Springer Gas Plant - Executive Summary |
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EXECUTIVE SUMMARY RISK MANAGEMENT PLAN ONEOK Gas Processing, L.L.C. June 17, 1999 INTRODUCTION AND POLICIES ONEOK Gas Processing, L.L.C. (ONEOK) is committed to being associated with unmatched environmental performance as measured by our employees, customers, regulators, and the public. Our management philosophy goals are achieved by the personal commitments of our employees and contractors, and by open communication with our employees, customers, neighbors, and regulators. The accidental release prevention and emergency response programs at our facilities are part of the high standards for which we strive. 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 remedying 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 Springer Gas Plant is a natural gas processing plant, owned by ONEOK Gas Processing L.L.C. and operated through a contract with The Hanover Company (Hanover), located in Yukon, Oklahoma. The facility was installed and brought on-line October 14, 1998. We separate the liquid hydrocarbons from natural gas by employing a refrigerated gas process with a maximum total plant capacity of 10,000,000 cubic feet per day. A portion of the residue gas is used for plant fuel, and the balance is transported to a customer as high pressure gas for additional processing. There is a product surge tank with a maximum capacity of 50,000 gallons which contains de-methanized product (<0.01% methane). Administrative procedures main tain a lower product quantity in the tank. This product is the only flammable substance at the facility in an amount greater than threshold quantity that is regulated under the Risk Management Program (RMP). The product is a flammable mixture containing the following regulated substances: methane, ethane, propane, butane, isobutane, pentane, and isopentane. Propane is also stored in a 1,200 gallon tank for use as a process refrigerant. Administrative procedures maintain a lower quantity of propane in the tank. There are no RMP-regulated toxic substances present at the plant in amounts greater than threshold quantity. The facility is classified as Program Level 2 under the RMP regulation. Under this program the facility has compiled process safety information and performed a process hazard analysis, developed and implemented written operating procedures and trained the employees and contractors that operate or maintain the plant. The facility has also developed and implemented routine maintenance, compliance audit, and incident investigation procedures. 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. Additionally, the results of the worst-case release scenario and an alternate release scenario are presented. FIVE YEAR ACCIDENT HISTORY The Springer Gas Plant initiated operations on October 14, 1998. The facility has not had any RMP defined accidents or spills since commercial operations and startup began. No incident resulting in onsite or offsite impacts from a hydrocarbon release has occurred at the plant within the last five years. Our continued success is due to proper design and operation of the facility coupled with a competent staff at ONEOK and Hanover. We also pla ce daily emphasis on our prevention and safety programs to ensure this record continues. EMERGENCY RESPONSE PROGRAM We will continue to conduct emergency response preparedness activities and coordinate any emergency response actions necessary for the Springer Gas Plant with the Springer and Ardmore Fire Departments. Also involved in emergency response for the facility would be the Carter County Sheriff, Ardmore Mercy Hospital, and the Oklahoma Department of Public Safety. The plant Operator 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. Our Emergency Response Program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. WORST-CASE RELEASE SCENARIO ONEOK's RMP has been developed to prevent an accidental release of product. Admin istrative procedures are used as controls to limit the quantity of product stored in the product tank to 20,000 gallons. Therefore, the worst-case release scenario would be a release of 20,000 gallons of product from the product tank within ten minutes. The effects of a vapor cloud explosion resulting from this release would diminish with distance from the plant. The RMP Offsite Consequence Analysis (OCA) Guidance was used to determine that the effects from this worst-case release scenario would diminish to an overpressure of less than one (1) psi at a distance of 0.37 miles from the plant. An overpressure of one (1) psi will not normally cause window breakage. ALTERNATIVE RELEASE SCENARIO The effects of a more realistic release scenario than the worst-case scenario were determined as an alternative. The alternative scenario is a truck driver failing to disconnect the product loading hose prior to pulling away from the loading rack. The scenario assumes that the product load ing pump continues to pump for twenty minutes until shut off at the Control House. The effects of a vapor cloud explosion resulting from this release would diminish with distance from the plant. RMP OCA Guidance was used to determine that the effects from the alternate release scenario would diminish to an overpressure of less than one (1) psi at a distance of 0.12 miles from the plant. PLANNED CHANGES TO IMPROVE SAFETY Because the plant has operated less than one year, and due to its proper design and operation, no necessary changes have been identified yet to improve safety. However, the facility will continue to perform planned training, maintenance, compliance audits, and incident investigations to maintain and to improve safety at the facility. |