Bryans Mill Gas Plant - Executive Summary

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           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. 
           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. 
      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. 
      Flammable Substanc 
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 
      overpressure endpoint. 
      Toxic Substances 
      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. 
 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 
 prevention program. 
   Employee Participation 
 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 
 are necessary. 
 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. 
 Operating Procedures 
 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  
prepared for 
 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. 
 Mechanical Integrity 
 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. 
 Incident Investigation 
 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. 
 Compliance Audits 
 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. 
 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 
 human effors.  
 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: 
 Release Detection 
     1.  Hydrocarbon detectors with alarms 
 Release Containment/Control 
     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 
 Release Mitigation 
     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 
     breathing apparatus) 
 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. 
 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 
onsists 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 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. 
 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 
 foreseeable future.
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