HEMPHILL GAS PLANT - Executive Summary |
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HEMPHILL GAS PLANT RISK MANAGEMENT PLAN: EXECUTIVE SUMMARY ACCIDENTAL RELEASE PREVENTION & RESPONSE POLICIES: Crescendo Resources L.P owns and operates the Hemphill Gas Plant. Crescendo is committed to worker and public safety at the Hemphill Gas Plant along with all of it's operations. This commitment is demonstrated by a strong management involvement and resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation and maintenance of our processes. Numerous prevention and detection controls have been implemented to prevent a release of regulated substances. If a release were to occur gas plant trained personnel would respond to control and contain the release according to the Hemphill Gas Plant Response Plan, which includes notification of the public. DESCRIPTION OF THE STATIONARY SOURCE & REGULATED SUBSTANCES: The Hemphill Gas Plant is located in a rural area of Hemphill County, near Canadian, Texas. The plant is a cryogenic natural gas processing plant which was constructed as a new facility with start up in late 1998. Raw natural gas and condensate are processed into residue natural gas and a Y-grade natural gas liquids stream for sales. The primary regulated substance contained in processes at the Hemphill Gas Plant are flammable mixtures. OFFSITE CONSEQUENCE ANALYSIS: There are three (3) processes at the Hemphill Gas Plant that contain regulated flammable substances which are flammable mixtures. All of the processes are program level I. There are no processes that contain toxic regulated substances above the regulated substances threshold. A worst case scenario (WCS) for flammable substances has been completed for each of the three (3) processes: No credit for administrative controls or passive mitigation measures was taken into account in determining the scenarios. The following is a summary of the WCS for each of the three (3) processes. Process 1: Process Area A vapor cloud explosion (VCE) involving the full inventory of all vessels and piping in the core process area containing 289,039 lbs of a flammable mixture. The maximum distance to the 1 psi end point for this WCS is 0.53 mile. Process 2: Propane and NGL Storage A vapor cloud explosion (VCE) involving the full inventory of these tanks containing 411,075 lbs of a flammable mixture assuming they are 100% liquid full. The maximum distance to the 1-psi end point for this WCS is 0.60 mile. This is the WCS with the furthest endpoint, at the Hemphill Gas Plant. Process 3: Condensate Tanks A vapor cloud explosion (VCE) involving the full inventory of the tank containing 140,412 lbs of a flammable mixture assuming it is 100% liquid full. The maximum distance to the 1-psi endpoint for this WCS is 0.42 mile. The Offsite Consequence Analysis Guidance was used to determine the 1-psi endpoint for each WCS. There are no offsite impacts within the distance to each flammable endpoint. GENERAL ACCIDE NTAL RELEASE PREVENTION PROGRAM The following is a summary of the Accident Prevention Program in place at the Hemphill Gas Plant. Although processes at the Hemphill Gas Plant that are regulated by the Environmental Protection Agency's (EPA's) Risk Management Program (RMP) regulation are Program Level 1, they are also subject to the Occupational Safety and Health Administration's (OSHA's) Process Safety Management (PSM) standard. This summary addresses each of the OSHA PSM elements and describes the system to implement the Accident Prevention Program. Employee Participation Crescendo Management requires employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents to participating as a member of a process hazard analysis (PHA) team. Employees have access to all information created as part of the gas plant accident prevention program. Process Safety Information The Hemphill Gas Plant keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and equipment design basis/configuration information. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). For specific process areas, the gas plant has documented safety-related limits for specific process parameters (e.g., temperature, level, composition). The plant ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel and protective instrument systems (e.g., automated shutdown systems). The Hemphill Gas Plant also maintains numerous technical documents that provide information about the design and construction of process equipment. This information includes mate rials of construction, design pressure and temperature ratings, and electrical rating of equipment. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. Process Hazard Analysis (PHA) The Hemphill Gas Plant has a program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. The Hemphill Gas Plant primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. These analyses are conducted using a team of people who have operatin g and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and the team makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team findings are forwarded to management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking. This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options in response to PHA team findings are tracked until they are completed. The final resolution of each finding is documented and retained. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the plant periodically updates and revalidates the hazard analysis results. These p eriodic reviews will be conducted at least every 5 years. The results and findings from these updates will be documented and retained. Operating Procedures The Hemphill Gas Plant maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. These procedures are periodically reviewed and annually certified as current and accurate. The procedures are kept current and accurate by revising them as necessary to reflect changes made through the management of change process. In addition, the Hemphill Gas Plant provides guidance on how to respond to upper or lower limit exceedances for specific process or equipment parameters. This information is included in written operating proce dures, is readily available to operators in the process unit and for other personnel to use as necessary to safely perform the job tasks. Training To complement the written procedures for process operations, the Hemphill Gas Plant has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in gas plant operations if they are not already familiar with such operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate (e.g., through tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at leas t every 3 years. All of this training is documented for each operator, including the means used to verify that the operator understood the training. Contractors The Hemphill Gas Plant uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the gas plant has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand the follow site safety rules, and (6) inform gas plant personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plant requirements, and (4) safety work practices prior to their beginning work. In addition, C rescendo evaluates contractor safety programs and performance during the selection of a contractor. Plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-startup Safety Reviews (PSSRs) The Hemphill Gas Plant conducts a PSSR for any new facility or facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. Mechanical Integrity The Hemphill Gas Plant has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process. Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their jobs in a safe manner. Written procedures help ensure that work is performed in a consistent manner and provide a basis for training. Inspections and tests are performed to help ensure that equipm ent functions as intended and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or a management of change team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. Another integral part of the mechanical integrity program is quality assurance. The Hemphill Gas Plant incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. Safe Work Practices The Hemphill Gas Plant has work practices in place to help ensure work and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolat ion of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of flammable substances before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) 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 that operations and maintenance activities are performed. Management of Change The Hemphill Gas Plant has a comprehensive system to manage changes to all covered processes. This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes be properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existi ng controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change. Incident Investigation The Hemphill Gas Plant will promptly investigate all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, 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 investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to plant management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations will be tracked until they are complet e. The final resolution of each finding and recommendation will be documented, and the investigation results reviewed with employees (including contractors) who could be affected by the findings. Incident investigation reports will be retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations. Compliance Audits To help ensure that the accident prevention program is functioning properly, the Hemphill Gas Plant will periodically conduct an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. In addition to the above PSM elements, the Hemphill Gas Plant has additional programs that support accident prevention. A summary of these programs are as follows: Near Miss/Hazard Identification Employees are encouraged to participated in this program which identifies through a written procedure observed near miss incidents, unsafe acts and/or hazards at the Hemphill Gas Pla nt. These near miss/hazard identifications are reviewed for actions and trends, categorized and resolved as required. Tailgate Safety Meetings These informal meetings take place just prior to the start of a job by contractors or employees at the Hemphill Gas Plant. Safety concerns or potential hazards that may be encountered during the job are identified and discussed. CHEMICAL-SPECIFIC PREVENTION STEPS The processes at the Hemphill Gas Plant have hazards that must be managed to ensure continued safe operation. The following is a description of existing safety features applicable to prevention of accidental releases of regulated substances in the facility. Universal Prevention Activities The accident prevention program summarized previously is applied to all RMP-covered processes at the Hemphill Gas Plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. Specialized Safety F eatures The Hemphill Gas Plant 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: Release Detection 1. Hydrocarbon detectors with alarms/shutdown. 2. Fire eyes. 3. Vibration shutdowns. Release Containment/Control 1. Process relief valves that discharge to a flare to capture and incinerate episodic releases. 2. Valves to permit isolation of the process (manual or automated) 3. Automated shutdown systems for specific process parameters (e.g., high temperature) 4. Curbing or diking to contain liquid releases 5. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system) 6. Atmospheric relief devices Release Mitigation 1. Trained emergency response personnel 2. Personal protective equipment (e.g., chemical protective clothing, self-contained breathing apparat us, SCBA) 3. Fire extinguishers FIVE YEAR ACCIDENT HISTORY The Hemphill Gas Plant has an excellent record of accident prevention. There have been no applicable events that have occurred since the startup of the Plant in October of 1998. EMERGENCY RESPONSE PROGRAM INFORMATION The Hemphill Gas Plant maintains a written emergency response plan, 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 aspects of emergency response, including proper first aid and medical treatment, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs. In addition, the plant has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is updated when necessary based on modifications made to plant processes or other Hemphill Gas Plant facilities. The emergency response program changes are administered through the Management of Change (MOC) process, which includes informing and/or training affected personnel in the changes. The overall emergency response program for the Hemphill Gas Plant and this Risk Management Plan have been coordinated with the Hemphill County, Texas, Local Emergency Planning Committee (LEPC). The Hemphill Gas Plant has around-the-clock communications capability with appropriate emergency response organizations. This provides a means of notifying the public of an incident, if necessary. The Hemphill Gas Plant conducts periodic emergency drills and provides annual refresher training to emergency responders regarding the hazards of regulated substances in the plant. PLANNED CHANGES TO IMPROVE SAFETY The Hemphill Gas Plant is committed to continuous improvement in safety. The Plant is a new facility with startup in late 1998. No major changes are currently planned that would have an effect on safety improvement. Any changes identified in future PHA's, safety audits and/or incident investigations will be scheduled for completion. |