Mount Pearl Unit Gas Injection Facility - Executive Summary

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Executive Summary 
A) Accidental Release Prevention and Response Policies 
The Mount Pearl Gas Injection Facility 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, our trained personnel will respond to control and contain the release.  We also work closely with our public emergency responders providing them with training and equipment so that they can respond safety and efficiently to emergencies that might occur at our facility. 
B) Description of the Stationary Source and Regulated Substances  
The Mount Pearl Gas Injection Facility; located 8 miles north, and 2.5 miles east of Kit Carson, Co.; incorporates a variety of processes to  
produce petroleum products (e.g., natural gas, propane, butane, condensate) from oil and gas wells.  The Mount Pearl Gas Injection Facility handles methane; ethane, propane and butane which are regulated flammables. It processes approximately 10 million cubic feet a day of raw natural gas and natural gas liquids.  The Mount Pearl Gas Injection Facility does not use, process or store a reportable quantity of toxic regulated substances. 
C) Hazard Assessment Results 
The Worst Case Scenario (WCS) associated with a release of flammable materials in processes at the gas plant is a vapor cloud explosion (VCE) involving the full inventory of the largest process vessel containing 169,828 pounds of a propane, ethane mix. The maximum distance to the 1-psi endpoint for this WCS is 0.450 miles.  No passive mitigation measures were taken into account in evaluating this WCS. 
E) Five-Year Accident History 
Within the past five years the processes have not had an accidental release that caused offsi 
te impacts provided in the risk management program rule (40 CFR 68.10(b)(1)). 
D) General Accidental Release Prevention Program/Chemical-Specific Prevention Steps 
The following is a summary of the accident prevention program in place at the Mount Pearl Gas Injection Facility.  Although processes at the Mount Pearl Gas Injection Facility are regulated by the EPA Risk Management Program (RMP) regulation, they are not subject to the OSHA Process Safety Management (PSM) standard. This summary addresses only general safety issues and describes the management system in place to implement the accident prevention program. 
  I) Safe Work Practices 
The Mount Pearl Gas Injection Facility has long-standing safe work practices in place to help ensure   worker and process safety. Examples of these include:   
  (1)  lockout/tagout procedure to ensure isolation of energy sources for equipment that is being worked on  
(2) a procedure for safe removal of hazardous materials before process piping o 
r equipment is opened  
(3) a permit and procedure to control spark-producing activities (i.e., hot work)   
(4) 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 operations and maintenance activities are performed safely. 
II) Incident Investigation 
The Mount Pearl Gas Injection Facility promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, 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 investigator documents his/her findings, develops recommendations to prevent a recurrence, and forwards these results to Southeast Colorado management for resolution.  Corrective actions taken in response to the investig 
ation team's findings and recommendations are tracked until they are completed.  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.  
III) Compliance Audits 
To help ensure that the accident prevention program is functioning properly, the Mount Pearl Gas Injection Facility periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented.  Compliance audits are conducted approximately every 3 years.  Personnel from other operating areas compose the Audit Team.  Both hourly and staff personnel participate as audit team members.  The audit team develops findings that are forwarded to Mount Pearl Gas Injection Facility management for resolution.  Corrective actions taken in response to the audit team's findings are traced until they are completed.  The final resolutio 
n of each finding is documented, and the two most recent audit reports are retained. 
IV) Summary of Process Hazards, Safety Features, and Hazard Analysis Findings 
The processes at the Mount Pearl Gas Injection Facility have hazards that must be managed to ensure continued safe operations. 
 a) Universal Prevention Activities 
 The accident prevention program summarized previously is applied to all EPA RMP covered processes at  the Mount Pearl Gas Injection Facility.  Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failures and (2) human errors. 
 b) Specialized Safety Features 
The Mount Pearl Gas Injection Facility 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: 
 c) Release Detection 
       1. Hydrocarbon detect 
ors with alarms in all closed compressor buildings 
 d) Release Containment/Control 
        1.Valves to permit isolation of the process (manual or automated) 
        2. Automated shutdown systems for specific process parameter (e.g., high level, high temperature,   high pressure) 
        3. Curbing or diking to contain liquid releases 
        4. Atmospheric relief devices 
   e) Release Mitigation 
         1. Personal protective equipment 
         2. Trained emergency first-responder personnel 
         3.  Spacing of equipment in accordance with IRI spacing guideline 
         4. Emergency shutdown strategically placed in the plant to automatically shut in the inlet.  
Emergency Response Program 
The Southeast Colorado Area maintains a written emergency response program, which is in place 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, 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 procedures. The emergency response program is updated as necessary.  Any significant changes to the emergency response program are identified and affected personnel are informed of the changes. 
The overall emergency response program for the Mount Pearl Gas Injection Facility is coordinated with the Kit Carson Fire Department and the local emergency planning committee (LEPC).  This coordination includes periodic meetings with the LEPC, which includes local emergency response officials, local government officials, and industry representatives.  The gas plant has around-the-clock communications capability wi 
th appropriate LEPC 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. The Mount Pearl Gas Injection Facility provides training and equipment to local emergency responders so that they are familiar with any unique hazards that they may encounter when responding to emergencies at our facilities.  
Planned Changes to Improve Safety 
Although Mount Pearl Gas Injection Facility management does not believe additional safety measures are necessary to prevent offsite impacts from accident releases, it does resolve all findings from the Safety and Environmental Compliance Audits.  
Based on the criteria in 40 CFR 68.10, the distance to the specified endpoint for the worst-case accidental release scenario for the following process is less than the distance to the nearest public receptor.  Within the past five years, the proc 
ess has not had any accidental release that caused offsite impacts provided in the risk management program rule (40 CFR 68.10(b)(1)).  No additional measures are necessary to prevent offsite impacts from accidental releases.  In the event of fire, explosion, or a release of a regulated substance from the process, entry within the distance to the specified endpoints may pose a danger to public emergency responders.  Therefore, public emergency responders should not enter this area except as arranged with the emergency contact indicated in the RMP.   
The undersigned certifies that to the best of my knowledge, information and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. 
Herschel Kennedy                                                                                             Date 
Senior Production Foreman
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