and safe working condition, daily maintenance is checked and recorded on the plant daily log. 7 Compliance audits to be conducted at least once every three years to ensure the continued compliance of the HSR RMP program. The compliance audit will be conducted before June 21, 2002 7 Incident investigations will be conducted whenever to examine the underlying cause of catastrophic release or near misses that could result in a catastrophic release. The plant has not conducted any incident investigations since operations began in the fall of 1998. Emergency Response Program This facility is covered by 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 person nel and regulatory changes. Planned Changes for Improved Safety Ideas for changes to improve safety are actively sought from employees. Employee safety meetings that focus on chemical 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 HSR RMP program, process hazard analyses were 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. |