Sea Robin Gas Processing Plant - Executive Summary |
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EXECUTIVE SUMMARY Amerada Hess Corporation U.S. Exploration and Production Sea Robin Gas Processing Plant United States Environmental Protection Agency - Risk Management Program CERTIFICATION STATEMENT To the best of the undersigned's knowledge, information, and belief formed after reasonable inquiry, the information submitted is true, accurate and complete. James L. Jordan Plant Superintendent March 30, 2000 ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The Sea Robin Gas Processing Plant has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as personnel training and considering safety as a primary factor 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, trained plant personnel will respond to control and contain the rel ease. To prevent accidental releases, the Sea Robin Gas Processing Plant achieves control of hazardous materials by: ? A commitment to OSHA's PSM and HAZWOPER standards and EPA's RMP regulations, which promote and require adherence to process safety activities, designed to prevent accidental releases. ? Development and use of Amerada Hess Corporation and Sea Robin Gas Processing Plant safety, operating, maintenance, emergency response, engineering design and construction policies, procedures and practices designed to eliminate potential causes of or sources for releases. ? Knowledge of and adherence to industry recognized standards, specifications and recommended practices that address and provide guidance for the proper design, construction and operation of facilities containing hazardous materials. ? A plant equipment inspection and testing program. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES Amerada Hess Corporation will assume operation of the Sea Robin Gas P rocessing Plant on April 1, 2000. The facility is located at 5624 Aristide Road near Henry, Louisiana. The plant was originally operated by Bridgeline Gas Distribution LLC, a subsidiary of Texaco Exploration and Production The plant was included in the initial RMP for the Texaco Henry Complex, Henry, Louisiana. The plant contains regulated flammables, such as Liquefied Petroleum Gas (LPG) and Natural Gas Liquids (NGL). The main components being Ethane, Propane and Butane within its process areas. OFFSITE CONSEQUENCE ANALYSIS RESULTS The worst-case scenario (WCS) for the Sea Robin Gas Processing Plant is a Vapor Cloud Explosion (VCE), involving 167,776 pounds of a flammable mixture contained in the Product Surge Drum. Although administrative controls are in place to limit this quantity, those controls were not considered in calculating this maximum quantity determination. The entire inventory of the storage tank is assumed to release, forming a vapor cloud, igniting and exploding - creating a Vapor Cloud Explosion (VCE). Using EPA' OCA Guidance Reference Tables, the maximum distance to the 1 psig overpressure endpoint is 0.4 miles (2,336 feet). Although there are numerous controls 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) that will be used as a planning case for the Sea Robin Gas Processing Plant is a product pump seal leak considered the equilvalent of an 0.50 inch hole diameter, causing a release of gas mixture stored under pressure as a liquid, to the atmosphere at a rate of 328 pounds per minute. This particular ARS is assumed to last for 10 minutes before operation of the isolation valves, pumps, fire monitor cooling water and/or other mitigating actions can be utilized to mitigate the release. Under this ARS, the released material is accidentally ignited -resulting in a fireball. Using EPA's OCA Guidance Refere nce Table 22, the maximum Distance to the Radiant Heat Dose of 5kw/square meters Exposure Duration for 40 seconds is 0.08 miles (414 feet) . With a radius of 0.08 miles, this ARS would extend outside of the Sea Robin Gas Processing Plant approximately 286 feet. This scenario extends off-site but does not impact a public receptor. This event was selected as being a practical scenario for use in emergency response planning. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM Processes at the Sea Robin Gas Processing Plant that are regulated by the Environmental Protection Agency's (EPA's) risk management program (RMP) regulation are also subject to the Occupational Safety & Health Administration's (OSHA's) Process Safety Management (PSM) standard. The Sea Robin Gas Processing Plant adheres to all applicable federal and state regulatory statutes. The following summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention prog ram at the plant. Employee Participation The Sea Robin Gas Processing 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 documentation and chemical information, to participating as members of a process hazard analysis (PHA) team, incident investigations, development of operating and maintenance procedures, participation in safety meetings. The PHA teams typically have members from various departments of the plant, including operations, maintenance, engineering, safety and environmental, and plant management. Employees have access to all information created as part of the plant accident prevention program. Process Safety Information The Sea Robin Gas Processing Plant maintains 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 process parameters and specific chemical inventories, and equipment design basis/configuration information. Chemical-specific information, including exposure hazards and emergency response is provided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. The plant ensures that the process is maintained within proper operating limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems such as automated shutdown systems. The plant also maintains numerous technical documents that provide information about the design and construction of the process equipment, materials of construction, design pressure and temperature ratings as well as the electrical ratings of the equipment. Process Hazards Analysis The Sea Robin Plant has a comprehensive program to help ensure t hat hazards associated with the various processes are identified and controlled. Within this program, each covered process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. The Sea Robin Plant primarily uses the hazard and operability (HAZOP) methodology to perform these evaluations. HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The analyses are conducted using a team of plant employees who have operating and maintenance experience in the process as well as representatives from engineering, safety, technical support and management. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and 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. Implemen tation of mitigation options in response to PHA findings is based on relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk rating, receive immediate attention. All approved mitigation options being implemented 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 significantly deviate from the original design safety features, the plant periodically updates and revalidates the hazard analysis results. The reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. Operating Procedures The Sea Robin Gas Processing Plant maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shut down, (5) normal shutdown, and (6) initial startup of a new operation or after maintenance activities. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new process operators. The procedures are periodically reviewed and annually certified as current and accurate. These procedures are readily available to operators and other plant personnel to safely perform their job tasks. Training To complement the written procedures for process operations, the plant has implemented a training program for all process operators. New operators receive basic training in plant operations if they are not already familiar with such operations. After successfully completing this training, a new operator works under the supervision of a senior operator to learn process-specific duties and tasks. After operators demonstrate (e.g., through tests, skills demonstration) that they possess adequate knowledge to perform the duties and tasks in a safe manner on their own, they are allowed to work independently. In addition, all operators periodically receive refresher training on the operating procedures to ensure their skills and knowledge is maintained at an acceptable level. This refresher training is conducted at least every 3 years. All training is documented for each operator, including the means to verify that the operator understood the training. Contractors The Sea Robin Gas Processing Plant uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors perform work on or near process equipment, the 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 the workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform plant personnel of any hazards t hat they may find during their work. This is accomplished by providing contractors with (1) 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 addition, the plant evaluates contractor safety programs and performance during the selection of the contractor. Plant personnel periodically monitor contractor performance to ensure that they are fulfilling their safety obligations. Pre-startup Safety Reviews (PSSR's) The Sea Robin 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 the equipment are appropriately prepared for startup prior to placing the equipment into service. Mechanical Integrity The Sea Robin Plant follows established 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 equipment. Another integral part of the mechanical integrity program is quality assurance. The plant incorporates quality assurance measures into equipment purchases and repairs. Safe Work Practices The Sea Robin 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 mater ials before the process piping or 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. Management of Change The Sea Robin Plant has a comprehensive system to manage changes to 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 been compromised 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 tr aining on the change. Incident Investigation The Sea Robin Plant promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental impact, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents findings, develops recommendations to prevent recurrence, and forwards these results to 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 affected by the findings. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidation. Compliance Audits To help ensure that the accident prevention program is functioning properly, the 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 3 years. The audit team develops findings that are forwarded to 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 audit reports are retained. CHEMICAL-SPECIFIC PREVENTION STEPS The Sea Robin Gas Processing Plant processes have potential hazards that are managed for continued safe operation. The following is a description of current safety features applicable to preventing accidental releases of regulated substances in the facility. Universal Prevention Activities The plant's previously summarized accident pre vention program is applied to RMP - covered processes. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. Specialized Safety Features The plant has safety features to provide a means of containing/controlling a release, detecting a release, and reducing the consequences of a release. The following types of safety features are used in the covered processes: Monitoring and detection systems include (1) Hydrocarbon gas detectors, (2) Operations personnel on site 24 hours per day providing routine surveillance, (3) Camera surveillance from the Control Room, (4) Audible and visual warning alarms, and (5) Programmable Logic Control (PLC) based system which provides real-time monitoring and control by plant operations personnel. Containment and process controls include (1) Relief devices to avoid overpressure of process equipment, (2) Emergency flare system to capture and incinerate episo dic releases, (3) Valves to permit process control or isolation (manual and automated controlled), (4) Interlocks and automated shutdown instrumented safety control systems for specific process parameter (e.g., high temperature, pressure, level, etc), (5) Curbing or diking for spill prevention, control and containment, and (6) Redundant equipment and instrumentation (e.g. back up power supply for the plant control system). Active and passive mitigation include (1) Fire suppression and extinguishing systems, (2) Emergency procedures to react to emergencies, and (3) Communications link with local emergency planning committee (LEPC). Release mitigation systems include (1) Fire suppression and extinguishing, (2) Coordination with emergency response personnel, and (3) Personal protective equipment (e.g. fire retardant clothing). FIVE YEAR ACCIDENT HISTORY Within the past five years, the process has had no accidental release that caused offsite impacts provided in the risk management pr ogram rule (40 CFR 68.10(b)(1). No additional measures are necessary to prevent offsite impacts from accidental releases. In the event of fire, explosion or a release of a regulated substance from the process, entry within the distance to the specified endpoint may pose a danger to public emergency responders. Therefore, public emergency responders should not enter this area except as arranged with the emergency contact indicated in the RMP. EMERGENCY RESPONSE PROGRAM INFORMATION The Sea Robin Gas Processing Plant maintains a written emergency response program, which is designed to protect worker and public safety and the environment. The program consists of procedures for responding to a release of regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures assures all aspects of emergency response, including proper first aid and medical treatment for exposures, evacuation plans and accounting for perso nnel 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. The emergency response program is updated when necessary based on modifications made to gas plant processes or other plant facilities. The overall emergency response program for the plant has in the past been coordinated with the Henry Volunteer Fire Department. Amerada Hess will continue to coordinate with local emergency responders PLANNED CHANGES TO IMPROVE SAFETY Amerada Hess Corporation has a strong commitment to personnel safety and health. Extensive efforts are undertaken to incorporate that safet y focus in the design and operation of the facility and the training of our personnel. We strive to maintain clear, concise, consistent and straightforward operating methodologies to ensure that the Sea Robin Plant is readily operable and maintainable. The safety program will be continuously monitored and modified to incorporate added value to our operations. |