Williams Gas Processing - Kutz PLant - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

EXECUTIVE SUMMARY 
KUTZ PLANT RISK MANAGEMENT PLAN 
 
Accidental release prevention and emergency response policies: 
 
Williams Energy Services and the Kutz Plant are strongly committed to the protection of employees, general public and the environment. This commitment is demonstrated by the resources that the company invests in accident prevention including, personnel training, and the safe design, installation, operation and maintenance of its processes. It is the policy of Kutz plant to implement appropriate controls to prevent possible releases of regulated substances.  The plant's emergency response plan includes procedures for notification of trained personnel to respond, control and contain any releases. 
 
The Stationary Source and Regulated substances: 
 
Kutz Plant is located in San Juan county, New Mexico, = mile south of Bloomfield and 2 miles east on county Road 4980.  Kutz Plant operates a cryogenic and lean oil absorption natural gas liquids extraction process. The facility proc 
esses four regulated substances that include Methane, Ethane, Propane and Butane, all of which are extracted from the inlet natural gas stream.  Refrigerant grade propane is used in the process as a cooling medium.   
 
Worst Case Release Scenario and Alternative Release Scenarios: 
 
The worst case scenario with a release of flammable substances is a vapor cloud explosion involving 70% of storage inventory of the products tank containing natural gas liquids which is a mixture of the plant's regulated substances.  A written procedure is in place to limit the storage inventory to 179,768 lbs.  Pumps are set to keep the tank at 26-28% of full liquid height. When the level of the tank reaches 70%, an alarm will sound in the control room to initiate an investigation. A high-pressure alarm will sound before pressure relief devices start relieving. The reduced inventory is assumed to be released, ignited and result in a vapor cloud explosion.  The maximum distance to the 1psi endpoint for this w 
orst case scenario is 0.46 miles.  
 
The alternative release scenario for flammable substances is an inlet gas line that develops a bad leak at a flange, causing gas to blow and accumulate from inlet header area. The unconfined vapor travels to its lower flammability limit and ignites, the distance to the 1 psi endpoint for this scenario is 0.25 miles. 
 
General Accidental Release Prevention Program: 
 
Kutz Plant encourages employees to participate in all aspects of Process Safety Management, Risk Management and Accident Prevention.  Employee participation range from updating and compiling technical data for Operating Procedures and Process Safety information to participating as a member of a Process Hazard Analysis team.  In addition, Kutz plant has a number of initiatives that address Process Safety, Risk Management and accident prevention. These initiatives include forming teams to promote both process and personal safety. Members of the teams represent various areas and functions of t 
he plant. 
 
Process Safety Information: 
 
Kutz Plant keeps a variety of technical documents that are used to help maintain safe operation of the process.  These documents address chemical properties, associated hazards, limits for key process parameters, specific chemical inventories and equipment design basis information.  Process safety information is also used to evaluate proposed process and facility changes to ensure that safety features in the process are not compromised. 
 
Process Hazard Analysis ( PHA ): 
 
Kutz Plant has a comprehensive program to help ensure that hazards associated with the process are identified and controlled. The process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.  The PHA methods for identifying hazards include the -" what if" and "Hazop" techniques. The PHA's are conducted using a team of people who have operating, maintenance and engineering expertise.  This team identifies and evalua 
tes hazards of the process along with accident prevention and mitigating measures. The team makes suggestions for additional prevention measures when appropriate, and forwards their findings to the locations management for resolution. The findings are classified according to relative risk rankings assigned by the PHA team.  This ranking helps ensure that the potential accident scenarios that are assigned the highest risk will receive immediate attention.  All approved action items resulting from the PHA team's findings are tracked until they are completed. All PHA's, team findings, recommendations and tracking status are documented and retained. Revalidation of all PHA's is conducted on a 5-year cycle. 
 
Operating Procedures: 
 
Kutz Plant maintains written procedures that address various modes of process operations, such as (1) initial start-up,  (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) emergency operations, (6) normal shutdown, and (7) start-up after  
turnaround.  These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators.  These procedures are reviewed and verified annually to ensure they are current and accurate. 
 
Contractors: 
 
Kutz Plant uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the plant has procedures in place to ensure that contractors, (1) perform their work in a safe manner, (2) are aware of any hazards in the workplace, (3) understand what they should do in the event of an emergency, (4) understand and follow site safety rules, and (5) inform plant personnel of any hazards that they find during their work . Prior to allowing contractors to begin work they are provided with an orientation that includes,  (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements and (4) sa 
fe work practices. Kutz Plant personnel periodically conduct safety audits on contractor performance to ensure that they are working in a safe manner. 
 
Pre-startup Safety Reviews (PSSR's): 
 
Kutz conducts a PSSR on any Plant modification that requires a change in the process safety information.  The purpose of the PSSR is to ensure that safety features, procedures, personnel, and equipment are appropriately prepared for startup before placing the equipment into service.  This review provides an additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready.  The PSSR uses a checklist to verify the modification readiness, it involves field verification of the construction and serves as a quality assurance function by requiring verifications that the accident prevention program requirements are properly implemented. 
 
Mechanical Integrity: 
 
Kutz Plant has well established practices and procedures to maintai 
n pressure vessels, piping systems, relief and vent systems, controls, pumps, compressors, and emergency shutdown systems in a safe operating condition.  The basic aspects of this program include employee training, written maintenance procedures, inspection/ testing, correcting identified deficiencies and applying quality assurance measures.  Collectively, these activities form a system that maintains the Mechanical Integrity of the process. 
 
Safe Work Practices and Procedures: 
 
Kutz has established safe work practices to help ensure worker and process safety. Examples of these safe work practices include methods for controlling plant entry, presence and exit of support personnel, and lockout/ tagout procedures to ensure isolation of energy sources for equipment undergoing maintenance.  Hot work procedures and permits are used whenever the work involves the potential for generating ignition sources in the presence of flammable or combustible material. Confined space entry permits and p 
rocedures are used to ensure that adequate precautions are in place before entry is allowed into a permit required confined space.  The use of written safety procedures and safe work practices along with training of affected personnel, helps to ensure that operations and maintenance activities are performed safely. 
 
Training: 
 
The plant has implemented a comprehensive training program for all employees involved in operating a process.  New employees receive basic training in the safe operation of the process. They are then paired up with an experienced operator to learn process specific duties and tasks.  Upon completion of a testing and skill demonstration program, the operator can work independently. In addition, all operators receive refresher training every three years to ensure that their skills and knowledge are maintained at an acceptable level. All training is documented for each operator including the means used to verify that the operator understood the training. 
 
Management  
of Change: 
 
Kutz has a comprehensive system to manage changes that affect all covered processes. This system requires that change to items such as process equipment, chemicals, technology, (including process operating conditions), procedures and other facility changes be reviewed and authorized before being implemented.  Changes are reviewed to ensure that adequate controls are in place to manage any new hazards and to verify that existing controls have not been compromised by the change.  Process operating limits, equipment information and operating procedures affected by the change are updated as necessary. In addition, operating and maintenance personnel are provided any necessary training related to the change. 
 
Incident Investigation: 
 
Kutz safety committee members along with management promptly investigates all incidents that resulted in, or could have resulted in a fire, explosion, gas release, property damage, environmental loss, or personal injury.  The goal of each investigat 
ion is to determine the facts and develop corrective actions to prevent recurrence of the incident or a similar incident.  The investigation team documents its findings, develops recommendations and forwards these results to management for resolution.  The final resolution of each finding is documented and the investigation results are reviewed with all affected employees and contractors. Incident investigation reports are retained for at least 5 years so they can be reviewed during future PHA's and PHA revalidation. 
 
Compliance Audits: 
 
Kutz Plant personal conduct audits on a regular basis to ensure that the facility is in compliance with applicable RMP / PSM procedures and regulations. These audits are conducted at least every three years. All corrective actions taken in response to audit findings and recommendations are tracked until they are completed.  The final resolution of each finding is documented and the two most recent audit reports are retained at the facility. 
 
Five-year  
Accident History: 
 
Kutz Plant has had an excellent record of preventing accidental releases over the last 5 years.  As a result of the plant's stringent release prevention policies, there has not been a single release of a regulated substance. 
 
Emergency Response Program Information: 
 
Kutz Plant maintains a written emergency response program to protect employees, contractors, public and the environment from hazards associated with accidental releases of regulated substances. The program consists of procedures for responding to releases of regulated substances, including the possibility of associated fires or explosions. The procedures address all aspects of emergency response, including evacuation plans, accounting for personnel after an evacuation and notification of local emergency response agencies and the public.  Employees receive training in these procedures annually to perform emergency response duties.  The program is updated when necessary based on modifications made to the ga 
s plant processes.  
The overall emergency response program for Kutz is coordinated with San Juan Local Emergency Planning Committee (LEPC).  This coordination includes attending periodic meetings of the committee, which includes local emergency response officials and industry representatives.  Kutz has 24-hour communications capability with the San Juan LEPC. The Plant conducts periodic emergency drills that involve the LEPC and emergency response organizations. 
 
 
Planned Changes to Improve Safety: 
 
Kutz Plant in an effort to address all PHA action items has made modifications to its process. The following types of changes are planned in response to PHA, Safety Audit and Incident Investigation action items. 
X Plumb some PSV's to flare header 
X Install PSV's on some exchangers 
X Install pressure switches on compressors to detect compressor rod packing leaks
Click to return to beginning