Carpinteria Oil and Gas Plant - Executive Summary |
|
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 Carpinteria Oil & Gas Plant Facility is located in the extreme southeast corner of Santa Barbara County, about 600 feet from the Pacific Ocean and approximately 3 miles south of the Santa Ynez Mountains. The elevation of the Oil & Gas Plant site is about 50 feet above sea level. The nearest earthquake faults are the Mesa-Rincon Creek Fault Zone and the More Ranch-Mission Ridge-Arroyo Parida Fault Zone The approximate coordinates of the plant are longitude 1190 30' 21" west and latitude 340 23' 16" north. The Oil & Gas Plant is located in an open area as shown on E-SB-10758-2 and E-SB-10719A-1 (Appendix A) at the Venoco Carpinteria facility, 5675 Carpinteria Avenue. The area is bounded on the north by Carpinteria City Hall, on the south by the Southern-Pacific Railroad and the Pacific Ocean beyond, on the west by Dump Road, and on the east by the Brown & Serena property (Carpinteria Bluff's Development). The nearest major highw ay is U.S. Route 101, approximately <-mile (1,300 feet) to the north. A map of the area is shown in Figure 1-1. Neighboring properties are shown on a map in Appendix A. The nearest residential areas are approximately d-mile (2,000 feet) to the northwest and <-mile (1,300 feet) to the north, on the far side of Highway 101. The Carpinteria City Hall is approximately 400 feet to the north. Businesses within <-mile (1,300 feet) include an auto repair shop, two motels, and a game court. These and U.S. 101 are considered public receptors under the RMP regulation. Carpinteria State Beach is approximately d-mile (2,000 feet) to the west and is both a public and environmental receptor under the regulation. Figure 1-1. Area Map The Oil & Gas 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 Administr ation (OSHA's) Process Safety Management (PSM) standard under federal (codified at 29 CFR 1910.119), or state OSHA programs. A process flow diagram of the gas plant is shown in Figure 1-2. The Oil & Gas Plant currently processes about 4,000 barrels per day of crude oil, 9 million cubic feet per of pipeline quality sales gas, and 3,200 gallons per day of mixed natural gas liquids (NGL). A glycol dehydration unit removes excess moisture from the gas prior to low temperature separation of NGL from the sales gas. Since the field gas is naturally sweet, no desulfurization or CO2 removal unit is required. Major process steps include the following: a) Initial gas dehydration; b) Gas/NGL separation (V-101); c) NGL Reboiling (V-103); d) NGL vessels (V-20 and V-21 bullets); and e) Blending of NGL with crude oil (pumps and LACT unit). Table 1-1 shows mixed NGL system capacities for determination of RMP applicability. Mixed NGL contains ethane, propane, butane, and natural gasoline with a n average density of 5.17 pounds per gallon. Table 1-1. NGL System Capacities NGL System Component Maximum Capacity, gal Maximum Capacity, lbs V-101 Separator 734 3,795 Piping, V-101 to V-103 5 26 V-103 Reboiler 282 1,458 Piping, V-103 to bullets 96 496 V-20 NGL Bullet 15,000 77,550 V-21 NGL Bullet 15,000 77,550 Piping, bullets to pumps 103 533 Pumps 10 52 Piping, pumps to LACT 160 827 LACT 90 465 NGL System Total 31,480 162,752 Figure 1-2. Process Flow Diagram 1.2.1 Normal Operating Conditions During normal operation, the V-101 Separator contains about 58 gallons (300 pounds) and the V-103 Reboiler contains about 31 gallons (160 pounds) of mixed NGL. The current operating configuration limits one NGL vessel (bullet) to a working capacity of approximately 1,700 gallons (8,790 pounds) of mixed NGL. The other NGL bullet is empty, but remains connected to the NGL piping system with inlet and outlet valves closed. Table 1-2 shows the typical composition of the mixed NGL produ ced by the Carpinteria plant. Table 1-2. NGL Composition Substance Weight, % Liquid Volume, % Ethane 0.44% 0.75% Propane 5.77% 6.90% Butanes 22.35% 23.49% Pentanes 28.29% 29.02% Hexanes 24.23% 22.09% C7 - C10 18.92% 17.75% Total 100.00% 100.00% 1.3 Regulated Substances Regulated flammable mixtures containing methane, ethane, propane, butane, iso-butane, pentane, iso-pentane, and heavier alkanes are present at the facility. No regulated toxic substances are present at the facility in excess of the threshold quantities under the regulation. a) Liquefied propane gas under pressure: 9,400 pounds stored at 121 psig; b) Liquefied butane gas under pressure: 36,400 pounds stored at 121 psig; and c) Liquefied natural gasoline under pressure: 117,000 pounds stored at 121 psig. 1.4 Summary of Offsite Consequence Analysis Results The Offsite Consequence Analysis (OCA) was performed with the RMP*Comp version 1.06 consequence analysis program. The nearest public receptors are about 400 , 1,300, and 2,000 feet away. The nearest environmental receptor is 2,000 feet away, which is also a public receptor. The estimated residential population which could be impacted by releases is approximately 500, based on census tract information. 1.4.1 Worst-Case Scenario 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 instantaneously and ignited at the point of release. The worse-case release scenario modeled for the facility is a sudden release of the entire volume of the flammable material stored in the largest of two NGL storage vessels. The OCA first assumes a worst-case catastrophic (instantaneous) release of all NGL stored in one of the two NGL bullets each having a maximum capacity of 15,000 gallons, or approximately 77,550 pounds of mixed NGL. The worse-case release scenarios identified off-site impacts, but the impact area includes minimal public and residential receptors and no environmental receptors. For a hypothetical worst-case vapor cloud explosion, the estimated distance to 1 psi overpressure is approximately 1,600 feet. 1.4.2 Alternate-Case Scenarios The alternate-case release scenario 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 stored in the two NGL vessels over a period of 10 minutes. The OCA assumes an alternate-case I throttled (line break) release of all NGL stored in the two NGL vessels over a period of 10 minutes. Since the current operating configuration limits one NGL bullet to a working capacity of approximately 1,700 gallons (8,790 pounds) and the other NGL bullet is empty, an alternate-case II assumes a catastrophic (instantaneous) release of all NGL actually stored in one NGL bullet. The alternate-case I release scenario also identified off-site impacts, but the impact area includes minimal public and residential receptors and no environmental receptors. For the hypothetical alternate-case I vapor cloud explosion, the estimated distance to 1 psi overpressure is approximately 1,500 feet. For the alternate-case II vapor cloud explosion, the estimated distance to 1 psi overpressure is approximately 1,100 feet. The more realistic alternate-case II scenario impacts few, if any, residences. 1.5 Summary of Accidental Release Prevention Program In addition to being subject to RMP requirements the Carpinteria Oil & Gas Plant 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 Carpinteria Oil & Gas Plant 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 maintenance activities and procedures; 5) non-routine activities and procedures; 6) e mergency 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 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 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 Carpinteria Oil & 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 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 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, 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 Carpinteria Oil & 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 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 resulted 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 Contractor Safety Procedure to ensure that the actions or operating conditions of contract worke rs 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 Carpinteria Oil & 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 the Carpinteria Oil & Gas Plant: 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 1.7 Five-Year Accident History Since the Carpinteria Oil & Gas Plant is a new acquisition for Venoco (February 1, 1999), there are no known EPA reported incidents, system failures, or abnormal condit ions due to a malfunction involving a release of flammable gases involving injuries during the past five years. 1.8 Emergency Response Program Summary Venoco has developed written emergency response procedures to address all elements that may be encountered during planning, response or follow-up of an emergency at the Carpinteria 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. Public 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 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 in clude employee notification of emergencies and evacuation procedures for all emergency situations. 1.9 Planned Changes to Improve Safety The current operating configuration limits one NGL bullet to a working capacity of approximately 1,700 gallons (8,790 pounds) of mixed NGL. The other NGL bullet is not used, but remains connected to the NGL piping system with inlet and outlet valves closed. Venoco has determined that since NGL is blended with crude oil continuously and not stored for shipment, the NGL bullets can be bypassed. Venoco is studying the feasibility of decommissioning the bullets by emptying and physically disconnecting them before the end of 1999. This action would exempt the facility from RMP and PSM applicability because less than 10,000 pounds of regulated substances would be present on-site after the decommissioning. 1.10 Documents Incorporated by Reference The following documents are the basis for the RMP program and are incorporated by reference: 1. Offs hore Business Unit Management of Change Program, Venoco, January 1999. 2. Carpinteria Oil & Gas Plant 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 Carpinteria Facility and Pier, Venoco, 1999 (current version). 7. Hazard and Operability Study - Carpinteria Gas Plant, Chevron USA, 1996-97. 8. Process Safety Management Manual - Carpinteria Plant, Chevron USA, 1994-96 (incomplete). 9. Seismic Ground Acceleration Evaluation for the Carpinteria Oil & Gas Plant, Rincon Consultants, June 1999. 10. Preliminary Seismic Walk-Through for the Carpinteria Oil & Gas Plant, Process Unlimited, June 1999. 7.0 CERTIFICATION Venoco Carpinteria Oil & Gas Plant RMP EPA ID: CAL 00020275 "To the best of my knowle dge, 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 |