Silo Plant - Executive Summary |
|
Risk Management Plan Union Pacific Resources SILO PLANT Cheyenne, Wyoming Executive Summary A) Accidental Release Prevention and Response Policies The Silo plant has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the release. B) Description of the Stationary Source and Regulated Substances The Silo Plant; located 25 miles northeast of Cheyenne, Wyoming (1 mile south of the intersection of county road 222 and 136); incorporates a variety of processes to produce petroleum products (e.g., natural gas, propane, butane, pentane) from oil and gas wells. The Silo Pla nt handles methane; ethane, propane, pentane and butane which are regulated flammables. It processes approximately 10 million cubic feet a day of raw natural gas and natural gas liquids. The Silo Plant does not use, process or store a reportable quantity of toxic regulated substances. C) Hazard Assessment Results The Worst Case Scenario (WCS) associated with a release of flammable materials in processes at the gas plant is a vapor cloud explosion (VCE) involving the full inventory of the largest process vessel containing 140,000 pounds of a Natural Gas Liquids (NGL) mix. The maximum distance to the 1-psi endpoint for this WCS is 0.09 miles. No passive mitigation measures were taken into account in evaluating this WCS. E) Five-Year Accident History Within the past five years the processes have not had an accidental release that caused offsite impacts provided in the risk management program rule (40 CFR 68.10(b)(1)). D) General Accidental Release Prevention Program/Chemical-Specif ic Prevention Steps The following is a summary of the accident prevention program in place at the Silo Plant. Although processes at the Silo Plant are regulated by the EPA Risk Management Program (RMP) regulation, they are not subject to the OSHA Process Safety Management (PSM) standard. This summary addresses only general safety issues and describes the management system in place to implement the accident prevention program. 1) Safe Work Practices The Silo Plant has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include: (1) lockout/tagout procedure to ensure isolation of energy sources for equipment that is being worked on (2) a procedure for safe removal of hazardous materials before process piping or equipment is opened (3) a permit and procedure to control spark-producing activities (i.e., hot work) (4) A permit and procedure to ensure that adequate precautions are in place before entry into a confined space. Thes e procedures (and others), along with training of affected personnel, form a system to help ensure operations and maintenance activities are performed safely. 2) Incident Investigation The Silo Plant promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigator documents his/her findings, develops recommendations to prevent a recurrence, and forwards these results to Southeast Colorado management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are completed. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could b e affected by the findings. 3) Compliance Audits To help ensure that the accident prevention program is functioning properly, the Silo Plant periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted approximately every 3 years. Personnel from other operating areas compose the Audit Team. Both hourly and staff personnel participate as audit team members. The audit team develops findings that are forwarded to Silo Plant management for resolution. Corrective actions taken in response to the audit teams findings are traced until they are completed. The final resolution of each finding is documented, and the two most recent audit reports are retained. 4) Summary of Process Hazards, Safety Features, and Hazard Analysis Findings The processes at the Silo Plant have hazards that must be managed to ensure continued safe operations. a) Unive rsal Prevention Activities The accident prevention program summarized previously is applied to the EPA RMP covered process at Silo Plant. This prevention program helps prevent potential accident scenarios that could be caused by (1) equipment failures and (2) human errors. b) Specialized Safety Features The Silo Plant has safety features to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in the covered processes: 1) Release Detection a. Hydrocarbon detectors with alarms. 2) Release Containment/Control a. Valves to permit isolation of the process (manual or automated) b. Automated shutdown systems for specific process parameter (e.g., high level, high temperature, high pressure) c. Curbing or diking to contain liquid releases d. Atmospheric relief devices 3) Release Mitigation a. Personal protective equipment b. Trained emergency first-responder personnel c. Spacing of equipment in accordance with IRI spacing guideline d. Emergency shutdown strategically placed in the plant to automatically shut in the inlet. Emergency Response Program The Silo Plant maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including proper first-aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post incident cleanup and decontamination procedures. The emergency response program is updated as necessary. Any significant changes to the emergency response program are identified and affected personnel are informed of the changes. The overall emergency response program for the Silo Plant is coordinated with the Laramie County Fire Department and the Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings with the LEPC, which includes local emergency response officials, local government officials, and industry representatives. The Silo plant operator has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. Planned Changes to Improve Safety Although Silo Plant Management does not believe additional safety measures are necessary to prevent offsite impacts from accident releases, it does resolve all findings from the Safety and Environmental Compliance Audits. |