Williams Gas Processing - Lybrook Plant - Executive Summary |
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EXECUTIVE SUMMARY LYBROOK PLANT RISK MANAGEMENT PLAN Accidental release prevention and Emergency Response Policies Williams Energy Services and the Lybrook Plant are strongly committed to the employee, public, and environmental safety. This commitment is demonstrated by the resources that the company invested in accident prevention including: X Personnel Training Management Program X Consideration of safety in the design, installation, operation and maintenance of our facility It is our policy is to implement appropriate controls to prevent possible releases of any regulated substances. The facilities Emergency Response Plan includes: X Procedures for notification of trained personnel to respond X Control and contain the release The Stationary Source and Regulated Substances Lybrook Plant operates a cryogenic and fractionation natural gas liquids extraction process. Commercial grade Methane is produced by extracting propane, butane, and two separate flammable mixtures of natura l gas liquids from the inlet stream of unprocessed natural gas. We have 5 regulated natural gas liquids present in our facility that are initially separated into individual components. The separated components are blended back together at the end of the process except for propane. Propane is sold to external customers and the blended components are shipped via liquid pipeline. They include ethane, propane, butane and natural gasoline liquids. The maximum quantity of Methane at our facility is 10,400 lbs. While Ethane is present in a maximum quantity of 227,000 lbs., Propane has maximum quantity of 1,970,000 lbs.; Butane has maximum quantity of 384,000 lbs. and natural gasoline liquids maximum quantity is 384,000 lbs. Worst Case Release Scenario and Alternative Release Scenarios The worst case scenario with a release of flammable substances is a vapor cloud explosion involving 100% of a single storage inventory of one of our product tanks, containing a propane gas liquids, which i s a regulated substance at 380,549 lbs.. The propane storage inventory is assumed to release and finds an ignition source, resulting in a vapor cloud explosion. The maximum distance to the 1-psi over pressure endpoint for this worst case scenario is 0.586 miles. The alternative release scenario with a release of flammable substances is a vapor cloud explosion involving 100% of a single storage inventory of one of our product tanks, containing a flammable mixture, which is a regulated substance at 42,000 lbs. The flammable mixture storage inventory is assumed to release and finds an ignition source, resulting in a vapor cloud explosion. The maximum distance to the 1-psi over pressure endpoint for this worst case scenario is 0.46 miles. General Accidental Release Prevention Program The Lybrook Facility encourages employees to participate in all aspects of Process Safety Management, Risk Management, and Accident Prevention. Employee participation range from updating and compilin g technical data for Operating and Maintenance Procedures and Process Safety information to participating as a member of a Process Hazard Analysis team. In addition, Lybrook has a number of initiatives that address Process Safety, Risk Management, and accident prevention. These initiatives include: X Forming teams promoting process safety X Forming teams promoting the safety and health of all individuals Members of the teams represent various areas and functions of the plant. Process Safety Information (PSI) The Lybrook Facility keeps a variety of technical documents that are used to help maintain the safe operation of covered processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis information. This information, in conjunction with written procedures and trained personnel provides a basis for establishing inspection and maintenance activities, as well as for eval uating proposed process and facility changes to ensure that safety features in the process are not compromised. Process Hazard Analysis (PHA) The Lybrook Facility has a comprehensive program to ensure that hazards associated with the various processes are identified and controlled. These processes are systematically examined to identify hazards and ensure that adequate controls are in place to manage identified hazards. PHA methods utilized for identifying hazards include: X -What if Process X Hazop Techniques PHA's are conducted utilizing a team of people who have operating, maintenance, and engineering expertise. This team identifies and evaluates hazards of the process along with accident prevention, and mitigating measures. The team addresses suggestions for additional prevention measures when appropriate, and forwards their findings and recommendations to management for resolution. The findings are classified according to relative risk rankings assigned by the PHA team. Th is ranking ensures that the potential accident scenarios that are assigned the highest risk will receive immediate attention. All approved action items resulting from the PHA team's findings are tracked until brought to completion. All PHA's team findings, recommendations, and tracking status are documented and retained. Revalidation of all PHA's is conducted on a 5-year cycle. Procedures Operating Procedures Lybrook maintains written operating procedures providing clean instructions that address various modes of process operations, including: X Initial startup X Normal operations X Temporary operations X Emergency shutdown X Emergency operations X Normal shutdown X Startup after turnaround These procedures can be used as a reference by experienced operators and provide a basis for consistent training of newly assigned operators. Procedures are reviewed and verified annually to reflect current operations. Maintenance Procedures Lybrook maintains written maintenance procedures prov iding clear guidance in reference to the on-going integrity of all process equipment, including: X Training of newly assigned operators X Testing and Inspection of process equipment X Best Work Practice X Quality Assurance Maintenance Procedures, Best Work Practices, Vender Manuals, and the Plant Training Manual is used as a reference by experienced operators and provide a basis training of newly assigned operators. Maintenance Procedures are integrity into the facility Training Management Program ensuring procedures are review and verified annually to reflect current operations. Contractors The Lybrook Facility uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the facility has procedures in place to ensure that contractors comply with the following: X Perform their scope of work in a safe manner X Are aware of hazards involved within the workplace X Understand and verify contractors knowledge of emergency requirements X Understand and verify contractors follow site safety rules X Inform plant personnel of any hazards identified while performing their scope of work This is accomplished by providing contractors with the following prior tot the start of their assigned project: X Process Overview X Information about Safety and Health Hazards X Emergency Response Plan Requirements X Safe Work Practices X Best Work Practices Lybrook personnel periodically conduct safety audits, work assessments, and evaluations on contractor performance ensuring working is completed in a safe manner. Pre-startup Safety Reviews (PSSR's) Lybrook conducts a PSSR on any Plant modification that requires a change in process safety information. The purpose of the PSSR is to ensure those safety features, procedures, personnel, and equipment are appropriately prepared for startup before placing the process and equipment into service. This review provides an additio nal check verifying construction is in accordance with design specifications and that all-supporting systems are operationally ready. The PSSR utilizes a checklist to verify the modification readiness; it involves field verification of the construction and serves a quality assurance function by requiring verifications that the accident prevention program requirements are properly implemented. Mechanical Integrity Lybrook has well established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps, compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this program includes: X Employee training X Developing written procedures X Inspecting equipment X Testing and correcting identified deficiencies X Applying quality assurance measures Collectively, these activities form a system that maintains the Mechanical Integrity of the process. Safe Work Practices Lybrook has established safe w ork practices to ensure worker and process safety examples of these practices include: X Methods for controlling plant entry of support personnel X Methods for controlling presence of support personnel X Methods for controlling exit of support personnel X lockout/tagout procedures to ensure isolation of energy sources for equipment undergoing maintenance Hot work procedures and permits are used whenever the work involves the potential for generating ignition sources in the presence of flammable or combustible material. Confined space entry permits and procedures are used to ensure that adequate precautions are in place before entry is allowed into a permit required confined space. The use of written safety procedures and safe work practices along with training of affected personnel, helps to ensure that operations and maintenance activities are performed safely. Training Lybrook has implemented a comprehensive Training Management Program for all employees involved in operating a pr ocess. New employees receive basic training in the safe operation of the process. New employees are then paired up with an experienced operator to learn process specific duties and tasks. Upon completion of a verification and skill demonstration program, after the operator demonstrates having adequate knowledge to perform the duties and tasks assigned in a safe manner the operator is authorized to work independently. In addition, all operators receive refresher training every three years and/or as necessary to ensure that their skills and knowledge are maintained at an acceptable level. All training is documented for each operator including the means used to verify that the operator understood the training. Management of Change Lybrook has a comprehensive system to manage change to all covered processes. This system requires that change to items such as: X Process equipment X Chemicals, technology, (including process operating conditions) X Procedures X Other facility changes be reviewed and authorized before being implemented. Changes are reviewed to ensure that adequate controls are in place to manage any new hazards and to verify that existing controls have not been compromised by the change. Process operating limits, equipment information as well as procedures affected are updated appropriately. In addition, training is provided and verified to operating and maintenance personnel as required by the change. Incident Investigation Lybrook safety committee members along with management promptly investigates all incidents that resulted in, or could have resulted in a fire, explosion, gas release, property damage, environmental loss, and/or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations, and forwards these results to management for resolution. The final resolution of each finding is documented and the investigation results are reviewed with all affected employees and contractors. Incident investigation reports are retained for at least 5 years and addressed during future PHA's and PHA revalidation. Compliance Audits Lybrook personal conduct audits on a regular basis to ensure that the facility is in compliance with applicable regulatory compliance procedures and directives. Audits are conducted at least every three years. All corrective actions taken in response to audit findings and recommendations are tracked through completion. The final resolution of each finding is documented and the two most recent audit reports are retained at the facility. Five-year Accident History Lybrook has had an excellent record of preventing accidental releases over the last 5 years. As a result of the plant's stringent release prevention policies, there has not been a single release of a regulated substance. Emergency Response Program Information Lybrook maintains a written emergency response program to protect employees, contractors, public and the environment from hazards associated with accidental releases of regulated substances. The program consists of procedures for responding to releases of regulated substances, including the possibility of associated fires or explosions. The procedures address all aspects of emergency response, including evacuation plans, accounting for personnel after an evacuation and notification of local emergency response agencies and the public. Employees receive training in these procedures annually to perform emergency response duties. The program is updated when necessary based on modifications made to cover processes. The overall emergency response program for Lybrook is coordinated with San Juan Local Emergency Planning Committee (LEPC). This coordination includes attending periodic committee meetings, which include local emergency response officials and industry representatives. Lybrook has 24 -hour communications capability with San Juan's LEPC, in addition Lybrook Plant conducts monthly table top mock emergencies with personnel and annual emergency drills that involve the LEPC and emergency reponses organizations. Planned Changes to Improve Safety Lybrook Facility in an effort to address all PHA action items has made modifications to its process. The following types of changes are planned in response to PHA, Safety Audit and Incident Investigation action items. X Evaluate and Re-certify ESD System X Install PSV's on some vessels complying with code requirements X Validate, Repair, and/or replace Fire Eyes as required |