Bryans Mill Gas Plant - Executive Summary
EXECUTIVE SUMMARY |
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES
The Bryans Mill Gas Plant 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 facility's processes. Sulphur River
Resources, L.C. (Sulphur River) policy is to implement reasonable controls to
prevent foreseeable releases of substances. However, if a release does occur,
trained personnel will respond to, control, and contain the release.
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED
Sulphur River owns and operates the Bryans Mill Gas Plant located in Cass
County, Texas. The Bryans Mill Gas Plant is a gas separation, dehydration,
sweetening, and processing facility. The inlet streams ent
ering the plant go through
separators where crude oil/condensate is separated from the wet gas. The crude
oil/condensate is transferred to a raw crude tank and then stabilized in a stabilizer
tank. The wet, sour gas stream from the separator is dehydrated using a glycol
dehydration system. The dehydrated sour gas is compressed and sent to the Selexol
Sweetening Unit where the acid gases (H2S and C02) are removed. The sweet gas
is then processed through a cryogenic unit where methane, ethane, and propane are
separated from the heavier hydrocarbons. The natural gas liquids from the
cryogenic unit are sent to the stabilized crude tanks, where it is combined with the
crude oil stream. The residue gas from the cryogenic unit is piped off site. The
acid gas from the Selexol Sweetening Unit is recovered in a sulfur recovery unit
(SRU). The tail gas from the SRU is sent to an incinerator for destruction.
ts are transported from the facility via pipeline and truck.
The Bryans Mill Gas Plant was evaluated to determine if any regulated flammable
or toxic substances exceeded the threshold quantity. Based on process knowledge,
Sulphur River identified the regulated substances and quantities kept on site.
Listed flammable substances which are stored above threshold quantities at the
Bryans Mill Gas Plant are NGL/condensate, raw crude (condensate), propane and
natural gas liquids. However, Sulphur River has determined that raw crude
(condensate) has an NFPA flammability hazard rating of 3, which exempts this
mixture from threshold determination. Based on worst-case analysis, the distance
to the endpoint exceeds the distance to public receptors. In addition, the Bryans
Mill Gas Plant is subject to Occupational Safety and Health Administration's
(OSHA's) process safety management (PSM). Therefore, the B
ryans Mill Gas
Plant is classified as a Program 3 process under the ARP program.
OFF-SITE CONSEQUENCE ANALYSIS RESULTS
Flammable Substances - Worst-Case Scenario
The endpoint for worst-case release of flammable substances is 1 psi overpressure
(i.e., 15.7 psia), resulting from a vapor cloud explosion. The ARP Program
requirement for flammables assumes an instantaneous release and vapor cloud
explosion. A yield factor of 10 percent of the available energy released in the
explosion shall be used to determine the distance to the explosion endpoint based
on TNT-equivalent methods. Since the worst-case release scenario for a flammable
substance is based on the assumption that the entire quantity of the substance forms
a vapor cloud, passive mitigation systems are not applicable. NGL/condensate is
the worst-case flammable release with a 1.07-mile distance to the endpoint.
es - Alternative-Case Scenario
A single alternative release scenario for all flammable substances is required under
the ARP program. A hypothetical, but likely to occur, release scenario has been
identified for propane as follows. Seal failure on the propane make-up pump causes
a release from a 1-inch opening at 225 psig and 150 degrees F. The release is
assumed to continue for 10 minutes. The propane will vaporize and may ignite in
a vapor cloud explosion with an endpoint of I psi overpressure or a vapor cloud
fire with an endpoint of the lower flammability limit (LFL) for propane. The
alternative-case release of propane resulted in a 0. 11 -mile distance to the 1 psi
The Bryans Mill Gas Plant does not have any toxic substances held above the
threshold quantity; therefore, analysis of worst-case or alternative-case release
scenarios for toxic subs
tances is not required.
GENERAL ACCIDENT RELEASE PROGRAM
The following is a summary of the of the accident prevention program in place at the
Bryans Mill Gas Plant. Because the processes at the plant that are regulated by the
Environmental Protection Agency's (EPA's) risk management program (RMP) regulation
are also subject to the OSHA PSM, this summary addresses each of the OSHA PSM
elements and describes the management system in place to implement the accident
Active employee participation and involvement in the development and implementation of
the Bryans Mill Gas Plant's PSM program is an important step toward achieving the
objective to prevent or minimize the consequences of catastrophic releases of toxic,
reactive, flammable, or explosive chemicals. Employee involvement will help to ensure
that all perspectives regarding PSM are considered, and that the best ideas are
implemented. Open communicatio
ns are encouraged between supervisors and employees
regarding all safety and health issues.
The Bryans Mill Gas Plant strongly promotes employee involvement in safety issues
through existing programs. These programs include Unit Safety Teams (which are made
up of a cross section of employees and supervision), regularly scheduled safety meetings,
tail-gate safety meetings, Hazard Communication, Safety Suggestion Forms, linear-miss"
reporting, and special training programs (emergency response training, first aid, etc.).
The Bryans Mill Gas Plant actively seeks employee involvement in the development and
conduct of all accident prevention activities through the appropriate existing safety
programs. Accident prevention is discussed at the regularly scheduled safety meetings
and/or during special training sessions if necessary. Employees are encouraged to discuss
accident prevention with their supervisors if they have questions, comments, or
rocess Safety Information
Complete and accurate written process safety information (PSI) concerning process
chemicals, process technology, and process equipment is essential to an effective PSM and
RMP programs and to completing and maintaining a process hazard analysis (PHA). The
PSI will be useful to the operators; the team performing the PHA; those in charge of
training; contractors; those conducting pre-startup safety reviews; and those in charge of
updating the emergency preparedness plans. Process safety information is readily available
to all employees.
The Bryans Mill Gas Plant keeps a variety of technical documents that are used to help
maintain safe operation of the process. These documents address chemical properties and
associated hazards, limits for key process parameters and specific chemical inventories,
and equipment design basis/configuration information.
Chemical-specific information, including exposure hazards and emergency response/
exposure treatment considerations, is provided in material safety data sheets (MSDSs).
The Bryans Mill Gas Plant also maintains numerous technical documents that provide
information about the design and construction of process equipment. This information
includes materials of construction, design pressure and temperature ratings, and electrical
rating of equipment. This information, in combination with written procedures and 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 Bryans Mill Gas Plant 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 i
n place to manage these hazards.
The Bryans Mill Gas Plant primarily uses the hazard and operability (HAZOP) and
What-if/Checklist method analysis technique to perform these evaluations. The analyses
are conducted using a team of people who have operating and maintenance experience as
well as engineering expertise. This team identifies and evaluates hazards of the process as
well as accident prevention and mitigation measures, and the team makes suggestions for
additional prevention and/or mitigation measures when the team believes such measures
The PHA team findings are forwarded to local and corporate management 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 tracke
d 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.
The Bryans Mill Gas Plant maintains written procedures that address various modes of
process operations, such as; (1) startup, (2) normal operations, (3) temporary operations,
(4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process.
procedures provide guidance for experienced operators and also provide the basis
for training new operators. Operating procedures are periodically reviewed and annually
certified as current and accurate. The review and certification process involves both
operators and technical staff.
The intent of the operating procedures is to provide workable, useful, and clearly written
instructions for conducting operating activities. To have effective operating procedures,
the task and procedures directly and indirectly related to the covered process must be
appropriate, clear, consistent, and most importantly, communicated to employees.
Operating procedures are specific instructions or details on what steps are taken or
followed in carrying out the stated procedures. The specific instructions include the
applicable safety precautions and appropriate information on safety implications.
In addition to training on operating procedures the Bryans Mill Gas P
lant has a
comprehensive training program for all employees involved in operating the process. New
employees receive basic training in gas operations. In addition, all operators periodically
receive refresher training on the operating procedures to ensure that their skills and
knowledge are maintained at an acceptable level. 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 Bryans Mill Gas Plant 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 appropriate knowledge and skills, (3) are
aware of the hazards of their workplace, (4) understand what they should do in the
of an emergency, (5) understand and follow site specific safety rules, and (6) inform gas
plant personnel of any hazards that they find during their work. This is accomplished by
providing contractors with an orientation session that covers (1) a process overview, (2)
information about safety and health hazards, (3) emergency response plan requirements,
and (4) safe work practices prior to beginning their work. In addition, the Bryans Mill
Gas Plant evaluates contractor safety programs and performance during the selection of a
contractor. Gas plant personnel periodically monitor contract performance to ensure that
contractors are fulfilling their safety obligations.
Pre-startup Safety Review (PSSRs)
The Bryans Mill Gas Plant conducts a PSSR on any new facility or facility modification
that requires a change in process safety information. The purpose of the PSSR is to ensure
that safety features, procedures, personnel, and equipment are appropriately
startup prior to placing the equipment into service. This review provides one additional
check to make sure construction is in accordance with design specification and that
all-supporting systems are operationally ready. The PSSR involves field verification of the
construction and serves a quality assurance function by requiring verification that accident
prevention program requirements are properly implemented.
The Bryans Mill Gas Plant has well established practices and procedures for maintaining
process equipment. The basic aspects of this program include (1) training, (2) developing
written procedures, (3) performing inspections and tests, (4) correcting equipment
deficiencies, when identified, and (5) applying quality assurance measures. In
combination, these activities form a system that maintains the mechanical integrity of the
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
Another integral part of the mechanical integrity program is quality assurance. The Bryans
Mill Gas Plant incorporates quality assurance measures into equipment purchases and
repairs. 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 Practices
The Bryans Mill Gas Plant 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 and 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 Bryans Mill Gas Plant has a comprehensive system to manage changes to all covered
processes. This system requires that changes to items such as process equipment,
technology (including process operating conditions), procedures, and other facility changes
be properly reviewed 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 informa
tion, as well as procedures
are updated to incorporate these changes. In addition operating and maintenance personnel
are provided any necessary training on the change.
The Bryans Mill Gas Plant 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 gather the facts,
determine the root cause, and develop corrective action to prevent the reoccurrence of the
incident or a similar incident. The investigation team documents its findings, develops
recommendation to prevent a recurrence, and forwards these results to the business
management team for resolution.
To help ensure that the accident prevention program is functioning properly, the Bryans
Mill Gas Plant periodically conducts an audit to determine whether the procedures and
required by the accident prevention program are being implemented. Compliance
audits are conducted at least every 3 years. Both hourly and staff personnel participate as
audit team members. The audit team develops findings that are forwarded to Bryans Mill
Gas Plant management for resolution. Corrective actions taken in response to the audit
team's findings are tracked until they are complete. The final resolution of each finding
is documented, and the two most recent audit reports are retained.
CHEMICAL SPECIFIC PREVENTION STEPS
The processes at the Bryans Mill Gas Plant 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 accident prevention program summarized previously is applied to all RMP-covered
processes at the Bryans Mill Gas Plant. Collectivel
y, these prevention program activities
help prevent potential accident scenarios that could be caused by equipment failures and
Specialized Safety Features
The Bryans; Mill Gas Plant 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 features are used in the covered processes:
1. Hydrocarbon detectors with alarms
1. Process relief valves that discharge to a flare to capture and incinerate episodic
2. Valves to permit isolation of the process (manual or automated)
3. Automated shutdown systems for specific process parameters (e.g., high
4. Curbing or diking to contain liquid releases
5. Redundant equipment and instrumentation (e.g., uninterruptible power supply for
process control system, backup firewater pump)
6. Atmospheric relief devices
1. Fire suppression and extinguishing systems
2. Deluge system for specific equipment
3. Personnel trained in emergency procedures
4. Personal protective equipment (e.g., chemical protective clothing, self-contained
FIVE YEAR ACCIDENT HISTORY
The Bryans Mill Gas Plant has an excellent record of accident prevention over the past 5
years. There has been one incident involving a release of lean oil, which had no offsite
effects. The incident was investigated very carefully to determine ways to prevent similar
incidents from recurring. The recommendations from the investigation were implemented.
EMERGENCY PROCEDURE INFORMATION
The Bryans Mill Gas Plant maintains a written emergency procedure, which is in place to
protect worker and public safety as well as the environment. The plan c
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 notification of local emergency response agencies if a release occurs, and post
incident cleanup and decontamination requirements. Employees receive training in
emergency procedures. The emergency procedure is updated when necessary based on
modifications made to Bryans Mill Gas Plant facilities. The emergency procedure changes
are administered through the Management of Change (MOC) process, which includes
informing and/or training affected personnel in the changes.
The overall emergency procedure program for the Bryans Mill Gas Plant is coordinated
with the Cass County, Texas, Local Emergency Planning Committee (LEPC). This
coordination includes periodic meetings of the committee, which includes local emergency
response officials, local government officials, and
industry representatives. The Bryans
Mill Gas Plant has around-the-clock communications capability with appropriate LEPC
officials and emergency response organizations (e.g., fire department). This provides a
means of notifying the public of an incident, if necessary, as well as facilitating quick
response to an incident. In addition to periodic LEPC meetings, the Bryans Mill Gas Plant
conducts periodic emergency drills that involve the LEPC and emergency response
organizations, and the Bryans Mill Gas Plant provides periodic refresher training to local
emergency responders regarding the hazards of regulated substances in the plant.
PLANNED CHANGES TO IMPROVE SAFETY
The Bryans Mill Gas Plant resolves all findings from PHA's, some of which result in
modifications to the process. At the current time, no changes are planned in the