Collbran Gas Plant - Executive Summary
RISK MANAGEMENT PLAN |
KN Energy, Inc. and Rocky Mountain Natural Gas Company
Collbran Gas Plant Facility
PROJECT NO. 23987029
June 4, 1999
1. Executive Summary (40 CFR 68.155)
The Executive Summary is a brief description of the Risk Management Plan (RMP). KN Energy, Inc. (KN) will submit the Executive Summary to a central point as specified by the Environmental Protection Agency (EPA) prior to June 21, 1999.
1.1. Accidental Release Prevention and Emergency Response Policies (40 CFR 68.155(a))
KNs accidental release prevention policy involves a unified approach that integrates procedures and management practices. Applicable procedures of the U.S. Environmental Protection Agency (EPA) Prevention Program are generally adhered to. KNs emergency response policy involves the preparation of response plans which are tailored to each facility and to the emergency response services available in the community, and is in compliance with the EPA Emergency Response Program
KNs spill policy seeks to implement appropriate controls to prevent accidental releases of regulated substances. If such a release does occur, the Facility personnel are prepared to work with the local fire department, Local Emergency Planning Commission, and other authorities to control and mitigate the effects of the release.
1.2. Stationary Source and Regulated Substance Handled (40 CFR 68.155(b))
The primary activity at KNs Collbran Facility, herein referenced as the stationary source and the Facility, is the handling and storage of natural gas liquids (NGL) condensate. As part of the facility operation, natural gas liquids (NGL) condensate are stored on site, and sold to a petroleum refiner. The flammable regulated chemical mixture at the Facility is Natural Gas Liquid (NGL) that is an aliphatic and aromatic hydrocarbon mixture. The flammable regulated chemicals contained in the mixture include ethane, propane, isobutane, N-butane, isopentane and N-pentane.
These regulated flammable chemicals have a regulated threshold quantity of 10,000 pounds (lbs.). The maximum inventory of NGL is 300 barrels, which contains an average of 51,867 lbs. of regulated flammable chemicals.
1.3. Worst Case Release Scenario and Alternative Release Scenario (40 CFR 68.155(c))
Methodology given in the RMP Offsite Consequence Analysis Guidance by the EPA was applied using the RMP-COMP model approach to perform worst case release scenario (WCRS) and alternative release scenario (ARS).
The WCRS submitted for Program 2 flammable substances assumed the release was the total quantity of the 300-barrel bulk storage tank which forms a vapor cloud within the lower and upper flammability limits, and the cloud detonates. For flammable substances, the endpoint is overpressure of 1 pound per square inch (psi) for vapor cloud explosions.
Using the flammable endpoint of 1 psi overpressure the distance to the endpoint indicated that the Facility has offsite consequences
After considering possible ARSs, a release involving a pool fire of the NGL condensate from a failure of a 2-inch steel pipe connected to the NGL condensate bulk storage tank was selected. The ARS distance to endpoint for the above-described release was calculated at 0.02 miles from the Facility.
1.4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps (40 CFR 68.155(d))
KNs Collbran Facility has taken the necessary steps to comply with the accidental release prevention requirements of 40 CFR 68. This Facility was designed and constructed in accordance with applicable state and federal regulations as listed in the RMP. The following sections briefly describe the elements of the release prevention program that are in place at the stationary source.
1.4.1. Process Safety Information and Hazard Review
KN maintains a written Emergency Response Plan regarding safety information that describes the chemical hazards associated with regulated s
ubstances at the Facility. Further safety information is also detailed in the RMP. In addition, operating procedures and equipment design codes and standards associated with the operations at the Facility are maintained in the RMP at the Facility.
The Facility conducts safety inspections to identify and control the hazards associated with the process. KN inspects the bulk storage vessels, pipes, valves, gauges, and pumps on a regular basis. Any findings related to the hazard analysis are addressed in a timely manner.
1.4.2. Operating Procedures
For the purposes of safely conducting activities at the Facility associated with regulated substances, KN maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, emergency shutdown, emergency operations, normal shutdown and startup after an emergency shutdown. The information is reviewed as needed and is readily accessible to operators involved with the proce
KN has an operator safety-training program in place to train employees involved in the process. New employees receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently. Refresher training is provided annually and more frequently as needed. In addition, employees not operating the process are involved in safety training on the hazards associated with the regulated substances at the Facility.
1.4.4. Maintenance Procedures
KN performs maintenance checks on the Facility equipment to ensure proper functions. Qualified personnel carry out maintenance operations. Equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner.
When outside contractors are required for maintenance and construction activities, those personnel are accompanied by KN employees or are briefed by the area supervisor on the rules, regulations, and emergency procedures outline
d in the Emergency Response Plan before initiating work.
1.4.5. Compliance Audits
KN conducts audits on a regular basis to determine whether the provisions of the RMP rule are being implemented. These audits are performed at least every 3 years as required by 40 CFR 68. Corrective actions required as a result of the audits are undertaken in a safe and prompt manner.
1.4.6. Incident Investigation
KN promptly investigates any incident that has resulted in, or could have reasonably resulted in a catastrophic release of a regulated substance. These investigations are performed to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. Reports are retained for a minimum of 5 years.
1.5. Five-year Accident History (40 CFR 68.155(e))
The Facility has not had a reportable accident of covered processes in the five years previous to June 21, 1999, the effective date of the RMP regulation.
1.6. Emergency Response Program
(40 CFR 68.155(f))
The Facility has an Emergency Response Program that is called their Emergency Response Plan. The Emergency Response Plan describes response procedures to minimize hazards to human health and the environment in the event of a regulated substance accidental release. Aspects of emergency response include adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident cleanup of affected areas. In the event of a covered process accident, first aid procedures and procedures to inform authorities and the public are described in the Emergency Response Plan. A general emergency practice drill is performed at least annually and includes an invitation to the local authorities. A site map, MSDSs, and a list of chemicals kept on the site are kept at the Facility.
1.7. Planned Changes to Improve Safety (40 CFR 68.155(g)
Maintenance checks, compliance audits, management of change procedures a
nd incident investigations will identify changes to improve safety. KN has a continued commitment to update equipment and improve safety regarding the covered process when necessary.