Cut Bank NGL Plant - Executive Summary

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This is a brief overview of the RMP and policies of North American Resource Company's Cut Bank, MT gas plant. 
Location and Status 
The Cut Bank Main Line plant is located near Cut Bank, Montana at Township 33N -  Range 5W., Section 22.  The plant is located on approximately 20 acres of land, some six miles from the southern edge of the town of Cut Bank.  The plant is owned by North American Resources Company (NARCO), a wholly owned subsidiary of the Montana Power Company (MPC).  NARCO contracts with another MPC group to operate the plant, but NARCO retains authority for the operations.  The plant continues to fractionate approximately twenty-eight million cubic feet of gas per day and NARCO has no immediate plans to change the operations. 
The plant has not experienced an incident that resulted in injuries or environmental damage as defined in the RMP rule in the past five years. 
History and Ownership 
The plant was originally constructed by ProPak Inc. as a gas compression and fractio 
nation facility for Montana Power Company.  In 1997, through an internal reorganization, Montana Power Company's oil and gas operations (NARCO) assumed responsibility for management of the plant.  Since that time NARCO has managed the compliance issues associated with the plant's operations.  Montana Power/NARCO have a long history in the energy services field and have a well-defined environmental and safety management system implemented throughout the company.   
Program Level 
NARCO has determined the Cut Bank plant is a Program Level 1 facility because there are no identified public receptors within the range of the worst case release scenario, there have been no incidents meeting the RMP criteria in the past five years, and emergency response procedures have been coordinated with the local response agency.  The plant is covered under the Occupational Safety and Health Administration's Process Safety Management standard.   
Prevention and Response Policies 
The accidental release prev 
ention and emergency response policies are provided in the plant Emergency Response Plan and the Emergency Planning and Response section of the Cut Bank plant RMP manual.  The plant's emergency response plan has been coordinated with the Glacier County Disaster and Emergency Services department (LEPC) and agency personnel have toured the facility.  NARCO takes an active role in preventing accidental releases at its facility by ensuring that employees are trained in the safe operation of the plant and evacuation procedures.   
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.   
Stationary Source and Regulated Substances 
The plant is a natural gas fractionation facility designed to extract certain hydrocarbon liquids from the inlet gas stream.  This is done to make the gas stream pipeline ready as the dew point must be at a certain level to permit the gas to be trans 
ported via pipeline, safely.  The company has installed many safety systems to ensure that the inlet compression, processing, storage and distribution systems function safely.  
Propane, butane, natural gas, and natural gasoline are products of the distillation processes at the Cut Bank plant.  These flammable substances are managed with great care given their inherent hazards.  The company invests in equipment upgrades as necessary to ensure the operations remain safe.  In addition, there are maintenance procedures, parts controls, internal engineering standards, and ongoing personnel awareness training (e.g., hazard communication, lockout/tagout, emergency drills.)   
Internal and external audits are done to ensure the plant is in a continual improvement process.  Audits may be regulatory or management systems in nature, but in any case are done as part of the plant's objectives.  Results are reported to management and corrective actions taken and tracked as indicated.  
The butane s 
torage tank is filled only to 80% of capacity.  This is done as an administrative control to ensure overfilling or over pressuring of a tank cannot occur.  Trucks are used to transport product from the plant.  No one is allowed access into the plant without prior authorization from personnel in the plant office, so plant administration knows when a truck is on premises. 
Release Scenario 
For worst case the regulation is clear.  The assumption is that the single largest container is released over a ten (10) minute period.  No active mitigation is considered.  Worst case meteorological conditions are assumed and RMP*Comp was used to calculate the endpoint distance for overpressure of 1.0 pound per square inch (PSI) for a butane vapor cloud explosion.   A distance of 0.5 miles to the flammable endpoint was determined for a release of 275,000 pounds in ten minutes.   
Prevention Program 
The prevention program and chemical-specific action steps are described in detail in the Cut Bank PSM/RM 
P Manual and the plant emergency response plan. 
Elements in the program include or refer to: 
- Employee participation 
- Process safety information 
- Process hazard analysis 
- Operating and maintenance procedures   
- Training 
- Contractor management 
- Pre startup procedures 
- Mechanical integrity requirements 
- Hot work procedures 
- Management of change procedures 
- Incident investigation 
- Compliance audits 
Accident History 
The plant has not experienced any accidents that meet the criteria specified in the standard in the past five years. 
Emergency Response Program 
The facility has established and maintains an emergency response plan that is coordinated with local response agencies.   The plan meets the requirements of 40 CFR 68.95.  The plan is designed to protect personnel on the site, to ensure their safe and orderly evacuation in event of an emergency, and to provide appropriate information and protection for response personnel.   The program is reviewed and updated as needed on  
at least an annual basis.
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