Eustace Plant - Executive Summary
Accidental Release Prevention and Emergency Response Policies |
The Eustace Plant is committed to protecting the health and safety of company personnel, contractors working in the facility, our neighbors in the surrounding community and the environment. This commitment is strongly supported by senior management and is demonstrated by the resources invested in accident prevention, such as employee training and in considering safety in the design, installation, operation, and maintenance of our facility. This location implements both administrative and engineering controls to reasonably minimize the risk of an uncontrolled release of a hazardous substance. The facility does not anticipate having any type of uncontrolled release. However if an uncontrolled release does occur, the personnel at the facility in cooperation with local response agencies are trained to respond, minimize and/or eliminate any exposure that could occur to protect employees and the surrounding area.
of the Stationary Source and Regulated Substances
The Eustace Plant is a facility which receives raw natural gas from well production. The raw gas is dehydrated and contaminants removed. Marketable natural gas is delivered via pipelines. Natural gas liquids are extracted and stored on site. The extracted natural gas liquids include ethane, propane, butanes, and pentane as pure products or in mixtures that are delivered to market via pipeline and transport vehicles. There are no listed toxic substances which exceed their respective threshold quantities stored at this facility.
Hazard Assessment - Worst Case Scenario
The Worst Case Scenario for this facility is for flammables and would be a failure of a NGL storage tank releasing the entire contents instantaneously to the atmosphere; having an offsite impact. EPA's OCA Guidance was used to calculate this release scenario. This type of scenario is very unlikely to occur. In addition qualified individuals operate this facility d
aily; the equipment is inspected and maintained according to a preventive maintenance schedule further reducing the likelihood of this occurrence.
Hazard Assessment - Alternative Release Scenario
The Alternative Release Scenario for this facility is for flammables and would be a failure of the NGL Product Pump piping, thus releasing the entire contents of the NGL tank in a 10-minute period. The result of the release would have an offsite impact. EPA's OCA Guidance was used to calculate this release scenario. Qualified individuals operate this facility daily, the equipment is inspected and maintained according to a preventative maintenance schedule, which further reduces the likelihood of this release occurring.
Accidental Release Prevention Program
This facility is regulated by 29CFR 1910.119 (Process Safety Management of Highly Hazardous Chemicals), 1910.38 (Employee Emergency Plans), 1910.120 (Hazardous Waste and Emergency Response), 40CFR 112 (Spill Prevention Control and C
ountermeasure), RCRA and State and Federal EPCRA Rules/Laws, as well as other federal, state and local regulations which are all developed to reduce the potential for the release of Highly Hazardous Chemicals.
This facility has implemented the Process Safety Management of Highly Hazardous Chemicals along with additional requirements of the Risk Management Program as the Accident Release Prevention Program. There are other practices and measures, which are contained in numerous plans and procedures that all assist to prevent the release of Highly Hazardous Chemicals. Facility accident prevention programs promote the pro-active identification, evaluation, and mitigation or prevention of releases of highly hazardous substances that could occur as a result of failures in processes, procedures or equipment. The implementation of The Employee Participation Program requires the development of the necessary expertise, experiences, judgement, and proactive initiative within the workforce.
An established comprehensive training program has been developed and implemented at the facility. All employees are trained in an overview of the process as well as in appropriate safe work practices per the corporate safety guidelines. In addition to the training required of all employees, personnel having responsibilities under the operating and maintenance procedures are trained in those procedures.
Safe work practices have been developed to ensure safe operations that are consistent with industry practice and meet regulatory requirements. Safe work practices include site control, lockout/tagout, line breaking, confined space entry and hot work to ensure the safety and well being of employees and the surrounding area.
This facility has a policy of investigating every incident, which may have possibly resulted in a release to prevent a similar accident from recurring.
The Company has established an audit procedure to assure the continued integrity of the prevention program. En
suring the safety and well being of employees and the surrounding area.
5 Year Accident History
The Eustace Plant has had an excellent accident prevention program over the last five- (5) years. There have been no releases of listed Hazardous Substances which resulted in offsite effects.
Emergency Response Program
The Eustace Plant maintains a written emergency response plan to protect workers, ensure public safety and to protect the environment. The plan details the procedures for responding to an emergency, including the release or potential release of a hazardous substance. The procedures include instruction for response, communication, first aid, evacuation, accounting for personnel, company and agency notification procedures, and post incident cleanup and decontamination. All emergency equipment is maintained following established procedures. Employees are trained in the procedures and use of equipment appropriate to their role in the response effort. The emergency response
plan is coordinated with the local emergency responders such as local law enforcement, local and state government officials, and the local emergency planning committee.
Planned Changes to Improve Safety
The plant personnel are continually developing new ways to improve the safety of the facility. This is done through responsibility matrices and training which is a vital part of any safety program. Training is conducted according to a systematic schedule so employees and contractors are given the most up to date programs that are on the market today. All new and modified equipment is designed with appropriate safety controls and devices.