Coyanosa Plant - Executive Summary
KOCH MIDSTREAM PROCESSING 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 rem
edying 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 Coyanosa Plant is one of many facilities operated by Koch Midstream Processing Company (Koch). At the facility we receive natural gas via pipeline. The natural gas is treated to remove carbon dioxide and water. The natural gas is then demethanized and separated into methane and natural gas liquids. Methane and natural gas liquids are transported from the facility via two separate pipelines. The recovered sulfur is also sold via pipeline to third party customers. A flammable mixture (Natural Gas Liquids) is the only flammable substance regulated under the Risk Management Program (RMP) that is stored at the facility. The facility is classified as Program Level 3 under the regulation. The purpose of this Risk Management Plan (RMPlan) is to provide information about our operations at the facili
ty, our programs to prevent accidental chemical releases, our emergency response plans in case an accidental release should occur, our 5 year accident history, and our planned changes to improve safety at the facility.
Worst Case and Alternative Release Scenarios
As specified by the U. S. Environmental Protection Agency (EPA) RMP Regulations, our worst case release scenario for flammables would be the loss of all of the natural gas liquid in our largest vessel causing a vapor cloud explosion. In the case of the Coyanosa Plant, this would involve our 60,000 gallon Natural Gas Liquid bullet. 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. An overpressure of 1 psi is EPA's threshold for measurable impacts. Although we have numerous controls to prevent such releases (high level alarms, emergency shutdown,
and others) and to manage their consequences, no credit for any controls or mitigation measures was taken into account when evaluating this scenario. The alternative release scenario characterized as a more likely scenario, which would involve offsite consequences, is calculated to reach approximately 0.3 miles (approximately 1600 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. Once again, no credit for any controls or mitigation measures was taken into account when evaluating this alternative release scenario. We selected the alternative release scenario based on a release of hydrocarbon vapor due to failure of the demethanizer relief valve. If such an incident occurred, the relief valve could release hydrocarbon vapor at a rate of approximately four tons per minute. We have active mitigation measures in place to greatly reduce the chance that su
ch an event could ever occur. We monitor the level of liquid in the vessel at all times. If the level gets too high, emergency shutdown will occur. We regularly inspect and test the relief valves on all our tanks and vessels. The presence of these active mitigation measures serves to either prevent this scenario from occurring or minimize its impact if it does occur.
We have discussed these potential hydrocarbon releases with our employees and with local emergency response officials in Pecos County, thereby further reducing the possibility of any impact on the public.
The Coyanosa Plant has been operating under the strict guidelines of the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) Program since 1992. Our ongoing analysis of the potential hazards of our process, detailed training of our employees, and constant emphasis on safety have helped us avoid any serious accidents over the last 5 years. Part of this progra
m has also involved identifying and taking steps to avoid potential accidental chemical releases. A few examples of the additional prevention features implemented at this facility include:
7 We installed hydrogen sulfide monitors around the sulfide treatment plant and the sulfur recovery plant which will sound an audible alarm upon detection of high hydrogen sulfide concentrations.
7 We installed Lower Explosive Limit monitors in our engine room.
7 We provided manually operated emergency shutdown (ESD) buttons near all the facility gates in order to shutdown the entire facility during emergency situations.
7 We installed a natural gas flare that is lit continuously.
These safeguards, as well as the vigilance of our trained employees, have helped us operate safely at this facility since we acquired it in 1998.
Five Year Accident History
No incident having resulting in onsite or offsite impacts from a hydrocarbon release has occurred at the Coyanosa Plant within the la
st five years. Although we take pride in that record, we also place daily emphasis on our prevention and safety programs to ensure this record continues.
Emergency Response Program
Any emergency response necessary for the Coyanosa Plant is coordinated with the Fort Stockton Voluntary Fire Department and the Pecos County Sheriff's Department. The Coyanosa Plant Manager is responsible for coordinating all emergency actions. A specific Emergency Response Plan for the facility is in place and that plan has been coordinated with local officials, along with evacuation procedures, regular drilling, and training. Our Emergency Response Program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations.
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 Coyanosa Plant. 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 Internal and third party compliance audits will ensure we maintain and increase our level of safety protection.
7 An ongoing dialogue with the Pecos County Emergency Management Director or his designate will ensure a constant state of readiness to respond to any potential emergencies, as well as a mean
s 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 Pecos 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.