Zif Gas Plant - Executive Summary
EXECUTIVE SUMMARY |
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES
The Equinox Oil Company Zif 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
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.
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES
The Zif Plant, located approximately seven miles south of Clay City in Wayne County, Illinois,
operates a variety of processes to produce petroleum products (e.g., natural gas, propane,
butane/gasoline [BG]-mix and condensate) from natural gas. The Zif Plant has several regulated
flammables, such as propane and BG-mix. There are no regulated t
oxic substances at the Zif facility.
OFFSITE CONSEQUENCE ANALYSIS RESULTS
The worst-case scenario (WCS) associated with a release of flammable substances in Program Level
3 processes at the gas plant is a vapor cloud explosion (VCE) involving the full inventory of the
largest storage tank containing BG-mix and condensate. A written procedure is in place to limit the
storage inventory to 24,000 gallons, (85% of the maximum tank capacity); therefore, the reduced
inventory is assumed to release and ignite, resulting in a VCE. The maximum distance to the 1psi
endpoint for this WCS is 0.41 miles. Although controls are in place to prevent such releases and to
manage their consequences, no credit for passive mitigation measures was taken into account in
evaluating this WCS.
The Alternative Release Scenario (ARS) for flammable substance's At the Zif Plant is a VCE resulting
from the release of propane from the propane storage area. The maximum distance to the 1 - psi
endpoint for this event
is 0.17 miles. This event was selected as being a practical scenario for use in
emergency planning and response. Figure 1-1 graphically presents the hazard assessment results for
the flammable WCS and ARS events.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM
The following is a summary of the accident prevention program in place at the Zif Plant. Because
processes at the gas plant that are regulated by the Environmental Protection Agency's (EPA's) risk
management program (RMP) regulation are also subject to the Occupational Safety and Health
Administration's (OSHA's) process safety management (PSM) standard, this summary addresses each
of the OSHA PSM elements and describes the management system in place to implement the accident
The Zif Plant encourages employees to participate in all facets of process safety management and
accident prevention. Examples of employee participation range from updating and compiling technical
documents and c
hemical information to participating as a member of a process hazard analysis (PHA)
team. Employees have access to all information created as part of the gas plant accident prevention
program. Specific ways that employees can be involved in the accident prevention program are
documented in an employee participation plan that is maintained at the gas plant and addresses each
accident prevention program element. In addition, the gas plant has a number of initiatives under way
which address process safety and employee safety issues. These initiatives include forming teams to
promote both process and personal safety. The teams typically have members from various areas of
the plant, including operations, maintenance, engineering, and plant management.
Process Safety Information
The Zif Plant keeps a variety of technical documents that are used to help maintain safe operation of
the processes. These documents address chemical properties and associated hazards, limits for key
ters and specific chemical inventories, and equipment design basis/configuration
information. Specific departments within the gas plant are assigned responsibility for maintaining
up-to-date process safety information. A table summarizing the reference documents and their
location is readily available as part of the written employee participation plan to help employees locate
any necessary process safety information.
Chemical-specific information, including exposure hazards and emergency response/exposure
treatment considerations, is provided in material safety data sheets (MSDSs). The gas plant ensures
that the process is maintained within acceptable limits using process controls and monitoring
instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown
The gas plant also maintains numerous technical documents that provide information about the design
and construction of process equipment. This information includes materials of con
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 Zif Plant has a 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 Zif Plant primarily uses the fault tree analysis technique to perform these evaluations. Fault tree
analysis is recognized as a systematic hazard evaluation techniques. The analyses are conducted using
a team of people who have operating and maintenance experience as well as engineering expertise.
This team id
entifies 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 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 five 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 Zif Plant 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 periodically reviewed and annually certified as current and accurate. The
procedures are kept current and accurate by revising them as necessary to reflect changes made
through the management of change process. In addition, the Zif Plant maint
ains written operating
procedures, which are readily available to operators in the process unit and for other personnel to use
as necessary to safely perform their job tasks.
To complement the written procedures for process operations, the Zif Plant 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) 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 level.
This refresher training is
conducted at least every three years. All of this training is documented for
each operator, including the means used to verify that the operator understood the training.
The Zif 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 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 practices prior to their
beginning work. In ad
dition, the Zif Plant 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 Zif Plant conducts a PSSR for any new facility or 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 that accident
prevention program requirements are properly implemented.
The Zif Plant has well-estab
lished 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. Written procedures
help ensure that work is performed in a consistent manner and provide a basis for training. Inspections
and tests are performed to help ensure that equipment functions as int
ended 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 a management of change team will review the use of the equipment and
determine what actions are necessary to ensure the safe operation of the equipment.
Another integral part of the mechanical integrity program is quality assurance. The Zif 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 Zif 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 sour
ces 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 sparkproducing 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 Zif Plant 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 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 b
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.
The Zif 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 determine the facts and develop corrective actions to prevent a
recurrence and forwards these results to gas plant management for resolution. Corrective actions
taken in response to the investigation team's 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 aff
by the findings. Incident investigation reports are retained for at least five years so that the reports
can be reviewed during future PHAs and PHA re-validations.
To help ensure that the accident prevention program is functioning properly, the Zif Plant 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 three
years. Both hourly and staff personnel participate as audit team members. The audit team develops
findings that are forwarded to 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 Zif Plant have hazards that must be managed to ensure continued safe operation.
ing 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 Zif Gas Plant. Collectively, these prevention program activities help prevent potential accident
scenarios that could be caused by equipment failures and human errors.
Specialized Safety Features
The Zif 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 releases
2. Valves to permit isolation of the process
3. Automated shutdown sys
tems for specific process parameters
4. Curbing or diking to contain liquid releases
5. Redundant equipment and instrumentation
6. Atmospheric relief devices
1. Fire suppression and extinguishing systems
2. Trained emergency response personnel
3. Personal protective equipment
4. Blast-resistant buildings to help protect control systems and personnel
FIVE-YEAR ACCIDENT HISTORY
The Zif Plant has an excellent record of accident prevention over the past five years. There have been
no off-site accidents within this time period.
EMERGENCY RESPONSE PROGRAM INFORMATION
The Zif Plant maintains a written emergency response program that is in place to protect worker and
public safety, as well as the environment. The program 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 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 equipment,
as well as instructions that address the use of emergency response equipment. Employees receive
training in these procedures as necessary to perform their specific emergency response duties. When
necessary, the emergency response program is updated based on modifications made to gas plant
processes or other Zif Plant facilities. The emergency response program changes are administered
through the MOC process, which includes informing and/or training affected personnel in the
The overall emergency response program for the Zif Plant is coordinated with th
e Clay City
Volunteer Fire Department. The Zif Gas Plant has around-the-clock communications capability with
appropriate 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, the Zif Gas Plant conducts periodic emergency audits that involve emergency response
organizations, and the gas plant provides annual refresher training to local emergency responders
regarding the hazards of regulated substances in the gas plant.
PLANNED CHANGES TO IMPROVE SAFETY
The Zif Gas Plant resolves all findings from PHAs, some of which may result in modifications to the
process. At the current time, no changes are planned over the foreseeable future.