Hutchinson Fractionation Facility - Executive Summary
KOCH HYDROCARBON COMPANY |
THE RISK MANAGEMENT PLAN (RMPlan)
Introduction and Policies
Under the Koch Environmental Excellence Program (KEEP) at Koch Industries, Inc., we are committed to being associated with unmatched environmental performance as measured by our employees, customers, regulators, and the public. Our KEEP management philosophy goals are achieved by the personal commitments of our employees and contractors, and by open communication with our employees, customers, neighbors, and with regulators. The accidental release prevention and emergency response programs we have at our facilities are part of the high standards we strive for through KEEP. Our high standards are achieved by operating in compliance with all required environmental permits and regulations, by operating and maintaining our assets in such a manner that any unpermitted release will be unintentional and acknowledged as unacceptable, by reme
dying any shortcomings found during regular audits of our facilities, and by reporting promptly to regulators any shortcomings found during the course of our audits as required by law.
The Hutchinson Facility is one of seven facilities operated by Koch Industries, Inc. (KOCH). At the facility we receive liquid residue from natural gas facilities as feed stock totaling up to 58,000 barrels per day (bpd). The liquid feed to the facility is split into five product streams in a series of fractionator columns: E-P Mix, Propane, Isobutane, Normal Butane, and Natural Gasoline. These five product streams are further purified to remove contaminants such as water, carbon monoxide, and mercaptans. The purity products are stored in tanks or caverns and are distributed to various customers via pipeline. The facility is also equipped with five truck loading docks, which allow purity products to be loaded or unloaded. The facility is classified as Program Level 3 under the regulation. The pu
rpose of this Risk Management Plan (RMPlan) is to provide information about our fractionation process at the facility, our programs to prevent accidents, our emergency response plans in case an accident would occur, our 5 year accident history and our planned changes to improve safety at the facility. At the facility, we have no toxic chemicals above the threshold quantity. However, we store or process the following flammable substances listed in the RMP regulations: Ethane, Propane, and Butane.
Worst Case and Alternative Release Scenarios
As specified by the U. S. Environmental Protection Agency (EPA) regulations, our worst case release scenario would be the loss of all of the propane in our largest vessel causing a vapor cloud explosion. Such a scenario is highly unlikely, however, using the EPA Offsite Consequence Analysis (OCA) methods, the distance that the resulting vapor cloud explosion could cause an overpressure of 1 psi would be approximately 0.6 miles (approximately 3
,200 feet). An overpressure of 1 psi is EPA's threshold for measurable impacts. The alternative release scenario characterized as a more likely scenario, is calculated to reach approximately 0.4 (approximately 1,600 feet) from the release point. This distance calculation is also based on the EPA OCA methods, which are known to overpredict the impact of any potential release from such a scenario. We selected the alternative release scenario based on an incident involving the loss of a stringer in a cavern resulting in product being released into the brine pond. We have several active mitigation measures in place to prevent the occurrence of this incident. These active mitigation measures include the following: 1) if this incident were to occur the total release should be directed to the flare; 2) gas detection and flare alarms are on site to facilitate immediate corrective action by operating personnel. The presence of these active mitigation measures serves to either prevent
this scenario from occurring or minimizing it's impact if it does occur.
We have discussed these potential releases with our employees and with local emergency response officials in Reno County, thereby further reducing the possibility of any impact on the public.
The Hutchinson Facility has been operating under the strict guidelines of the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) Program since 1993. Our ongoing analysis of the potential hazards of our process, detailed training of our employees, and constant emphasis on safety has helped us minimize serious accidents over the last 5 years. Part of this program has also involved identifying and avoiding potential safety problems. A few examples of the additional safety features implemented at this facility include:
7 Installed gas detectors throughout process and on brine ponds.
7 Installed a continuous flare tied into each tower and storage cavern and other cr
7 Installed continuous monitoring and control systems.
7 Installed surveillance cameras to check for releases.
7 Provided uninterrupted power supply to the facility.
7 Provided siren system for evacuation of the facility during emergencies.
These safeguards as well as the vigilance of our trained employees have helped us operate safely at this facility since our acquisition in 1993. In addition, installation of an automated emergency shutdown system is planned for all the wells.
Five Year Accident History
Only one incident has occurred at the Hutchinson Facility, which qualifies as an RMP accident. This incident took place on June 24, 1997 at one of the truck loading docks and resulted in a release of approximately 200 pounds of propane vapor along with a head injury to one of the employees. The release was stopped by plant personnel within one minute, and did not result in any fire or explosion. Upon investigation, it was determined that the incident o
ccurred due to the opening of the wrong ball valve at the truck loading dock. The following corrective actions were identified and implemented to prevent recurrence of such incidents: 1) installation of a hose secure system; 2) repair of a safety interlock; and 3) replacement of hoses and fittings.
Emergency Response Program
We will continue to conduct emergency response preparedness activities and coordinate any emergency response actions necessary for the Hutchinson Facility with the Reno County Fire Department. Also involved in emergency response would be the Reno County Sheriff and, as appropriate, the Reno County Emergency Medical Services Department, and the Reno County Emergency Preparedness Center. The Hutchinson Facility Plant Manager is responsible for coordinating all emergency actions. A specific emergency response plan for the facility is in place and includes coordination with local officials, evacuation procedures, and regular drilling and training. The mo
st likely emergency action foreseen for this facility is tornadoes.
Planned Changes to Improve Safety
Diligent compliance with our RMP Prevention Program forms the framework on which we will continue to improve the level of safety at the Hutchinson Facility. Some of the key components of the safety improvements we expect to achieve are as follows:
7 The Management of Change provisions ensure that we consider the potential safety and health impacts of any change we make to process chemicals, technology, equipment or procedures.
7 The Process Hazard Analysis (PHA) provisions serve as a tool to ensure continual evaluation of potential hazards, thereby leading to continual improvements in our safety standards.
7 The Mechanical Integrity provisions ensure that process equipment and instrumentation are designed, constructed, installed and maintained to minimize the risk of hazardous releases, thereby serving as an integral part of our safety program.
7 Compliance audits will ensur
e we maintain and increase our level of safety protection.
7 An ongoing dialogue with the Reno County Emergency Management Director or his designate will ensure a constant state of readiness to respond to any potential emergencies, as well as a means to implement improvements as the need develops. In this way, we shall bolster our strong commitment to the safety of our workers and the community.
We encourage all interested citizens or community organizations to contact the Reno County Emergency Management Director for the latest information on emergency response for the county. We plan to diligently integrate our response capabilities and personnel with those of the county on an ongoing basis.