Ellwood Onshore Treatment Facility - Executive Summary |
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1.0 EXECUTIVE SUMMARY 1.1 Accidental Release Prevention and Emergency Response Policies It is the policy of Venoco that its employees, environment, property, and the general public be protected from any harm that may occur as a result of its operations. To achieve this end, Venoco strives to operate its facilities in compliance with applicable federal, state, and local safety, health, and environmental regulations. Venoco implements its emergency response policies to comply with the overall corporate policy of providing its workers with a safe workplace and of minimizing risk to the public. The safety of emergency and non-affected personnel is the highest priority; therefore, all procedures must be implemented in the appropriate manner (e.g., safely executed rescue and medical activities). Protection of the environment is also a high priority. Once the issues of life, safety, and the environmental are addressed, the secondary issues of property conservation and business recov ery may be considered. 1.2 Facility Description The Ellwood Onshore Treatment Facility (Plant) is located west of Goleta in the southeast corner of Santa Barbara County, about 1,200 feet from the Pacific Ocean and approximately 2 miles south of the Santa Ynez Mountains. The elevation of the Treatment Plant site is about 20 feet above sea level. The nearest earthquake faults are the Mesa-Rincon Creek Fault Zone, approximately 9 miles to the west and the More Ranch-Mission Ridge-Arroyo Parida Fault Zone, approximately =-mile to the south. Other local faults include the Santa Ynez Fault and the Los Alamos-Baseline Fault Zone. The approximate coordinates of the plant are longitude 1190 54' 40" west and latitude 340 25' 43" north. The Treatment Plant is located in an open area as shown on Maps #1 and #2 (Appendix A) at the Venoco Ellwood facility, 7979 Hollister Avenue, Goleta. The area is bounded on the north by the access road (Hollister Avenue extension), on the southwest by the Pacific Ocean, and on the east by the Sandpiper Golf Course. The nearest major highway is U.S. Route 101, approximately 400 feet to the north. The Southern-Pacific Railroad parallels U.S. Route 101. A map of the area is shown in Figure 1-1. A small residential area is located above Highway 101, about <-mile (1,300 feet) the north of the plant. The Sandpiper Golf Course is adjacent to the site on the east, about 400 feet from the site boundary. A resort hotel is under construction about 2,100 feet to the west of the facility. These and U.S. 101 are considered public receptors under the RMP regulation. Figure 1-1. Area Map The Treatment Plant consists of one Program 3 process which utilizes several operations to process natural gas and natural gas liquids product. The Gas Plant qualifies for Program 3 because it is subject to the federal Occupational Safety and Health Administration (OSHA's) Process Safety Management (PSM) standard under federal (codified at 29 CFR 1910.119), or state OSHA programs. A simplified process flow diagram of the gas separation plant is shown in Figure 1-2. The Treatment Plant currently processes about 5,000 barrels per day of crude oil, 6 million cubic feet per day of sales gas, and 15,000 gallons per day of natural gas liquids (NGL) and mixed liquefied petroleum gas (LPG). A glycol dehydration unit removes excess moisture from the gas and a gas sweetening unit removes H2S from the gas prior to low temperature separation of NGL/LPG from the sales gas. Major NGL/LPG process steps include the following: a) Initial gas dehydration and desulfurization; b) Gas/NGL separation (V-118/119); c) NGL Reboiling (E-213) (currently out-of-service); d) Debutanizer (V-215/216) (currently out-of-service); e) LPG vessels (V-218/219 bullets); f) NGL vessels (V-227/228 bullets); and g) NGL/LPG Truck Loading Rack (loading pumps). Table 1-1 shows mixed NGL/LPG system capacities for determination of RMP applicability. Mixed NGL contains ethan e, propane, butane, and natural gasoline with an average density of 5.17 pounds per gallon. NGL contains natural gasoline with an average density of 5.54 pounds per gallon. Mixed LPG contains ethane, propane, and butane with an average density of 4.66 pounds per gallon. Table 1-1. NGL/LPG System Capacities NGL System Component Maximum Capacity, gal Maximum Capacity, lbs V-118/119 Separators 734 3,795 E-213 Reboiler* 0 0 V-215/216 Debutanizer* 0 0 V-218/219 LPG Bullets 50,000 233,000 V-227/228 NGL Bullets 50,000 277,000 Pumps 20 103 Loading Rack 20 103 Piping (1%) 1042 5,302 NGL System Total 101,816 519,303 * currently out-of-service Figure 1-2. Process Flow Diagram 1.2.1 Normal Operating Conditions During normal operation, the V-118/119 Separators contains about 58 gallons (300 pounds) of NGL, the E-213 Reboiler the V-215/216 Debutanizers are currently out-of-service. Table 1-2 shows the typical composition of the mixed NGL/LPG produced by the Ellwood plant. 1.3 Regulate d Substances Regulated flammable mixtures containing methane, ethane, propane, butane, iso-butane, pentane, iso-pentane, and heavier alkanes are present at the facility. Hydrogen sulfide (H2S), a regulated toxic, is present in the untreated crude oil (6,000 ppm maximum) and sour gas (20,000 ppm maximum, 13,000 ppm average) at the facility in excess of the state, but not the federal, threshold quantity under the regulation. a) Liquefied propane gas under pressure: 31,000 pounds stored at 121 psig; b) Liquefied butane gas under pressure: 120,000 pounds stored at 121 psig; c) Liquefied natural gasoline under pressure: 368,000 pounds stored at 121 psig; d) Sulfur compounds (as H2S ) dissolved in crude oil: 2,540 pounds in process; and e) Hydrogen sulfide in sour gas under pressure: 44 pounds process equipment. Table 1-2. NGL/LPG Composition Substance Weight, % Liquid Volume, % Ethane 0.03% 0.04% Propane 5.97% 7.26% Butanes 23.06% 23.63% Pentanes 27.13% 27.50% Hexanes 10.54% 9.79 % C7 - C10 33.27% 31.78% Total 100.00% 100.00% 1.4 Summary of Offsite Consequence Analysis Results The OCA was performed with the RMP*Comp version 1.06 consequence analysis program. The nearest public receptors are about 400, 1,300, and 2,100 feet away. The estimated residential population which could be impacted by releases is approximately 50, based on reconnaissance. 1.4.1 Worst-Case Scenarios The worst-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 instantaneously and ignited at the point of release. The worst-case release scenario model ed for the facility is a sudden release of the entire volume of the flammable material stored in the largest of four NGL/LPG storage vessels. The OCA assumes a worst-case catastrophic (instantaneous) release of all NGL or LPG stored in one of the two NGL or LPG bullets each having a maximum capacity of 25,000 gallons, or approximately 138,500 pounds of NGL or approximately 116,500 pounds of LPG. For toxics, the worst-case release scenario is a 10-minute release of the entire amount of toxic gas present in the process into near-calm atmospheric conditions, resulting in maximum ambient concentrations. The OCA assumes a worst-case release of 44 pounds of hydrogen sulfide over a 10-minute period into a 3.4 mph wind. The worst-case release scenarios identified off-site impacts, but the impact area includes minimal public receptors. For a worst-case vapor cloud explosion, the estimated distance to 1 psi overpressure is approximately 2,100 feet. For the worst-case toxic release, the e stimated distance to the ERPG-2 toxic endpoint is also approximately 2,100 feet. These endpoint zones include part of the golf course and some residences. However, the hotel boundary coincides with the edge of the 2,100-foot endpoint zones. For the toxics worst-case scenario, some residents of the area to the north could experience a strong odor and possibly eye irritation, with the potential for adverse, but not permanent, health effects. On the west, at the resort hotel currently under construction, guests could also experience a strong odor and possibly eye irritation, but no permanent health effects. This is because the hotel boundary (2,100 feet from the plant) coincides with the 30 ppm for 1-hour toxic endpoint, which is the ERPG-2 limit for causing health effects in the general population. The same would be true for golfers on the golf course. General health effects information is provided in Section 2.6.3. 1.4.2 Alternate-Case Scenarios The alternate-case release scena rio for flammables is a 10-minute release of flammable materials in two vessels which results in an attenuated vapor cloud explosion. The OCA assumes an alternate-case throttled (line break) release of all NGL or LPG stored in two NGL or LPG vessels over a period of 10 minutes. For toxics, the alternate-case release scenario is a 10-minute release of the entire amount of toxic gas present in the process into breezy atmospheric conditions, resulting in attenuated ambient concentrations. The OCA assumes alternate-case release of 44 pounds of hydrogen sulfide over a 10-minute period into a 6.7 mph wind. The alternate-case release scenarios also identified off-site impacts, but the impact area includes minimal public receptors. For the alternate-case vapor cloud explosion, the estimated distance to 1 psi overpressure is approximately 1,900 feet. For the alternate-case toxic release, the estimated distance to the ERPG-2 toxic endpoint is approximately 500 feet. The flammables endpoint zone includes only part of the golf course and some residences. The toxics endpoint zone include only part of the golf course and no residences. The hotel boundary lies beyond both the flammables and toxics endpoint zones. For the toxics alternate-case scenario, there would be no offsite impact of a hydrogen sulfide release on the small residential area and the resort hotel other than odor problems with no toxic side effects. The golf course impact would be minimal, effecting only about 100 feet of the western boundary area. Effects would be limited to a strong odor and possibly eye irritation, with the potential for adverse, but not permanent, health effects, consistent with the 30 ppm for 1-hour ERPG-2 toxic endpoint for causing health effects in the general population. General health effects information is provided in Section 2.6.3. 1.5 Summary of Accidental Release Prevention Program In addition to being subject to RMP requirements the Ellwood Onshore Treatment Facility is subject to the federal Occupational Safety and Health Administration (OSHA) Process Safety Management Program (PSM). Through compliance with the PSM standard (with minor additions), the Ellwood Onshore Treatment Facility has implemented the requirements of the Program 3 prevention program. Compliance with PSM's comprehensive program ensures the integrity of the processes which handle flammable or toxic materials. The objective of the PSM Program is to prevent unwanted releases of hazardous chemicals. To control these types of hazards, Venoco has developed the necessary expertise, experiences, judgement and proactive initiative within their workforce to properly implement and maintain an effective PSM program. An effective PSM program requires a systematic approach to evaluating the whole chemical process. Using this approach the following components were considered in the evaluation: 1) the process design; 2) process technology; 3) process changes; 4) operational and mainten ance activities and procedures; 5) non-routine activities and procedures; 6) emergency preparedness plans and procedures; 7) training programs; and 8) other elements that affect the process. 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. PSM 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 pertai ning 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 or toxic materials. 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 or toxic materials. As part of the company's PSM program a PHA has been conducted for the Ellwood Onshore Treatment Facility. 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 Trainin g - Personnel performing specific tasks which affect the natural gas processing system must be qualified to perform their assigned tasks. The company utilizes 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 or toxic 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 f ully 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, Venoco 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 Ellwood Onshore Treatment Facility 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 Venoco 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, including 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 Venoco'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, Venoco has an incident investigation program which requires the investigation of each incident that resulted in, or could have reasonably r esulted in, release of a flammable or toxic material. Employee Participation Plan - Venoco has developed written procedures to include employees in the development, implementation and management of these PSM program elements. Hot Work & Safe Work Practices - Venoco has established safe work practices in place to ensure worker and process safety. 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 - Venoco, 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. Venoco also has a written Con tractor 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, Venoco has implemented specific safety features for the prevention, detection and control of releases of regulated (and other) substances at the Ellwood Onshore Treatment Facility. 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 the Ellwood Onshore Treatment Facility: 7 Relief and/or safety valves 7 High temperature alarms and/or shutdowns 7 Flame detectors (fire-eyes) 7 Combustible Gas Detectors 7 Smoke Detectors 7 Fire Protection System 7 Emergency Shutdown Systems (ESD) 7 Leak Detection System 7 Hydrogen Sulfide Detectors and Monitors 1.7 Five-Year Accident History Since the Ellwood O nshore Treatment Facility is a recent acquisition for Venoco, there are no known EPA reported incidents, system failures or abnormal conditions due to a malfunction involving a release of flammable or toxic gases involving injuries during the past five years. There have been, however, visits to the site by the Fire Department because of calls made to the Fire Department and other county agencies by some local residents regarding odor complaints caused by small releases of sour gas containing hydrogen sulfide. Documentation of gas releases is maintained as required by the Santa Barbara County Air Pollution Control District. In the event of an accident at the Ellwood facility, all personnel would follow the emergency response procedures outlined in the Emergency Response Plan. Following an accident, including a hydrogen sulfide release, an accident investigation team will conduct the post-accident inquiry. The procedures for this investigation are outlined in the Accident and Repo rting Manual and the Loss Prevention Policy and Procedures Guide. 1.8 Emergency Response Program Summary Venoco developed written emergency response procedures to address all elements that may be encountered during planning, response or follow-up of an emergency at the Ellwood facility. Application of the emergency response procedures ensures compliance with OSHA Standard 29 CFR 1910.38 (Emergency Response Plans or ERP) and the emergency response element of PSM. The basic concept of Venoco's emergency procedures are to provide a comprehensive approach for managing emergencies. The four elements of this approach are prevention, preparedness, response, and recovery. The ERP, contained in the Business Plan, is designed to be applicable to any type of emergency that may affect Venoco and based on the concept that the elements of emergency response are similar, regardless of the hazard. The ERP addresses the following required topics: 1. Agency Interface and Response Planning; 2. P ublic and Agency Notification; 3. Emergency Medical Care; 4. Emergency Response Actions; 5. Emergency Equipment; 6. Emergency Response Training; 7. Incident Command System; and 8. Plan Review and Update. In cases where the hazard requires a response that is unique and not covered by other elements, the ERP contains certain hazard-specific information. Procedures for responding to the following emergencies are included in Venoco's emergency response procedures: a) Hazardous substance spill or release of flammable or toxic liquids or gases; b) Fires; c) Personnel injuries; d) H2S releases; e) Storm drain or sewer spill incidents; and f) Bomb threats. Venoco's emergency response procedures serve as a guide for emergency control staff, company personnel, emergency assistance groups and law enforcement agencies that may be called upon to participate in controlling an emergency within the facility and surrounding areas. These procedures include employee notification of emergencies and evacuation procedures for all emergency situations. 1.9 Planned Changes to Improve Safety In response to recent odor complaints, the facility is implementing odor reduction measures in cooperation with the Santa Barbara County APCD. 1.10 Documents Incorporated by Reference The following documents are the basis for the RMP program and are incorporated by reference: 1. Offshore Business Unit Management of Change Program, Venoco, January 1999. 2. Ellwood Onshore Treatment Facility Business Plan (Hazardous Materials Unified Program), Venoco, April 19, 1999. 3. Oil Spill and Emergency Contingency Plan, Venoco, 1999 (current version). 4. Waste Management Plan, Venoco, 1999 (current version). 5. Corporate Health and Safety Policies and Procedures, Venoco, 1999 (current version). 6. SPCC Plan for the Ellwood Facility, Venoco, 1999 (current version). 7. Risk Management and Prevention Program Technical Document - Ellwood Onshore Treatment Facility, Tracer ES&T, Revision 3, August 30, 1997. 8. Emergency Response Plan, Mobil E&P 9. Accident and Reporting Manual, Mobil E&P 10. Loss Prevention Policy and Procedures Guide, Mobil E&P 11. Hydrogen Sulfide Associated Information and Reference Material, Secorp Industries 12. Electronic NIOSH Pocket Guide to Chemical Hazards, Industrial Hygiene Services, Inc. 7.0 CERTIFICATION Venoco Ellwood Onshore Treatment Facility RMP EPA ID: CAT080011307 "To the best of my knowledge, information and belief, formed after reasonable inquiry, the information submitted is true, accurate, and complete." (signed) Steve Greig Environmental Manager Signature Title June 21, 1999 Date |