Pucket Plant - Executive Summary |
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1. Facility Policy: The management and employees of Growers Cooperative, Inc. are committed to the prevention of any accidental releases of anhydrous ammonia through the use of proper equipment, regular inspections, maintenance and training of all persons that work with anhydrous ammonia. Should an accidental release occur, this facility has worked with the local fire department and local emergency planning committee so they can plan for response to a release and minimize the impact of the release to people and the environment. 2. Facility Information: The primary activity at this facility is the storage and handling of anhydrous ammonia for sale to farmers. Anhydrous ammonia is received, stored and distributed for direct application to the soil as a crop production nutrient. The maximum quantity stored is 170000 pounds. This facility stores anhydrous ammonia in 2 tanks. 3. Worst-Case Scenario: Failure of the largest storage tank when filled to the maximum allowed capacit y of 85% would release the total contents or 80000 pounds of anhydrous ammonia as a gas in a period of ten minutes. Company procedures and equipment design standards limit the maximum filling capacity of tanks to 85% of capacity. The distance to the endpoint of dispersion based on the model used is 1.9 miles. Alternative-Case Scenario: The alternative-case scenario is assumed to be a release of 11908 pounds of anhydrous ammonia in a period of two minutes from the rupture of a 2 inch transfer pipe. The distance to the endpoint of dispersion is 0.6 miles. 4. Accidental Release Program: This facility complies with the various rules and regulations governing the storage and handling of anhydrous ammonia including ANSI K61.1, OSHA 29 CFR 1910.111 and regulations administered by the Department of Agriculture. Training is provided on safe anhydrous ammonia operations for employees. 5. Five-year Accident History: There have been no accidental releases of anhydrous ammonia for th e covered process at this facility in the past five years. 6. Emergency Response Program: This facility has a written emergency plan in accordance with OSHA Standards 29 CFR 1910.38 and 1910.120. Emergency planning and community right-to-know information is provided to the state emergency response commission, local emergency planning committee and local fire department as required by SARA Title III of EPCRA. 7. Planned Changes to Improve Safety: Safety improvement is an on-going process at this facility. Periodic inspections and evaluations are performed to assess the maintenance of safe practices and operations. There are no additional specific anhydrous ammonia safety recommendations for implementation at this time. HS Gathering's Hambert Compressor Station is not covered under OSHA's PSM Standard because it is a normally unoccupied remote facility. However HS Gathering has elected to use OSHA's PSM Standard as a model of good business practice at this compressor station even if it is "normally unoccupied remote facilities". Accidental Release Prevention and Response HS Gathering LLC 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, HS Gathering personnel are trained on how to respond to such emergencies. If the situation requires, HS Gathering will notify, cooperate with, and support the various emergency response agencies. Location and Regulated Substances HS Gathering's Hambert Compressor Station is located in Weld County, Colorado near the intersection of WCR 38 and WCR 35 in a rural area which is used primarily for farming. The Hambert Compressor Station consists of two compressor unit, #5 1 and #52, that discharge 18 MMCF/D through glycol dehydration to delivery points via a 20" cleanable pipeline. The discharge pressure is not to exceed 180 psig. The station is equipped with inlet seperation. Liquids separation (condensate) goes to four 225 barrel storage tanks. The purpose of a compressor station is to increase the pressure of the gas being transported in the pipelines and to reduce the dew point of the gas to a level that is acceptable for pipeline transmission. Each compressor station receives gas from various gathering lines and supplies the pipeline(s) that transports the gas to a processing plant. Control of the dew point is critical since the incoming gas contains moisture (water and heavy hydrocarbons). The amount of moisture in the gas varies from day to day depending on a great number of variables at the well heads. The dew point increases as the concentration of moisture in the inlet gas increases. As gas flows through the pipeline, its temperature will decrease to about the same temperature as the surrounding environment. If this temperature is below the dew point of the gas, the water and heavy hydrocarbons will tend to condense. The resulting buildup of hydrates can begin to restrict gas flow, particularly at orifices and bends in the pipe. In extreme cold, the hydrates may form a potentially dangerous ice plug. In order to reduce the dew point of the gas (minimize the formation of hydrates), the inlet gas is put through a slug catcher, an inlet separator, and a glycol contactor with scrubber to remove moisture. Compression of the gas causes some of the naturally occurring hydrocarbons, which are in the vapor phase of the inlet gas stream, to condense out of the stream. This allows heavy hydrocarbons and water to condense out of the gas resulting in a lower dew point. These condensed raw natural gas liquids (NGL), also called condensate, are stored in tanks until there is a sufficient volume to be pumped into a tank tr uck for transportation for processing into marketable products. The glycol is regenerated and used again. The flammability and volume of the raw NGL stored at The Hambert Compressor Station triggered coverage under the EPA RMP Standard. History and Ownership The Hambert Compressor Station was built by Panhandle Eastern Co in the mid 1970's. HS Resources entered into a purchase and sale agreement with Kinder Morgan Inc., formerly known as KN Energy, in December of 1999. KN Energy operated the system from April 1993 through December 1, 1999. Program Level HS Gathering has determined that Program Level 1 applies to the Hambert Compressor Station since it has a documented Emergency Response Plan which has been coordinated with the local Fire Department and has had no accidental release of the regulated substance (condensate) that directly or indirectly caused a death, injury, or response or restoration activity for an environmental receptor in the previous five years. Also, the fac ility's distance to a "public receptor" is greater than the distance to the calculated endpoint for the worst-case scenario of 0.1 miles. Offsite consequence Analysis Results The worst-case scenario (WCS) associated with flammable substances in a Program Level 1 process at the Hambert Compressor Station is a vapor cloud explosion resulting from a catastrophic tank failure in the condensate tank storage area. A written procedure is in place to limit the storage inventory to 80% of the maximum tank capacity. Therefore the reduced inventory is assumed, resulting in a release of 31,000 lbs. (approximately 5700 gals.) of condensate over a 10-minute period. Although we have various controls to prevent such releases and to manage their consequences, no credit for passive mitigation measures (such as dikes or berms) was taken into account in evaluating this scenario. The maximum distance to the 1-psi overpressure from a vapor cloud explosion of this material was 0.1 miles. No Program Le vel 2 or 3 processes containing regulated flammable substances were identified at the Hambert Compressor Station. Emergency Response Program The Hambert Compressor Station has established and maintains an emergency response plan that is coordinated with local response agencies. The goals of the program are to protect employees and the general public from the hazardous effects of releases and to minimize the effects of any releases. The program is routinely reviewed and updated to reflect station, personnel, and regulatory changes. Accident History During the last five years, there have been no accidents that meet the criterion for inclusion in this submittal Planned Changes for Improved Safety Ideas for changes to improve safety are actively sought from employees. Employee safety meetings that focus on safety issues, such as flammable substances, are held regularly. Employees are encouraged and trained to recognize hazards and present ideas to eliminate them or to minimize t he potential consequences of those hazards. HS Gathering's Hambert Compressor Station is not covered under OSHA's PSM Standard because it is a normally unoccupied remote facility. However HS Gathering has elected to use OSHA's PSM Standard as a model of good business practice at this compressor station even if it is "normally unoccupied remote facilities". Accidental Release Prevention and Response HS Gathering LLC 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, HS Gathering personnel are trained on how to respond to such emergencies. If the situation requires, HS Gathering will notify, cooperate with, and support the various e mergency response agencies. Location and Regulated Substances HS Gathering's Hambert Compressor Station is located in Weld County, Colorado near the intersection of WCR 38 and WCR 35 in a rural area which is used primarily for farming. The Hambert Compressor Station consists of two compressor unit, #51 and #52, that discharge 18 MMCF/D through glycol dehydration to delivery points via a 20" cleanable pipeline. The discharge pressure is not to exceed 180 psig. The station is equipped with inlet seperation. Liquids separation (condensate) goes to four 225 barrel storage tanks. The purpose of a compressor station is to increase the pressure of the gas being transported in the pipelines and to reduce the dew point of the gas to a level that is acceptable for pipeline transmission. Each compressor station receives gas from various gathering lines and supplies the pipeline(s) that transports the gas to a processing plant. Control of the dew point is critical since the incoming gas contains moisture (water and heavy hydrocarbons). The amount of moisture in the gas varies from day to day depending on a great number of variables at the well heads. The dew point increases as the concentration of moisture in the inlet gas increases. As gas flows through the pipeline, its temperature will decrease to about the same temperature as the surrounding environment. If this temperature is below the dew point of the gas, the water and heavy hydrocarbons will tend to condense. The resulting buildup of hydrates can begin to restrict gas flow, particularly at orifices and bends in the pipe. In extreme cold, the hydrates may form a potentially dangerous ice plug. In order to reduce the dew point of the gas (minimize the formation of hydrates), the inlet gas is put through a slug catcher, an inlet separator, and a glycol contactor with scrubber to remove moisture. Compression of the gas causes some of the naturally occurring hydrocarbons, which are in the vapor phase of the inlet gas stream, to condense out of the stream. This allows heavy hydrocarbons and water to condense out of the gas resulting in a lower dew point. These condensed raw natural gas liquids (NGL), also called condensate, are stored in tanks until there is a sufficient volume to be pumped into a tank truck for transportation for processing into marketable products. The glycol is regenerated and used again. The flammability and volume of the raw NGL stored at The Hambert Compressor Station triggered coverage under the EPA RMP Standard. History and Ownership The Hambert Compressor Station was built by Panhandle Eastern Co in the mid 1970's. HS Resources entered into a purchase and sale agreement with Kinder Morgan Inc., formerly known as KN Energy, in December of 1999. KN Energy operated the system from April 1993 through December 1, 1999. Program Level HS Gathering has determined that Program Level 1 applies to the Hambert Compressor Station since it has a documented Emergency Response Plan which has been coordinated with the local Fire Department and has had no accidental release of the regulated substance (condensate) that directly or indirectly caused a death, injury, or response or restoration activity for an environmental receptor in the previous five years. Also, the facility's distance to a "public receptor" is greater than the distance to the calculated endpoint for the worst-case scenario of 0.1 miles. Offsite consequence Analysis Results The worst-case scenario (WCS) associated with flammable substances in a Program Level 1 process at the Hambert Compressor Station is a vapor cloud explosion resulting from a catastrophic tank failure in the condensate tank storage area. A written procedure is in place to limit the storage inventory to 80% of the maximum tank capacity. Therefore the reduced inventory is assumed, resulting in a release of 31,000 lbs. (approximately 5700 gals.) of condensate over a 10-minute period. Although we have various contr ols to prevent such releases and to manage their consequences, no credit for passive mitigation measures (such as dikes or berms) was taken into account in evaluating this scenario. The maximum distance to the 1-psi overpressure from a vapor cloud explosion of this material was 0.1 miles. No Program Level 2 or 3 processes containing regulated flammable substances were identified at the Hambert Compressor Station. Emergency Response Program The Hambert Compressor Station has established and maintains an emergency response plan that is coordinated with local response agencies. The goals of the program are to protect employees and the general public from the hazardous effects of releases and to minimize the effects of any releases. The program is routinely reviewed and updated to reflect station, personnel, and regulatory changes. Accident History During the last five years, there have been no accidents that meet the criterion for inclusion in this submittal Planned Changes for I mproved Safety Ideas for changes to improve safety are actively sought from employees. Employee safety meetings that focus on safety issues, such as flammable substances, are held regularly. Employees are encouraged and trained to recognize hazards and present ideas to eliminate them or to minimize the potential consequences of those hazards. The worst-case release scenario would be the release of the total contents of a storage tank released as a gas over 10 minutes. The maximum quantity stored would be 114,000 pounds, which represents the volume of the storage tank at 85 percent capacity as limited by design standards. The distance to the endpoint (point of dispersion to 200 PPM0 is 2.32 miles.The alternative release scenario based on the five-year accident history or most likely potential incident, is a release from a break in a transfer hose. The distance to endpoint (point of dispersion to 200 PPM) is .83 miles. The facility has implemented the provisions of ANSI K-61 and O SHA 29 CFR 1910.111. We have also complied with EPA, DOT and the Kansas Department of Agriculture who inspects our facilities on an annual basis. These standards and regulations along with the safety culture and training our employees have been through have helped us achieve an outstanding safety record. There have been no accidental releases of anhydrous ammonia in the past five years that: have caused any deaths, injuries, or significant property damage at the facility: nor to our knowledge, have resulted in offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. The facility has a written emergency action plan, in accordance with OSHA and we report our regulated materials to the Community Right to Know program, the local fire department, and the County LEPC. Our safety efforts go beyond what the rules require; we do what is good for business. Our goal is to effectively serve the community we operate in and deliver quality service to ou r farmer owners. |