Colorado Interstate Gas Co. - Sturgis Station - Executive Summary |
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In this facility, we handle natural gas and natural gas liquid. Certain components of the natural gas and natural gas liquid are considered hazardous by the EPA. The same properties that make these substances valuable as fuel also make it necessary to observe certain safety precautions when handling them. Such precautions help to prevent unnecessary human exposure, to reduce the threat to our own personal health as well as our co-workers, and to reduce the threat to nearby members of the community. It is our policy to adhere to all applicable Federal and state rules and regulations. Safety depends upon the manner in which we handle these substances, combined with the safety devices inherent in the design of this facility, combined with the safe handling procedures that we use and the training of our personnel. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our emergency response plan inclu des procedures for notification of the local fire authority and notification of any potentially affected neighbors. STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED The Sturgis Plant, located near Keyes, Oklahoma, produces petroleum products from natural gas. The facility has several regulated flammable substances, such as butane and pentane, which are contained in flammable mixtures handled and stored on site. WORST-CASE RELEASE SCENARIO AND ALTERNATIVE RELEASE SCENARIO The worst-case release scenario is a vapor cloud explosion involving the full inventory of the largest storage tank containing natural gas liquid (a flammable mixture in which the predominant component is butane). This tank, when filled to the greatest amount allowed, would release 170,000 pounds of liquid. It is assumed that the entire contents forms a vapor cloud, which then finds an ignition source. Ten percent of the cloud quantity is assumed to participate in the resulting explosion. The predicted dista nce to the 1-psi endpoint is 0.44 miles and extends beyond the facility boundary. The alternative release scenario is a vapor cloud explosion resulting from the release of natural gas liquid from a flex hose transfer line shear. The release is expected to be isolated and controlled by operators within 30 seconds by using active mitigation measures. The released quantity of liquid is expected to be 430 pounds, of which 130 pounds is flashed to the atmosphere. It is assumed that the flashed quantity forms a vapor cloud, which then finds an ignition source. Three percent of the cloud quantity is assumed to participate in the resulting explosion. The predicted distance to the 1-psi endpoint is 0.03 miles and extends beyond the facility boundary. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM This facility is subject to OSHA's Process Safety Management (PSM) rule. Thus, the prevention program currently implemented at the facility for processes subject to the EPA's risk management pr ogram includes all of the aspects of PSM. Specifically, the prevention program includes all of the elements listed below. 1. Employee Participation in all facets of process safety management and accident prevention. 2. Process Safety Information, consisting of a variety of technical documents, is kept readily available for employee use. 3. Process Hazard Analysis is used to ensure that hazards associated with the various processes are identified and controlled. 4. Operating Procedures are maintained and address various modes of process operations, such as unit startup, normal operations, temporary operations, emergency shutdown, normal shutdown and initial startup of a new process. 5. Training programs have been implemented for all employees involved in operating a process. 6. Contractors are educated to ensure that they perform their work in a safe manner, have the appropriate knowledge and skills, are aware of the hazards in their workplace, understand what they should do in t he event of an emergency, understand and follow site safety rules, and inform facility personnel of any hazards that they find during their work. 7. Pre-Startup Safety Reviews are conducted for any new equipment or modification that requires a change in the process safety information. 8. Mechanical Integrity is ensured by implementing procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. 9. Safe Work Practices are in place to help ensure worker and process safety. 10. Management of Change systems are used to properly review and authorize process changes prior to actual implementation. 11. Incident Investigation of all occurrences that resulted in, or reasonably could have resulted in an accidental release, is conducted in order to determine the facts and develop corrective actions to prevent a recurrence of the incident. 12. Compliance Audits are used to dete rmine whether the procedures and practices required by the accident prevention program are being implemented. FIVE-YEAR ACCIDENT HISTORY The facility has an excellent record of accident prevention. Over the past five years, the facility has not experienced any accidental releases from covered processes that resulted in deaths, injuries or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage or environmental damage. EMERGENCY RESPONSE PROGRAM The emergency response program for this facility calls for notification of the local fire authorities and notification of nearby residents in the event of an accident. Notification procedures have been coordinated with the Keyes Volunteer Fire Department. PLANNED CHANGES TO IMPROVE SAFETY CIG is committed to operating this facility in a safe manner for workers, the public and the environment. CIG personnel utilize auditing processes to ensure the plant complies with safe operation of its processes. Improvements to safety are a continual process at the plant and safety policy and procedure modifications are constatntly evolving along with new and better training methods. No changes are planned in the immediate future. |