Grasslands Complex - Executive Summary

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Grasslands Complex 
Executive Summary 
Bear Paw Energy has a long-standing commitment to worker and public safety.  This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes.  Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances.  However, if a release does occur, gas plant trained personnel will respond to control and contain the release. The following is a statement from Bear Paw Energy Senior Management.  Bear Paw Energy Inc. believes in maintaining a safe working environment for all employees.  Our equipment and personnel reflect this belief, and our prime objective is to ensure the personal safety of every employee on the job-site and to safe guard company property through preventative measures.  Employees of Be 
ar Paw Energy Inc. are expected to be familiar with all company safety policies.  Through continuing education, in-house training and management support, we will provide a safe and professional working environment for our employees as well as those whose lives and safety have been entrusted to us. 
The Grasslands Complex, located in McKenzie County, North Dakota, uses cryogenic fractionation and amine absorption to process sour wellhead gas into marketable natural gas and natural gas liquids (NGL).  As a result of this operation, several EPA regulated flammable substances and one toxic substance are processed, recovered, and stored at the facility (e.g., methane, ethane, propane, butane, pentane, and natural gas condensate).  There are four 72,506gal (305,975lbs) propane, three 61,539gal (323,079lbs) natural gasoline, four 42,007gals (202,893lbs) butane, one 29,990gal (144,851lbs) field grade butane, one 17,978gal (86,833 
lbs) Y-Grade, three 33,150gal (160,114lbs) of iso-butane storage tanks.  The Grasslands Complex does not use or store any regulated toxic substances above the EPA set threshold levels.  However the plant does remove and convert the hydrogen sulfide (H2S) present in the raw wellhead gas into elemental sulfur and water in its Amine Sweetening Facility and Sulfur Recovery Unit (2990lbs H2S on site).   
The worst-case scenario (WCS) associated with a release of flammable substances in Program Level 1 process at the Grasslands Complex is a vapor cloud explosion (VCE) resulting from a release of 323,000 pounds of a flammable mixture  from the stations largest storage vessel.  Although we have numerous controls to prevent such releases and to manage their consequences, no credit for administrative controls, or active or passive mitigation measures were taken into account in evaluating this WCS.  The maximum distance to the 1-psi endpoint for this WCS is  
0.5 mile.  Zero public and zero environmental receptors were identified within the 0.5 mile radius.  
The following is a summary of the accidental release prevention program in place at the plant.  Because processes at the gas plant that are regulated by the Environmental Protection Agencys (EPAs) risk management program regulation are also subject to the Occupational Safety and Health Administrations (OSHAs) process safety management (PSM) standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement PROGRAM 3 under EPAs accidental release prevention program. 
Employee Participation 
The Grasslands Complex encourages employees to participate in all facets of process safety management and accident prevention.  Examples of employee participation range from updating and compiling process safety information to participation as a member of a process hazard analysis (PHA) team.  E 
mployees have access to all information created as part of the gas plants PSM and accidental release prevention programs.  These programs are documented in an employee participation plan that is maintained at the gas plant and addresses each element of PSM and the accidental release prevention programs.  In addition, the gas plant has a number of initiatives under way that address process safety and employee safety issues.  These initiatives include plant safety meetings and safety training to promote both process and personal safety.   
Process Safety Information 
The Grasslands Complex keeps a variety of technical documents that are used to help maintain safe operation of the processes.  These documents address chemical properties and associated hazard, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information.  The area Safety Department in conjunction with plant personnel are assigned the responsibility for maintainin 
g up-to-date process safety information. 
Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDS).  This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals.  The plant has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in the plants operating procedures, and ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems). 
The plant also maintains numerous technical documents that provide information about the design and construction of process equipment.  This information includes material of construction, design pressure and temperature ratings, and electrical rating 
of equipment.  This information, in combination with trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. 
Process Hazard Analysis (PHA) 
The Grasslands Complex has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled.  Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. 
The Grasslands Complex primarily uses the HAZOP analysis technique to perform these evaluations.  The analysis is recognized by OSHA and the EPA as an approved method for conducting PHAs.  Plant PHAs are conducted using a team of people who have operating, maintenance, engineering and safety experience.  The team identifies and evaluates hazards of the process as well as accident preve 
ntion and mitigation measures, and the team makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. 
The PHA team findings are addressed locally and by the companys corporate Safety and Engineering Departments for resolution.  Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team.  This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention.  All approved mitigation options in response to PHA team findings are tracked until they are completed.  The final resolution of each finding is documented and retained. 
To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the plant periodically updates and revalidates the hazard analysis results.  These periodic reviews are conducted at least every 5 years and will 
be conducted at this frequency until the process is no longer operating.  The results and findings from these updates are documented and retained.  Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained. 
Operating Procedures 
The Grasslands Complex maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process.  These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators.  These procedures are revised as necessary to reflect changes made through the management of change process and annually certified as current and accurate.   
In addition, Grasslands Complex Operating Procedures provide guidance on how to respond to specific process or equipment parame 
ters that exceed the parameter upper or lower limit.  Operating Procedures are readily available to operators and for other personnel to use as necessary to safely perform their job tasks. 
To complement the written procedures for process operations, the Grasslands Complex has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in gas plant operations if they are not already familiar with such operations.  After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks.  After operators demonstrate (e.g., through tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently.  In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable l 
evel.  This refresher training is conducted at least every 3 years.  All of this training is documented for each operator, including the means used to verify that the operator understood the training. 
The Grasslands Complex uses contractors to supplement its workforce during periods of increased maintenance or construction activities.  Because some contractors work on or near process equipment, the gas plant has procedures in place 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 they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform gas plant personnel of any hazards that they find during their work.  This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practic 
es prior to their beginning work.  In addition, the Grasslands Complex evaluates contractor safety programs and performance during the selection of a contractor.  Gas plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. 
Pre-startup Safety Reviews (PSSRs) 
The Grasslands Complex conducts a PSSR for any facility 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 appropriately prepared for startup prior to placing the equipment into service.  This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready.  The PSSR review team uses checklists to verify all aspects of readiness.  A PSSR involves field verification of the construction and serves a quality assurance function by requiring ver 
ification that the accident prevention program requirements are properly implemented. 
Mechanical Integrity 
The Grasslands Complex has established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition.  The basic aspects of this program include:  (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures.  In combination, these activities form a system that maintains the mechanical integrity of the process. 
Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their jobs in a safe manner.  Equipment manufacturers written procedures help 
ensure that work is performed in a consistent manner and provide a basis for training.  Inspections and tests are performed in accordance with the manufacturers recommendations to help ensure that equipment functions as intended and to verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels).  If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or place temporary safeguards in place to ensure the safe operation of the equipment. 
Another integral part of the mechanical integrity program is quality assurance.  The Grasslands Complex incorporates quality assurance measures into equipment purchases and repair.  This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. 
Safe Work Practice 
The Grasslands Complex has long-standing, safe work practices in place to help ensure worker 
and process safety.  Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous substances before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space.  These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. 
Management of Change 
The Grasslands Complex has a comprehensive system to manage changes to all covered processes.  This system requires that changes to items such as process equipment, chemicals, technology (including process operating conditions), procedures, and other facility changes to be properly reviewe 
d and authorized before being implemented.  Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change.  Affected chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated to incorporate these changes.  In addition, operating and maintenance personnel are provided any necessary training on the change. 
Incident Investigation 
The Grasslands Complex promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury.  The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident.  The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to ma 
nagement for resolution.  Corrective actions taken in response to the investigation teams findings and recommendations are tracked until they are complete.  The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings.  Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations. 
Compliance Audits 
To help ensure that the accident prevention program is functioning properly, the Grasslands Complex periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented.  Compliance audits are conducted at least every 3 years.  Audit findings are forwarded to the companys Safety Department for resolution.  The  Safety Department initiates any corrective actions taken in response to the audit and trac 
ks them until they are complete.  The final resolution of each finding is documented, and the two most recent audit reports are retained. 
The processes at the Grasslands Complex have hazards that must be managed to ensure continued safe operation.  The following is a description of existing safety features applicable to prevention of accidental releases of regulated substances in the facility. 
Universal Prevention Activities 
The accidental release prevention program summarized previously is applied to all RMP-covered processes at the Grasslands Complex.  Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. 
Specialized Safety Features 
The Grasslands Complex has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release.  The following types of safety fea 
tures are used in the covered processes: 
   Release Detection 
   Daily operator inspection. 
   Fixed point monitors for H2S and combustible gas. 
   Fire detection with shut-down. 
   Release Containment/Control 
   Process relief valves that prevent vessel over pressurization. 
   Valves to permit isolation of the process (manual or automated). 
   Automated shutdown systems for specific process parameters (e.g., high temperature). 
   Curbing or diking to contain liquid releases. 
   Redundant equipment and instrumentation (e.g., emergency power supply, backup pumps, etc.). 
   Release Mitigation 
   Fire suppression and extinguishing systems. 
   Trained emergency response personnel (HAZWOPER, fire response). 
   Personal protective equipment (e.g., hard hat, safety glasses, protective clothing, SCBA, etc.). 
The Grasslands Complex experienced NO reportable accidents in the past 5 years.  Releases that did occur at the plant involving a regulated substance, were qui 
ckly contained and resulted in no deaths, injuries, significant property damage, environmental damage, evacuations, or sheltering in place.   
The Grasslands Complex maintains a written emergency response plan, which is in place to protect worker and public safety as well as the environment. The plan consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released.  The procedures address or reference all aspects of emergency response, including proper first aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post incident cleanup and decontamination requirements.   
In addition, the plant has procedures that address maintenance, inspection, and testing of emergency response.  Employees receive 
training in these procedures as necessary to perform their specific emergency response duties, and participate in plant monthly emergency drills to ensure emergency shutdown system (ESD) integrity and reinforce proper employee response.  
The emergency response plan is updated when necessary based on modifications made to gas plant process or other Bear Paw Energy facilities.  The emergency response program changes are administered through the MOC process, which includes informing and/or training affected personnel in the changes. 
The overall emergency response plan for the Grasslands Complex is coordinated with the Richland County Local Emergency Planning Committee (LEPC) which is responsible for preparing the communitys emergency response plan.  The local responder for plant emergencies is the Richland County Volunteer Fire Department and Richland Co. Sheriffs Department.  The Grasslands Complex has around-the-clock communications capability with appropriate LEPC officials and em 
ergency response organizations (e.g., fire department, sheriffs office).  This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident.   
The Grasslands Complex resolves all findings from PHAs, some of which result in modifications to the process.  The following types of changes are planned over the next few years in response to PHA, safety audit, and incident investigation findings: 
7 Enhanced Training
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