Elmore City Gas Plant - Executive Summary

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Executive Summary for Elmore City Gas Plant RMP 
The following summary is intended to meet the requirements of 40 CFR Subpart G ' 68.155.  The Risk Management Program is based on the API Publication 761:  "Model Risk Management Plan Guidance for Exploration and Production Facilities." 
The accidental release prevention and emergency response policies at the Elmore City Gas Plant are included in the facility's Emergency Response Manual and PSM program.  The Emergency Response Manual covers action to be taken in case of an unplanned release of hazardous substances.  The mechanical integrity section of PSM covers action taken to prevent an unplanned accidental release of regulated substances. 
The Elmore City Gas Plant is a natural gas processing plant. The process consists of:  molecular sieve dehydration, NGL extraction, and liquid / liquid amine stripping.  The mole sieves remove water from the natural gas stream.  The natural gas liquids (NGL) are extracted by chilling the gas using a 
Turbo Expander, JT valve, and series of heat exchangers.  The NGL product is conditioned by the liquid / liquid amine contactor to meet CO2 specification.  The NGL product and residue gas are transported via pipeline to market.   
Elmore City Gas Plant was determined to be a program level 3 facility through the worst-case scenario analysis.  The worst-case scenario for this facility would be a vapor cloud explosion (VCE) due to the instantaneous release of 19,000 pounds of NGL.  The radius of exposure (ROE) resulting from the worst-case scenario release, assuming a fully loaded NGL surge tank, is 0.20 miles.  The estimated population within the distance to endpoint is 10.0.  There are no environmental receptors within the ROE for the worst-case scenario.  The alternative release scenario is also a (VCE) due a pressure relief valve failure which results in the release of 8,500 pounds of NGL.  The radius of exposure is 0.10 miles based on a normal level in the NGL tank.  There are no pu 
blic or environmental receptors within the distance to endpoint for the alternative release scenario.  The NGL surge tank is protected by alarms, a high pressure vent valve, and pressure relief valves which help prevent a release from occurring.     
The general accidental release prevention measures taken are outlined in the mechanical integrity section of the PSM program for the facility. Some of the main components of this section that would help prevent the accidental uncontrolled release of regulated substances include:  testing of critical control and shutdown instruments, testing of PSV's and routine testing of piping and vessel corrosion. 
There has not been a recordable / off-site accident in the previous five year history of this facility. 
The emergency response program for this facility is contained in the Emergency Response Manual, ERM. The ERM includes action to be taken in case of an uncontrolled release of a hazardous substance. The proper action includes immediately co 
ntacting the Garvin County Emergency Response system, which in turn will contact other emergency response agencies to aid in controlling access to the facility by the public. 
The facility has ongoing programs that help train personnel in areas that have the greatest potential for uncontrolled release of hazardous substances.  In addition to utilizing PSM for hazard assessment, safety training is done in which unsafe items are discussed and resolved.
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