Stocker Resources - Montebello Gas Plant - Executive Summary |
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1.0 EXECUTIVE SUMMARY 1.1 Accidental Release Prevention and Emergency Response Policies It is the policy of Stocker 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, Stocker strives to operate its facilities in compliance with applicable federal, state, and local safety, health, and environmental regulations. Stocker's emergency response policies are implemented to comply with the overall Stocker 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 must have priority. Only then can safely executed rescue and medical activities be considered. Another priority is protection of the environment. Only after life, safety, and environmental concerns are addressed will t he focus shift to the secondary issues of property conservation and business recovery. 1.2 Facility Description Montebello is located in the Los Angeles Basin, approximately 20 miles inland from the Pacific Ocean and approximately 13 miles south of the San Gabriel Mountains. The elevation of the gas plant site varies from about 450 to 480 feet above sea level. The nearest earthquake faults are the Elysian Park Fault, approximately 2 miles to the northwest and the Whittier Fault, approximately 5 miles to the southeast. The Elysian Park Fault produced the 5.9 magnitude Whittier Narrows earthquake of 1987. The Whittier fault has not experienced any significant movement in recent times. The approximate coordinates of the plant are longitude 1180 05' 06" west and latitude 340 02' 00" north. The gas plant is located in an open elevated area as shown on D-3778 (Appendix A) at the SRI Montebello facility, 1400 North Montebello Boulevard. The area is bounded on the north and west by Mon tebello Boulevard, on the south by Los Amigo Avenue, and on the west by Lincoln Avenue and San Gabriel Boulevard. The nearest major highway is State Route 60, the Pomona Freeway, approximately 0.4-miles to the north. A map of the area is shown in Figure 1-1. The nearest residential area, Los Amigos Avenue, is approximately 0.46-miles (2,400 feet) to the southwest. The Montebello Town Center Mall is approximately 0.23-miles (1,200 feet) to the north. These are considered public receptors under the RMP regulation. There are no residential or designated environmental receptors nearby. The 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 Administration (OSHA's) Process Safety Management (PSM) standard under federal (codified at 29 CFR 1910.119), or state OSHA programs. A process flow diagram o f the gas plant is shown in Figure 1-2. A block flow diagram of the Montebello Gas Plant is contained in Appendix A along with applicable piping and instrument diagrams (P&IDs). The gas plant is designed to convert and recycle approximately 2.0 MMSCF/day of sweet field gas into 1.846 MMSCF/day of pipeline quality sales gas and 953 gal/day of natural gas liquids (propane, butane, natural gasoline, and heavier alkanes). A diethanolamine (DEA) CO2 removal unit removes excess CO2 from the gas prior to final compression, treating, and shipping. Since the sweet field gas contains only 1 ppm H2S, the DEA will remove these small quantities of H2S. Major process steps include the following: a) First stage compression and dewatering (1.3 psig to 36.3 psig); b) Second stage compression and dewatering (36.3 psig to 150 psig); c) DEA CO2 and H2S removal and odor control; d) Third stage compression and dewatering (150 psig to 475 psig); e) NGL separation, storage, and shipping (LTS Unit); f) Sales gas metering skid assembly; and g) Gas metering skid assembly. The two natural gas liquids (NGL) storage tanks each have a working capacity of 3,500 gallons, or approximately 17,500 pounds of mixed NGL (natural gasoline, propane, butane). Mixed NGL contains ethane (trace), propane (2%), butane (5.5%), and natural gasoline (92.5%) with an average density of 5 pounds per gallon. 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: 700 pounds stored at 121 psig; b) Liquefied butane gas under pressure: 1,900 pounds stored at 121 psig; and c) Liquefied natural gasoline under pressure: 32,400 pounds stored at 121 psig. 1.4 Summary of Offsite Consequence Analysis Results The Offsite Conse quence Analysis (OCA) was performed with the RMP*Comp version 1.06 consequence analysis program. The nearest public receptor is about 1,200 feet away. There are no residential or designated environmental receptors nearby. 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 assum es a worst-case catastrophic (instantaneous) release of all NGL stored in one of the two NGL bullets each having a maximum capacity of 3,500 gallons, or approximately 17,500 pounds of mixed NGL. The worse-case release scenarios identified off-site impacts, but the impact area includes only marginal public and no residential or environmental receptors. For a hypothetical worst-case vapor cloud explosion, the estimated distance to 1 psi overpressure is approximately 1,100 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 throttled (line break) release of all NGL stored in the two NGL vessels over a period of 10 minutes. The NGL bullets have a combined maximum c apacity of 7,000 gallons, or approximately 35,000 pounds of mixed NGL. The alternate-case release scenario also identified off-site impacts, but the impact area included no public, residential, or environmental receptors. For the hypothetical alternate-case vapor cloud explosion, the estimated distance to 1 psi overpressure is approximately 700 feet. 1.5 Summary of Accidental Release Prevention Program In addition to being subject to RMP requirements the Montebello 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 Montebello 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, Stocker 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) 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 re leases 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 th e company's PSM program a PHA has been conducted for the Montebello 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, Stocker is required to perform a pre-startup safety review for new facilities, and for modified facilities when the modifi cation is significant enough to require a change in the process safety information. Although the processes at the Montebello 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 Stocker 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 Stocker'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, Stocker 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 - Stocker has developed written procedures to include employees in the development, implementation and management of these PSM program elements. Hot Work & Safe Work Practices - Stocker 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 proc ess 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 - Stocker, 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. Stocker 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, Stocker has implemented specific safety features for the prevention, detection and control of releases of regulated (and other) substances at the Montebello Gas Plant. The following is some of the control and detection equipment located in and around the facilit y to minimize the risk of an accident involving hazardous materials at the Montebello Gas Plant: * Relief and/or safety valves * High temperature alarms and/or shutdowns * Flame detectors (fire-eyes) * Combustible Gas Detectors * Smoke Detectors * Fire Protection System * Emergency Shutdown Systems (ESD) * Leak Detection System 1.7 Five-Year Accident History Since the gas plant is new construction, there are no prior incidents. 1.8 Emergency Response Program Summary Stocker 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 Montebello facility. Application of the emergency response procedures ensures compliance with OSHA Standard 29 CFR 1910.38 (Emergency Response Plans) and the emergency response element of PSM. The basic concept of Stocker's emergency procedures are to provide a comprehensive approach for managing emergencies. The four elements of this appro ach are prevention, preparedness, response, and recovery. The ERP is designed to be applicable to any type of emergency that may affect Stocker and based on the concept that the elements of emergency response are similar, regardless of the hazard. The ERP comprises the following sections: 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 Stocker'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. Stoc ker'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 Brief site-specific written operating procedures have been developed for the NGL chiller-separator system and NGL storage and transfer system, including truck loading (see PHA document). 1.10 Documents Incorporated by Reference The following documents are the basis for the RMP program and are incorporated by reference: 1. Seismic Ground Acceleration Evaluation for the Montebello Gas Plant, Rincon Consultants, June 1999. 2. Construction Detail Drawings and Seismic Calculation Package for the Montebello Gas Plant, Stocker Resources & Vanson Engineering, May 199 9. 3. Montebello Gas Plant Job Books Volume I, Stocker Resources & Vanson Engineering, May 1999. 4. Montebello Gas Plant Process Hazard Analysis for Compliance Year 1999, Sierra-Pacific Environmental, June 1999. 5. Emergency Response Plan - Environmental/Safety, Stocker Resources, May 1998. 6. Process Safety Management, Stocker Resources. 7. Injury & Illness Prevention Program, Stocker Resources. |