Santa Clara Valley Gas Plant - Executive Summary |
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1.0 EXECUTIVE SUMMARY 1.1 Accidental Release Prevention and Emergency Response Policies Nuevo Energy Company (Nuevo) is the owner of the Santa Clara Valley Gas Plant. Torch Operating Company (Torch) operates the facility for Nuevo. It is the policy of Nuevo and Torch that its employees, environment, property, and the general public be protected from any off-site impacts that may occur as a result of its operations. To achieve this end, Torch strives to operate is facilities in compliance with applicable federal, state, and local safety, health, and environmental regulations. Nuevo and Torch have a long-standing commitment to worker and public safety at the Santa Clara Valley Gas Plant. This commitment is demonstrated by the resources invested in accident prevention (e.g., training of personnel, considering safety in the design, installation, operation, and maintenance of the facility, etc.). It is each company's philosophy to implement reasonable mitigation measures to eliminat e preventable releases of regulated substances as well as other substances. Company emergency response policies are implemented to comply with the overall corporate policy of providing its workers with a safe workplace and minimizing risk to the public. This is considered to be of prime importance; therefore, all procedures must be carried out in the appropriate manner. The safety of emergency and non-affected personnel has the highest priority. Only then can safely executed rescue and medical activities be considered. Protection of the environment is another high priority. Only after life, safety, and environmental concerns are addressed will the focus shift to the secondary issues of property conservation and business recovery. 1.2 Facility Description The Santa Clara Valley Gas Plant is located in Ventura County, approximately 25 miles inland from the Pacific Ocean and approximately 6 miles south of the town of Piru. Torrey Canyon Road dead-ends into Guiberson Road at t he entrance to the facility. The nearest major highway is State Route 126, approximately 0.5-miles to the north. The facility is relatively remote and bounded by undeveloped private property on the south and southeast and citrus orchards on the northeast. A dry creek wash (Torrey Canyon Wash) is located along the northeast boundary of the facility. The Gas Plant consists of one Program 3 process which utilizes several operations to produce natural gas and natural gas liquids product. Two gas streams come into the plant from local oil production fields and enter separate gas scrubbers and then flow through three compressor skids where the gas is compressed to Gas Company specifications. The gas is cooled and sent through the turbo expander where gasoline, butanes and propane are dropped out. The liquids are separated out and sent to a pressure vessel for storage before being trucked offsite to distributors. The natural gas from the process is dry gas which is sold as a prod uct. 1.3 Regulated Substances Regulated flammable mixtures containing methane, ethane, propane, butane, iso-butane, pentane and iso-pentane are present at the facility. No regulated toxic substances are present at the facility in excess of the threshold quantities established by this regulation. 1.4 Summary of Offsite Consequence Analysis Results 1.4.1 Worse-Case Release Scenario - Flammables The worse-case release for flammables, as defined in the regulation, is a release of flammable materials resulting in a vapor cloud explosion of the maximum inventory of the largest vessel. Even though the normal operating inventory for this equipment is less than the maximum capacity, and this equipment is protected by high level alarms/shutdowns, pressure relief valves, periodic inspections, and routine monitoring by operating personnel, this maximum inventory must be assumed to be released in 10 minutes and ignited at the point of release. The worse-case release scenario modeled for the Santa Clara Valley Gas Plant is a release of the entire volume of the flammable material stored in the largest of four Butane/Propane storage vessels. The worse-case release scenario identified some off-site impacts, but the impact area includes minimal public receptors and no residential receptors. 1.4.2 Alternative Release Scenario - Flammables The alternative release scenario for flammables is a release of propane which results in a vapor cloud fire. The alternative release scenario could have some off-site impacts, but the impact area includes no off-site residential receptors. 1.5 Summary of Accidental Release Prevention Program In addition to being subject to RMP requirements the Santa Clara Valley Gas Plant is subject to Office of Employee Health Administration (OSHA) Process Safety Management Program (PSM). Through compliance with the PSM standard (with minor additions) Santa Clara Valley Gas Plant has implemented the requirements of the Program 3 preventio n program. Compliance with PSM's comprehensive program ensures the integrity of the processes which handle flammable materials. The objective of the Company's PSM Program is to prevent unwanted releases of hazardous chemicals. To control these types of hazards, Torch has developed the necessary expertise, experiences, judgement and proactive initiative within their workforce to properly implement and maintain an effective process safety management program. An effective PSM program requires a systematic approach to evaluating the whole chemical process. Using this approach, the process design, process technology, process changes, operational and maintenance activities and procedures, non-routine activities and procedures, emergency preparedness plans and procedures, training programs, and other elements that affect the process are all considered in the evaluation. The various lines of defense that have been incorporated into the design and operation of the process to prevent or mitigate the release of hazardous chemicals have been evaluated and strengthened to assure their effectiveness at each level. Process safety management is the proactive identification, evaluation and mitigation or prevention of chemical releases that could occur as a result of failures in process, procedures or equipment. The elements of the company's PSM and accidental release prevention program are summarized below: Process Safety Information - This includes complete and accurate written information concerning process chemicals, process technology, and process equipment essential to the company's PSM program and to a process hazard analysis. The process safety information includes information pertaining to the hazards, technology and the equipment of the natural gas processing system. Process Hazard Analysis (PHA) - Is an organized and systematic effort to identify and analyze the significance of potential hazards associated with the processing or handling of flammable material s. The PHA provides information that will assist the company and its employees in making decisions for improving safety and reducing the consequences of unwanted or unplanned releases of flammable materials. As part of the company's PSM program a PHA has been conducted for the Santa Clara Valley Gas Plant. Operating Procedures - As part of the PSM program, all procedures for operating and maintaining the natural gas processing system are documented and accessible to employees whose work involves this system. As needed, changes or updates to the natural gas processing system operating procedures are incorporated under the company's management of change program. Employee Training - Personnel performing specific tasks which affect the natural gas processing system must be qualified to perform their assigned tasks. The company has an established training program that ensures the training and competency of employees whose jobs require them to perform work which affect the natural gas processing system. Mechanical Integrity - Under the PSM program, equipment used to process, store, or handle flammable materials has to be designed, constructed, installed, and maintained to minimize the release of such chemicals. As required, elements of the mechanical integrity program include identifying and categorizing equipment and instrumentation, inspections and tests and their frequency; maintenance procedures; training of maintenance personnel; criteria for acceptable test results; and documentation of manufacturer recommendations for equipment and instrumentation. Management of Change - Contemplated changes to a process must be evaluated thoroughly to fully assess their impact on employee safety and health and to determine needed changes to operating procedures. The company has established and implemented procedures to manage changes (except for "replacements in kind") to process chemicals, technology equipment and procedures, and changes to facilities that affect the natural gas processing system. Pre-Startup Safety Review - As one of the requirements of PSM, Torch is required to perform a pre-startup safety review for new facilities, and for modified facilities when the modification is significant enough to require a change in the process safety information. Although the processes at the Santa Clara Valley Gas Plant are essentially mature and therefore the start up of new processes are not anticipated, a PHA will be performed prior to start up for new processes which require a hazardous material above the regulatory threshold. For existing processes that have been shutdown for turnaround or modification, company policy ensures that any changes other than "replacement in kind" made to the process during shutdown go through the management of change process. Compliance Audits - Periodically Torch performs an audit of their PSM program as required by the PSM standard. An audit is a technique used to gather sufficient facts and information, in cluding statistical information, to verify compliance with the PSM standards. The audit includes an evaluation of the design and effectiveness of the PSM system and a field inspection of the safety and health conditions and practices to verify that the PSM program elements are effectively implemented. Incident Investigation - A crucial part of Torch's PSM program is a thorough investigation of incidents to identify the chain of events and causes so that corrective measures can be developed and implemented. Accordingly, Torch has an incident investigation program which requires the investigation of each incident that resulted in, or could have reasonably resulted in, release of a flammable material. Employee Participation Plan - Torch has developed written procedures to include employees in the development, implementation and management of these PSM program elements. Hot Work & Safe Work Practices - Torch has established safe work practices in place to ensure worker and process sa fety. These include (but are not limited to): lock-out/tag-out procedures for energy isolation of equipment being worked on, procedures for the safe removal of hazardous materials before opening of process piping/equipment, hot work permit procedure to safely manage spark-producing activities, and confined space entry procedures for work performed in confined spaces. Contractor Safety - Torch, in following OSHA's PSM Guidelines, has established a screening process so they hire only contractors who accomplish the desired tasks without compromising safety when working around or in the natural gas processing system. Torch also has a written Contractor Safety Procedure to ensure that the actions or operating conditions of contract workers do not compromise the safety of employees, the community, or the contract workers themselves. 1.6 Chemical Specific Prevention Steps In addition to implementation of the PSM elements, Torch has implemented specific safety features for the preventio n, detection and control of releases of regulated (and other) substances at the Santa Clara Valley Gas Plant. The following is some of the control and detection equipment located in and around the facility to minimize the risk of an accident involving hazardous materials at Santa Clara Valley Gas Plant: 7 Relief and/or safety valves 7 High temperature alarms and/or shutdowns 7 Flame detectors 7 Combustible Gas Detectors 7 Smoke Detectors 7 Fire Protection System 7 Emergency Shutdown Systems (ESD) 7 Leak Detection System 1.7 Five-Year Accident History The Santa Clara Valley Gas Plant have had no incidents with off-site impacts involving a regulated substance as defined in the regulation in the past five years. 1.8 Emergency Response Program Summary Torch has developed written emergency response procedures to address all elements that may be encountered during planning, responding or following up to an emergency at the Santa Clara Valley Gas Plant. The plan consists of proce dures for responding to releases of regulated substances including the possibility of fires or explosions. The procedures address various aspects of emergency proper first-aid and medical treatment for exposures, notification of local emergency response agencies, evacuation plans for the Santa Clara Valley Gas Plant and accounting for facility personnel after an evacuation, and post-incident cleanup/decontamination requirements. In addition, the Santa Clara Valley Gas Plant has procedures that address the maintenance, inspection, and testing of emergency response equipment and alarms. Application of the emergency response procedures ensures compliance with OSHA Standard 29 CFR 1910.38 (Emergency Action Plans), and the emergency response element of PSM. The basic concepts of these emergency procedures are to provide a comprehensive approach for managing emergencies. The four elements of this approach are prevention, preparedness, response, and recovery. 1.9 Planned Changes to Improve Safety In order to increase safety and mitigate releases to the atmosphere, Torch plans to install a flare system for complete combustion of all fugitive gas releases from the plant due to compressor shutdowns and vapor vented from the vessels during process upsets. Torch has received an Authority to Construct Permit from the Ventura County Air Pollution Control District to install the flare. Installation is anticipated to occur within the next 6 to 12 months (late 1999 to mid-2000). California Accidental Release Prevention (CalARP) Program CERTIFICATION STATEMENT Facility Name: Torch Operating Company - Santa Clara Valley Gas Plant "To the best of my knowledge, information and belief, formed after reasonable inquiry, the information submitted is true, accurate, and complete." Mr. John Deacon Signature Print Name Manager ES & RC Title Date |