East Texas Gas Plant - Executive Summary

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East Texas Gas Plant 
Avinger, Texas 
Introduction and Policies 
Under the Koch Environmental Excellence Program (KEEP) at Koch Industries, Inc., we are committed to being associated with unmatched environmental performance as measured by our employees, customers, regulators, and the public.  Our KEEP management philosophy goals are achieved by the personal commitments of our employees and contractors, and by open communication with our employees, customers, neighbors, and with regulators. The accidental release prevention and emergency response programs we have at our facilities are part of the high standards we strive for through KEEP.  Our high standards are achieved by operating in compliance with all required environmental permits and regulations, by operating and maintaining our assets in such a manner that any unpermitted release will be unintentional and acknowledged as unacceptable, by r 
emedying any shortcomings found during regular audits of our facilities, and by reporting promptly to regulators any shortcomings found during the course of our audits as required by law. 
The East Texas Gas Plant is one of many facilities operated by Koch Midstream Services Company (Koch).  At the facility, we receive wellhead gas from wells via a pipeline.  We separate the liquid hydrocarbons out by employing the cryogenic/turbo-expander/demethanizer process.  The demethanized residue gas is either sold to customers as low pressure gas or recompressed employing five reciprocating compressors for sale to customers as high pressure gas.  The liquid hydrocarbons (Natural Gas Liquids or NGL) separated in the cryogenic/turbo-expander/demethanizer process are fed into a fractionation process.  In the fractionation process, propane, butane, and natural gasoline are separated off from the De-ethanizer tower bottom and are sold to third party customers.  The following flammable substances reg 
ulated under the Risk Management Program (RMP) are stored at the facility: propane, butane, and a flammable mixture (Natural Gas Liquids). There are no toxic substances present at the plant.  The facility is classified as Program Level 3 under the regulation.  The purpose of this Risk Management Plan (RMPlan) is to provide information about our operations at the facility, our programs to prevent accidental chemical releases, our emergency response plans in case an accidental release should occur, our 5 year accident history, and our planned changes to improve safety at the facility. 
Worst Case and Alternative Release Scenarios 
As specified by the U. S. Environmental Protection Agency (EPA) RMP Regulations, our worst case release scenario for flammables would be the loss of all of the propane in our largest vessel causing a vapor cloud explosion.  In the case of the East Texas Gas Plant, this would involve our 43,000 gallon propane tank.  Such a scenario is highly unlikely, however 
, using the EPA Offsite Consequence Analysis (OCA) methods, the distance that the resulting vapor cloud explosion could cause an overpressure of 1 psi would be approximately 0.5 miles (approximately 2,600 feet).  An overpressure of 1 psi is EPA's threshold for measurable impacts.  Although we have numerous controls to prevent such releases (high level alarms, emergency shutdown and others) and to manage their consequences, no credit for any controls or mitigation measures was taken into account when evaluating this scenario.  The alternative release scenario, characterized as a more likely scenario that would involve offsite consequences, is calculated to reach approximately 0.3 miles (approximately 1,600 feet) from the release point.  This distance calculation is also based on the EPA OCA methods, which are known to overpredict the impact of any potential release from such a scenario.  We have selected the alternative release scenario based on a release from our propane bullet due to  
a failure of the 4" relief valve on the vessel.  We have several mitigation measures in place to greatly reduce the chance that such an event could ever occur.  These measures include the following: 1) We carryout periodic inspection and testing of all the relief valves;  2) We keep the operating pressure of the bullet at well below the set pressure of the relief valve;  3) We continuously monitor the liquid level in the bullet from our control room;  4) We provided a sight glass on the bullet for visual observation of the liquid level; and  5) We provided an automatic emergency shutdown switch to shutdown the entire facility in case the liquid level in the bullet gets too high.  The presence of these mitigation measures serves to either prevent this scenario from occurring or to minimize its impact if it does occur. 
We have discussed these potential hydrocarbon releases with our employees and with local emergency response officials in Marion County, thereby further reducing the possi 
bility of any impact on the public.    
Prevention Program 
The East Texas Gas Plant has been operating under the strict guidelines of the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) Program since 1992.  Our ongoing analysis of the potential hazards of our process, detailed training of our employees, and constant emphasis on safety have helped us avoid any serious accidents over the last 5 years.  Part of this program has also involved identifying and taking steps to avoid potential accidental chemical releases.  A few examples of the additional prevention features implemented at this facility include: 
7 We installed Lower Explosive Limit monitors in the facility with a provision to automatically shutdown the entire facility when the facility is unmanned from 12 AM to 6 AM. 
7 An ESD will shutdown all the pumps in the facility when the facility is unmanned from 12 AM to 6 AM. 
7 We keep our flare continuously lit in order to ensure uninterr 
upted combustion of vented hydrocarbons. 
7 We provided fire extinguishers throughout the facility for extinguishing incipient fires. 
These safeguards as well as the vigilance of our trained employees have helped us operate safely at this facility since we acquired it in 1998. 
Five Year Accident History 
One incident having resulting in onsite or offsite impacts from a hydrocarbon release has occurred at the East Texas Gas Plant within the last five years.  An explosion and a flash fire occurred on October 7, 1994 due to release of hydrocarbon vapors from a process vessel during a hot job.  This explosion resulted in injury to a Koch employee.  Subsequent to the accident, improved maintenance procedures were implemented at the facility in order to prevent the recurrence of such accidents.  
Emergency Response Program 
We will continue to conduct emergency response preparedness activities and coordinate any emergency response actions necessary for the East Texas Gas Plant wit 
h the Avinger Volunteer Fire Department.  Also involved in emergency response for the facility would be the Mims Volunteer Fire Department, the Marion County Sheriff, the Good Shepherd Medical Clinic at Jefferson, Flight for Life Emergency Medical Services at Tyler, and the Texas Department of Public Safety.  The East Texas Gas Plant Manager is responsible for coordinating all emergency actions.  A specific Emergency Response Plan for the facility is in place and that plan has been coordinated with local officials, along with evacuation procedures, regular drilling, and training.  Our Emergency Response Program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. 
Planned Changes to Improve Safety 
Diligent compliance with our RMP Prevention Program forms the framework on which we will continue to improve the level of safety at the East Texas Gas Plant.  Some of the key components of the safety im 
provements we expect to achieve are as follows: 
7 The Management of Change provisions ensure that we consider the potential safety and health impacts of any change we make to process chemicals, technology, equipment or procedures. 
7 The Process Hazard Analysis (PHA) provisions serve as a tool to ensure continual evaluation of potential hazards, thereby leading to continual improvements in our safety standards. 
7 The Mechanical Integrity provisions ensure that process equipment and instrumentation are designed, constructed, installed and maintained to minimize the risk of hazardous releases, thereby serving as an integral part of our safety program. 
7 Internal and third party compliance audits will ensure we maintain and increase our level of safety protection. 
7 An ongoing dialogue with the Marion County Emergency Management Director or his designate will ensure a constant state of readiness to respond to any potential emergencies, as well as a means to implement improvements as the n 
eed develops.  In this way, we shall bolster our strong commitment to the safety of our workers and the community. 
We encourage all interested citizens or community organizations to contact the Marion County Emergency Management Director for the latest information on emergency response for the county.  We plan to diligently integrate our response capabilities and personnel with those of the county on an ongoing basis.
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