Denver Unit CO2 Recovery Plant - Executive Summary |
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(a) Accidental Release Prevention and Emergency Response Policies The Altura Energy Ltd's Denver Unit CO2 Recovery Plant (DUCRP) is committed to operating and maintaining all of our processes (especially regarding the use of hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention safeguards and programs and emergency response programs to address the safety of our employees and the public, and the protection of the environment. Our policy is to integrate process controls and administrative procedures that are designed to prevent the release of regulated substances. However, if a release does occur, DUCRP personnel are trained through an emergency action plan to control and contain the release. This document provides a brief overview of the risk management activities we have designed and implemented. (b) Description of the Stationary Source and Regulated Substances Handled DUCRP is designed to process produced gas and recycle C O2 back to our field injection operations. During our process we recover natural gas liquids (NGL) and strip hydrogen sulfide (H2S) from the gas stream. We utilize propane as a cooling agent for the process stream and we treat our cooling water with chlorine. Our evaluation of the regulated substances involved in the DUCRP process resulted in our classifying this as a Program Level 1 process with only our propane (CAS No. 74-98-6) inventory exceeding threshold quantities of the listed regulated substances. (c) Worst Case Scenario The worst case scenario (WCS) for DUCRP was associated with an instantaneous release and ignition resulting in a vapor cloud explosion of the 179,550 lbs. Inventory of the refrigeration propane in the facilities largest storage tank. Even though we have several safeguards and controls in place to prevent such a release and manage the consequences, we took no credit for any passive mitigation measures in the WCS evaluation. Our WCS results in no offsite impact on any public or environmental receptor. (d) General Accidental Release Prevention Program DUCRP is a Program Level 1 and is not required to have a specific prevention program. However, we do have an active PSM program, which incorporates accidental release prevention. (e) Five-year Accident History In our review of the DUCRP incident records for the past five years, we have not experienced an accidental release from a covered process resulting in deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. (f) Emergency Response Program DUCRP maintains a written emergency action plan to control and contain an accidental release of a regulated substance. Our plan considers all federal, state and local regulatory requirements for emergency response planning. The plan is designed to respond to a release of a regulated substance and provides first aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, and notification of local emergency response agencies. We have coordinated our emergency response activities with the Denver City, Texas emergency response agencies. (g) Planned Changes to Improve Safety 1. We will continue to develop and utilize a root cause failure methodology in analyzing any DUCRP incidents. 2. We will continue to develop and share management practices involving operations and maintenance activities between Altura plants. 3. We will review our active process safety management program from time to time for appropriate improvements to the program. Certification Based on the criteria in 40 CFR 68.10, the distance to the specific endpoint for the worst case accidental release scenario for the following process (es) is less than the distance to the nearest public receptor: Propane Storage Within the past 5 years the process (es) has (have) had no accidental release that caused offside impacts provided in the RMP rule (40 GFR 68.10(b)(1). No ad ditional measures are necessary to prevent offsite impacts from accidental releases. In the event of fire, explosion, or a release of regulated substance from the process (es), entry within the distance to the specified endpoints may pose a danger to the public emergency responders. Therefore, public emergency responders should not enter this area except as arranged with the emergency contact indicated in the RMP plan. The undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete, Signature: Mack Alexander Title: Team Leader Date: June 17, 1999 |