Lakin Gas Plant - Executive Summary |
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Coastal Field Services Company Lakin Gas Processing Plant - Kansas Risk Management Plan (RMP) Issue Date: 12/31/98 Revision Date: Revision Page 1 Number: 0 1.0 EXECUTIVE SUMMARY Coastal Field Services Company (CFS), Operators for the Lakin Gas Processing Plant, is committed to operating in a manner that is safe for CFS workers, the public and the environment. As part of this commitment, CFS has established a system to help ensure safe operation of the processes at this facility. One component of this system is a Risk Management Plan (RMP) that helps manage the risks at CFS and that complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR part 68, Accidental Release Prevention Requirements: Risk Management Program s (the RMP rule). One of the requirements of the RMP rule is to submit a risk management plan (RMPlan) describing the risk management program at CFS. This document is intended to satisfy the RMPlan requirement of the RMP rule and to provide the public with a description of the risk management program at CFS. The RMP program at CFS consists of three (3) elements: 1) A hazard assessment to help understand: The potential offsite consequences of hypothetical accidental releases and; l accidents that have occurred during the last five (5) years associated with the use of substances regulated by the RMP rule (regulated substances). 2) A prevention program to help maintain and safely operate the processes containing more than a threshold quantity of a regulated substance (covered processes). 3) An emergency response program to help re spond to accidental releases of regulated substances from covered processes. Information further describing these elements is provided in this RMPlan. Although the RMP program at CFS helps provide assurance that the facility is maintained and operated in a safe manner, it is only one component of the safety program at CFS. In fact, CFS has a comprehensive safety program in place establishing many levels of safeguards against release of a hazardous substance and injuries and damage to its employees, the public and the environment. Issue Date: Revision Date: Revision Page 2 12/31/98 Number: 0 CFS limits the use of hazardous substances. Before using a hazardous substance, less hazardous alternatives are considered. When a hazardous substance is used at CFS, consideration is given to the potential for this substance to adversely affect CFS w orkers, the public, and the environment and CFS takes steps to prevent any such effects. CFS prevents releases of the hazardous substances used at the facility. When a hazardous substance is used at CFS, the equipment is carefully designed, built and operated to reduce the likelihood of an accidental release. Industry and government standards are closely adhered to in the design, construction, and operation of the equipment. CFS limits damage from a release, if such a release occurs. CFS trains workers to respond to an emergency response, reducing the consequences of a release if it occurs. In addition, CFS works with the local fire department and with the local emergency planning committee (LEPC) to limit injuries and environmental damage if a release does occur. The safety program at CFS consists of a number of elements, only some of which are required by the RMP rule. This RMPlan is primarily intended to describe thos e parts of the safety program at CFS that are required by the RMP rule. 2.0 ACCIDENTAL RELEASE Accidental Release Prevention and Emergency Response Policies CFS is committed to the safety of workers and the public and the preservation of the environment, through the prevention of accidental releases of hazardous substances. CFS implements reasonable controls to prevent foreseeable releases of hazardous substances. These controls include training programs for personnel; programs to help ensure safety in the design, installation, operation, and maintenance of processes at CFS; and programs to evaluate the hazards at CFS. In the event of an accidental release, CFS controls and contains the release in a manner that will be safe for workers and will help prevent injury to the public or the environment. CFS coordinates response efforts with the local emergency response personnel. Response activities have also been discu ssed with the LEPC. Issue Date: 12/31/98 Regulated Substances and CFS The Lakin Gas Processing Plant is a plant primarily involved in the recovery of liquid hydrocarbons from a gas stream. As part of this process, CFS handles several regulated, flammable substances in sufficient quantities to be covered by the RMP rule. There are no such quantities of regulated toxic substances handled at the Plant. The following RMP-regulated flammables are found at the Plant: Ethane Pentane Propane Condensate Butane Offsite Consequence Analysis CFS performed an offsite consequence analysis to estimate the potential for an accidental release of a regulated substance which could affect the public or the environment. The offsite consequence analysis consists of evaluating both worst-case release scenarios and alternative release scenarios. CFS does not expect a wors t-case to ever occur. The alternative release scenarios were selected to help the local emergency planning committee improve the community emergency response plan. An alternative release scenario represents a release that: 1) might occur at a facility such as CFS, and/or, 2) would result in the greatest potential offsite consequences if the release occurred. The main objective of performing the offsite consequence analysis is to determine the distance at which certain effects might occur to the public because of an accidental release (called the endpoint distance). Minimal effects could occur at the endpoint distance. At distances less than the endpoint distance, the effects would be greater; at distances greater than the endpoint distance, the effect would be less. The RMP rule includes specific requirements for the worst-case and alternative release scenarios that must be reported by CFS. These requirements are: One worst-case and one alternative release scenario for the class of flammable substances in Program 3 processes. The following information summarizes the offsite consequence analysis performed by CFS. Issue Date: 12/31/98 Program 3 Processes Flammable Substances: The worst-case release scenario for flammable substances is failure of the 59,775 gallon gasoline storage tank, resulting in a vapor cloud explosion. No administrative controls or passive mitigation were considered for this release scenario. The maximum distance to the 1-psi overpressure endpoint is 0.56 miles. Several public receptors are located within this distance, including Colorado Interstate Gas Company, Lakin Golf Course Clubhouse and some residences east of the plant. The alternative release scenario for flammable substances is a pipe rupture of the line from the product storage vessel to the product pumps . This scenario assumes that flammable substances (ethane, propane, i-pentane, n-pentane, and heavier hydrocarbons) are released from a ruptured truck loading hose for 5 minutes before workers detect the release and isolate the piping section. The substances form a vapor cloud, resulting in a vapor cloud explosion. The maximum distance to the overpressure endpoint is 0.13 miles. Receptors, which could be affected by the alternate release scenario, include the adjacent Colorado Interstate Gas Company facility. Accidental Release Prevention Program CFS uses a prevention program to help prevent accidental releases of hazardous substances. Beginning in 1994, CFS formalized this prevention program for processing of natural gas to comply with the 14 elements of the OSHA process safety management (PSM) prevention program. In 1996, the EPA RMP rule established two levels of prevention program requirements. The level relevant to the Lakin Plant i s: Program 3: Essentially the same as OSHA PSM, except that the program also focuses on protecting the public and the environment. The following sections briefly describe the elements of CFS's prevention program that address the EPA RMP rule prevention program requirements. Issue Date: 12/31/98 Revision Date: Revision Page 5 Number: 0 Program 3 Prevention Program The CFS Program 3 prevention program, which applies to the Plant, consists of the following 12 elements: Employee Participation Process Safety Information Process Hazard Analyses Operating Procedures Training Contractors Pre-Startup Safety Review Mechanical Integrity Hot Work Permits Management of Change Incident Investigation Compliance Audits 3. 0 PROGRAM 3 PREVENTION PROGRAM Process Safety Information CFS maintains a variety of technical documents that are used to help ensure safe operation of the CFS processes. These documents address: 1) Physical properties of hazardous substances handled, 2) Operating parameters of the equipment, and 3) Design basis and configuration of the equipment. CFS ensures that this process safety information is available to all CFS employees, the LEPC and the fire department. Material safety data sheets (MSDS's) document the physical properties of hazardous substances handled at CFS, including regulated substances in covered processes. The information available for each hazardous substance typically includes: 1) Toxicity information and permissible exposure limits, 2) Physical data (e.g., boiling point, melting point, flash point), 3) Reactivity and corrosivity data, 4) Thermal and chemical stability data, and 5) Hazards of mixing substances in the process. Issue Date: Revision Date: Revision Page 6 12/31/98 Number: 0 MSDS's for hazardous substances handled in each process are available in the Plant's MSDS book so the personnel have ready reference to this information. In addition, MSDS's are provided to the LEPC and the fire department for use in helping formulate emergency response plans. The engineering design documents include the operating parameters and the design basis and configuration of the equipment in each covered process. The available information includes: 1) Operating parameters 2) Block flow or simplified process flow diagrams 3) Process chemistry 4) Maximum intended inventories 5) Safe upper and lower limits for parameters such as temperature, pressure or flow 6) Consequences of deviations from established operating limits 7) Design basis and configuration of equipment 8) Piping and instrument diagrams, including materials of construction, 9) Electrical classification 10) Safety systems 11) Applicable design codes and standards, and 12) Design basis for relief and ventilation systems. When important information was not available from the design documents, it was developed through special projects or, in the case of operating parameters, during process hazard analyses of the process. Many of the operating parameters are included in the operating procedures to help with the safe operation of the process. These documents are used: 1) to train employees; 2) to perform process hazards analyses, and 3) to help maintain the equipment. Process Hazard Analysis The CFS gas plant has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematical ly examined to identify hazards and ensure that adequate controls are in place to manage these hazards. Issue Date: 12/31/98 The Lakin Gas Processing 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. The analyses are conducted using a team of people who have operating 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 Process Hazard Analysis (PHA) team findings are forwarded to local and corporate management for resolution. Implementation of mitigation options in response to PHA findings is ba sed on a relative risk ranking assigned by the PHA team. 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 periodic reviews are conducted at least every five years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration and the final resolution of the findings is documented and reta ined. Operating Procedures The Lakin Gas Processing Plant maintains written procedures that address various modes of process operations, such as: Unit Start-up Normal Operations Temporary Operations Emergency Shutdown Normal shutdown Initial start-up of a new process Issue Date: 12/31/98 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 through the management of change process. In addition, the Lakin Gas Processing Plant maintains Operating Procedures, which provide guidance on how to respond to upper or lower limit exceedances for specific processes or equipment parameters. This information, along with writ ten operating procedures, is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks. Training To complement the written procedures for process operations, the Lakin Gas Processing 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 qualified 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. All of this training is documented for each operator, including the means used to verify that the operator understood the training. Documentation is maintained at the Plant, which certifies on-the-job experience for each operator. Contractors The Lakin Gas Processing 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 plant has procedures in place to ensure that contractors: Perform their work in a safe manner, Have the appropriate knowledge and skills, Are aware of the hazards in their workplace, Understand what they should do in the event of an emergency, Understand and follow site safety rules, and Inform gas plant personnel of any hazards they find during their work. Issue Date: Revision Date: Revision Page 9 12/31/98 Number: 0 This is accomplished by providing contractors with: A process overview, Information about safety and health hazards, Emergency response plan requirements, and Safe work practices prior to their beginning work. In addition, the plant evaluates contractor safety programs and performance during the selection of a contractor. Gas plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-Startup Safety Reviews (PSSR) CFS conducts a (Pre-Startup Safety Reviews) PSSR for any major facility modifications that require a change in the process safety information. The purpose of the Pre-Startup Safety Reviews (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 ensure that construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists or startup procedures to verify all aspects of readiness. A PSSR involves field verification of the construction and serves as a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. Mechanical Integrity The Lakin Gas Processing Plant has well-established Mechanical Integrity (MI) 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 basis aspects of this program include: Conducting training, Developing written procedures, Performing inspections and tests, Correcting identified deficiencies, and Applying quality assurance measures. Issue Date: 12/31/98 In combination, these activities form a s ystem that maintains the mechanical integrity of the process. Maintenance personnel receive training on: An overview of the process, Safety and health hazards, Applicable maintenance procedures, Emergency response plans, and 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 equipment 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 MI program is quality assurance. The Lakin Gas Processing 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 Lakin Gas Processing Plant has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include: Control of the entry/presence/exit of support personnel, A lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, A procedure for safe removal of hazardous substances before process piping or equipment is opened, A permit and procedure to control spark-producing activities (i.e., hot work), and, A permit and procedure to ensure that, adequate precautions are in place before entry into a confined space. Issue Date: 12/31/98 These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. CFS maintains a Safe Work Practices Manual as a guidance document to promote employee safety, comply with applicable safety laws and regulations, eliminate injuries, and prevent accidental damages. Management of Change The Lakin Gas Processing 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: Ensure that adequate controls are in place to manage any new hazards, and Verify that existing controls hav e not been compromised by the change. Affected 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 CFS promptly investigates all incidents that result in, or reasonably could have resulted in, a fire/explosion, flammable 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 recurrence, and forwards these results to gas plant management for resolution. Corrective actions taken in response to the investigation teams findings and re commendations are tracked until they are complete. 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. Incident investigation reports are retained for a least five years so that the reports can be reviewed during future PHA revalidations. Issue Date: 12/31/98 Compliance Audits To help ensure that the accident prevention program is functioning properly, the Lakin Gas Processing Plant periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every three (3) years. Both Operations and Corporate staff personnel may participate as audit team members. The audit team develops findings that are forwarded to gas plant management fo r resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained. 4.0 CHEMICAL-SPECIFIC PREVENTION STEPS The processes at the Lakin Gas Processing 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 is applied to the entire Lakin Gas Processing Plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. Specialized Safety Features CFS has safety features on many units to help: Contain/control a release, Quickly detect a release, and Reduce the consequences of (mitigate) a release. The following types of safety features are used in the covered processes. l Release detection: Hydrocarbon detectors with alarms. l Release containment/control: Process relief valves that discharge to a flare to capture and incinerate episodic releases. Valves to permit isolation of the process (manual or automated). Automated shutdown systems for specific process parameters (e.g., high pressure and temperature). Curbing or diking to contain liquid releases. Backup power equipment (e.g., 24-volt backup power supply for process control system). Atmospheric relief devices. Issue Date: Revision Date: Revision Page 13 12/31/98 Number: 0 Release mitigation: Fire suppression and extinguishing systems. Fire water monitors and hydrants for specific process units. Trained emergency response personnel. Personal protective equipment (e.g., fire retardant protective clothing). Five Year Accident History The Lakin Gas Processing Plant has an excellent record of accident prevention over the past five years. There have been no accidents or incidents in the past five years, resulting in offsite effects. 5.0 EMERGENCY RESPONSE Emergency Response Program Information The Lakin Gas Processing Plant 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 pl ans 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 requirements. In addition, the plant has procedures that address maintenance, inspection and testing of emergency response equipment (SPCC Plan Procedures), 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 gas plant processes or other CFS facilities. The emergency response program changes are administered through the Plant Supervisory approval process, which includes informing and/or training affected personnel in the changes. The overall emergency response program for the Lakin Gas Processing Plant is coordin ated with the Kearny County LEPC located in Lakin, Kansas. This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The Lakin Gas Processing Plant has communications capability with appropriate LEPC officials and emergency response organizations (e.g., Kearny County Sheriff's Department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. Issue Date: Revision Date: Revision Page 14 12/31/98 Number: 0 Planned Changes to Improve Safety CFS is committed to operating the Lakin Gas Processing Plant in a safe manner for workers, the public, and the environment. CFS personnel utilize auditing processes to ensure the Plant complies with safe operat ions of its processes. In the event improvements in safety can be realized through auditing efforts, actions are planned and instituted to respond to safety enhancements of operating practices. Improvements to safety are a continual process at the Plant. |