Piceance Creek #1 - Executive Summary
RISK MANAGEMENT PLAN |
KN Energy, Inc.
Piceance Creek #1 Gas Plant
Rio Blanco County, Colorado
PROJECT NO. 23997041
June 16, 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))
KN's 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. KN's 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 requirements.
KN's spill poli
cy 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 KN's Piceance Creek #1 Gas Plant Facility, herein referenced as the stationary source and the Facility, is the handling and compression of natural gas. In addition, as part of the facility operation, natural gas liquids (NGL) are separated from the natural gas stream, stored on site, and sold to a petroleum refiner. The flammable regulated chemical mixture at the Facility is Natural Gas Liquids (NGL) that is an aliphatic and aromatic hydrocarbon mixture. The flammable regulated chemicals contained in the mixture include methane, ethane, propane, isobutane, N-butane, isopenta
ne and N-pentane. These regulated flammable chemicals have a regulated threshold quantity of 10,000 pounds (lbs.). The maximum inventory of NGL is 30,000 gallons, which contains an average of 384,176 lbs. of regulated flammable chemicals
1.3. Worst Case 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).
The WCRS submitted for Program 1 flammable substances assumed the release was the total quantity of the 30,000-gallon 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 does not have offsite consequences.
1.4. The General Accidental Release
Prevention Program and the Chemical-Specific Prevention Steps (40 CFR 68.155(d))
The 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 Process Hazard Analysis
KN's release prevention program includes a written Emergency Response Plan. In addition, safety information that describes the chemical hazards associated with regulated substances is maintained 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.
1.5. Five-year Accident History (40 C
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 decontamination 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 Action Plan. A general emergency practice drill is performed at least annually and includes an invitation to the local authorities. A site m
ap, 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 and 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.