Casper Gas Plant - Executive Summary
RISK MANAGEMENT PLAN |
KN Energy, Inc.
Casper Gas Plant
PROJECT NO. 24997004
May 10, 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 policy seeks to implement a
ppropriate 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 the Casper 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 Liquid (NGL) that is an aliphatic and aromatic hydrocarbon mixture. The flammable regulated chemicals contained in the mixture include methane, ethane, propane, isobutane, N-butane, isopentane and N-pentane. These regulated f
lammable chemicals have a regulated threshold quantity of 10,000 pounds (lbs.).
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 3 flammable substances assumed the release was the total quantity of one of the bulk storage tanks 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 indicates that the Facility has offsite consequences.
After considering possible ARSs, a release involving a vapor cloud fire of NGL from a rupture in a 2-inch steel pipe connected to the NGL bu
lk storage tank was selected. The ARS distance to endpoint for the above-described release was calculated at less than 0.1 miles from the Facility.
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 maintains process safety information that describes the chemical hazards associated with regulated substances 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 and hazard analyses to identify and control the hazards associated with the process. 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 processes.
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 independ
ently. Refresher training is provided every three years 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. Mechanical Integrity
KN performs maintenance checks on the Facility equipment to ensure proper functions. Qualified personnel carry out maintenance operations. KN inspects the bulk storage vessels, pipes, valves, gauges, compressors and pumps on a regular basis. 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 outlined in the Emergency Response Plan before initiating work.
1.4.5. Compliance Audits
KN conducts audits on a regular basis to determine whether the pro
visions 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 the 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 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, safety inspections, management of change procedures and incident investigations will identify changes to improve safety. KN has a continued commitment to update equipment and i
mprove safety regarding the covered process when necessary.