Beaver Creek Gas Plant - Executive Summary

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Accidental Release Prevention and Response Policies 
The Beaver Creek Gas Plant has a commitment to worker and public safety. This commitment is shown by the resources invested in accident prevention such as training and safety design, installation, operation, and maintenance of processes. Mercury will implement reasonable controls to prevent foreseeable releases of regulated substances. If a release does occur, gas plant trained personnel will respond to control and contain the release. 
Description of the Stationary Source and Regulated Substances 
The Beaver Creek Gas Plant located at 8892 West 7 Mile Road, Grayling, Michigan, operates a cryogenic plant to produce petroleum products (e.g. natural gas liquids, butane, propane. etc.) from natural gas. The Beaver Creek Gas Plant produces two (2) regulated flammable substances. The plant uses propane as the cryogenic fluid while producing ethane and propane as saleable products. 
Offsite Consequence Analysis Results 
The worst case scenario (WCS) associated with the release of flammable substances in Program Level 2 at the gas plant is a vapor cloud explosion (VCE) involving the full inventory of the storage tank containing natural gas liquids by refrigeration. This WCS would release 95,000# of ngl (80% volume of the storage vessel). The major constituent is propane. The maximum distance to the 1-psi endpoint is .3 miles. 
The alternate release scenario (ARS) for flammable substances at the gas plant is a BLEVE resulting from the release of ngl from a line break and the resulting vaporization and ignition of the refrigerated liquids. It was assumed that all ngl in storage would be released. The release would not be expected to be isolated by the operators due to the plant's remote location. Upon arrival, operators would employ the emergency shut down (ESD) devices at the refrigeration plant to control any further problems. 
General Accidental Release Prevention Programs 
The following is a summary 
of the accident prevention program in place at the plant. The plant is regulated by the Environmental Protection Agency's (EPA) Risk Management Plan and is not subject to the Occupational Safety and Health Administration's (OSHA) process safety management (PSM) standard. The following summary addresses the management system in place. 
Employee Participation 
The Beaver Creek Gas Plant encourages employee's participation in all facets of safety and accident prevention. Regular safety meetings are held with plant personnel and field personnel in acquaint them with safety at the various facilities operated by Mercury. Employees have access to all information concerning the plant's operation, field operations, chemicals used, emergency procedures, location and use of material safety data sheets (MSDS) and first aid. 
Process Safety Information 
The Beaver Creek Gas Plant keeps a variety of technical documents that are used to help maintain safe operation of the processes. The documents ad 
dress chemical properties and associated hazards and equipment design information.  
Chemical information is provided by the use of MSDS sheets. The plant ensures process maintenance using process controls, trained personnel, and automatic shut down devices. 
The gas plant also maintains numerous technical manuals that provide information about the design and construction of process equipment. This information includes materials of construction. Designs pressure and temperature ratings, and electrical rating of equipment. This information, in combination with written operating procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluation proposed changes to ensure safety is not compromised. 
Process Hazard Analysis (PHA) 
The Beaver Creek Gas Plant has a program in place to help ensure that hazards associated with the various processes are identified and controlled. The program requires each process be examined to i 
dentify potential hazards and ensure controls are in place to manage these hazards. 
The Beaver Creek Gas Plant primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The analyses are conducted using people who have operating and maintenance experience. These personnel identify and evaluate hazards of the process as well as accident prevention and mitigation measures. Suggestions or additional written procedures or controls are made when these actions are believed necessary. 
The finding of the HAZOP are forwarded to local and corporate management for resolution. Implementation of options is based on relative risk factors assigned during the HAZOP study. This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. 
To help ensure that process controls do not deviate significantly from the  
original safety features, the plant periodically updates and revalidates the HAZOP results. These reviews are conducted every 5 years and will continue at this rate until the plant is dismantled. The result of these findings are documented and retained. Management is forwarded copies of the findings are responsible for their resolution. 
Operating Procedures 
The beaver Creek Gas Plant maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) emergency shutdown and (4) normal shutdown. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. These procedures are periodically reviewed and certified as current and accurate.  
New employees receive basic training in gas plant operations even if they are already familiar with such operations. After demonstrating adequate knowledge of the processes and ability to work in a safe mann 
er, they are allowed to work on their own independently. In addition, all operators periodically receive refresher training to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every 3 years. All training is documented and the verification methods (tests) kept on file for each operator. 
Contractors may be used during times of heavy maintenance or change out of critical pieces of equipment. Contractors are allowed to work on or near the gas plant only while supervised by a plant operator. Contractors are informed of procedures and are instructed to discuss all operations before beginning said operations. Plant operators are instructed to observe contractors to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what to do in the event of an emergency, and (5) understand and foll 
ow site safety rules. Mercury evaluates contractor safety programs and performance during the selection of a contractor for work at the gas plant. 
Pre-startup Safety Reviews (PSSRs) 
The Beaver Creek Gas Plant conducts a PSSR for any new facility or 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 prepared for startup prior to placing the equipment into service. The PSSR includes a field verification of the construction against drawings. 
Mechanical Integrity 
The Beaver Creek Gas Plant has established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps, compressors, and emergency shutdown systems in safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing written procedures, (3) correcting identified deficiencies, and (5) applying quality assurance measu 
res. In combination, these methods form a system that maintains system integrity. 
Plant operators visually inspect and report deficiencies to management. If a deficiency is identified, employees will correct the deficiency before placing the equipment back in service. If unable to correct the problem, the plant will be shut down until repair or replacement is finished. 
Safe Work Practices 
The Beaver Creek Gas Plant has safe work practices in place to help ensure worker and process safety. Examples of these include (1) a lockout/tagout procedure, (2) a procedure for safe removal of hazardous substances before process piping or equipment is opened, (3) a hot work permit program, and (4) a confined space entry program.  
Management of Change 
The Beaver Creek Gas Plant is a self-contained cryogenic liquid plant requiring the use of special metals and equipment. Change to any part of the equipment or processes require careful control of these changes. A management of change authorizatio 
n form is required if the equipment will not be "changed in kind". Change in kind requires that the same size, metallurgy, seals, relief valve, fittings, and connection devices be used as the original equipment. Any other change requires management approval along with safety and engineering approvals. 
Incident Investigation 
All incidents are required to be reported to management. This includes any incident that could cause personal injury, release of toxic/flammable chemicals, minor and major property damage, or environmental loss. The goal of such investigations is to determine the facts of the incident and develop procedures to prevent future re-occurrence. All employees are informed of the incident and findings and recommendations are tracked until final resolution. Records are maintained for a minimum of 5 years. Records are used as part of PHA revalidation. 
Compliance Audits 
Compliance audits are conducted at least every 3 years to ensure that procedures and programs are funct 
ioning properly. Employees and outside contract personnel may be used to determine if procedures are followed and if additional procedures are needed. Corrective actions are followed by management until resolution. 
Five Year Accident History 
The Beaver Creek Gas Plant has an excellent record of accident prevention over the past five years, There have been zero accident involving release of ngl or propane at the plant. 
Emergency Response Program Information 
The Beaver Creek Gas Plant maintains a written emergency response program to protect workers and public safety as well as the environment. The response program provides procedures for responding to releases of regulated substances, including the chance of fire or explosion. The procedures address aspects of emergency response, first aid and medical treatment for exposures, maintenance of MSDS for materials at the plant, evacuation plans and accounting for personnel after an evacuation, notification of emergency response agencies  
and the public, post -incident cleanup, and decontamination requirements. The plant has procedures for that address maintenance, inspection and testing of emergency response equipment and the proper use of the equipment. Employees receive training as necessary to perform the duties to which they are assigned. The emergency response program is updated as modifications are made to processes or other plant facilities. 
The Beaver Creek Gas Plant has around the clock communications capability with its employees who respond to any incident. The Beaver Creek Volunteer Fire Department will be called if needed and will be coordinated in the response by activating an incident command system. 
Planned Changes to Improve Safety 
The Beaver Creek Gas Plant updates and makes changes to its programs as needed to improve safety. Safety audits and incident investigations are used to make continuous improvements. In addition, The following items for change are planned for the future. 
* Revisions to pe 
rsonnel training programs 
* Involvement of the local emergency planning committee (LEPC) 
* Annual refresher training with the local volunteer fire department 
* Maintaining minimum amounts of ngl in storage 
* Continuing to revise the emergency response manual to add information as new facts are learned
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