Dillard A-1 Dehydrator Facility - Executive Summary

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Safety Information 
The chemicals stored at the facility will be NGL, made up of propane, butane, pentane and heavier than pentane compounds, and ethylene glycol.  Material Safety Data Sheets will be maintained for the stored chemicals. 
Equipment Inventory:  process skid made up of a gas/gas exchanger, chiller barrel, cold separator, stabilization tower, refrigerant condensing coil, refrigerant accumulator, glycol regenerator, glycol accumulator, glycol injection pump, glycol circulation pump; 250 gallon propane tank; 250 gallon glycol tank; electricity generator; 500 gallon triethylene glycol tank; glycol dehydrator; 18,000 gallon LPG tank; 300 BBL produced water tank. 
The process skid was manufactured in 1986 by HYD-PRO INC. of Odessa, TX.  The heat exchangers were manufactured by ALCO PRODUCTS, a division of NITRAM ENERGY, INC. of Wichita Falls, TX.  The ratings are as follows:  gas/gas exchanger-980 psi for the shell, 980 psi for the tube, -20 F to 150 F temperature range; chille 
r barrel-980 psi for the shell, 300 psi for the tube, -20 F to 150 F temperature range; stabilization tower-250 psi for the tube, 700 psi for the shell, a high temperature range of 125 F;  cold separator is a 24" x 10' s/s three phase vessel rated at 1000 psi. 
The facility is surrounded by a six foot fence with a gate that is locked when the operator is not present.  The load line valve will be locked with a padlock when the LPG is not be off-loaded, to prevent accidental release or vandalism. 
The process design is in compliance with recognized and generally accepted good engineering practices.  All safety information will be updated in the event of an equipment change or modification. 
Hazard Review 
Very few hazards are associated with this process.  Propane refrigerant, when exposed to atmospheric pressures, is extremely cold (-45 F) and should not be handled.  The glycol used for hydrate inhibition and stabilization heat is hot (245 F) and should not be handled.  Gas flowing thro 
ugh the exchangers and vessels is under pressure and should be treated accordingly. 
The opportunities for an accidental release would include an equipment failure or a deliberate act by the plant operator.  Equipment failure will be minimized by the regular testing of the PSV for their respective limits.  Thorough training of the plant operator is conducted to address any potential for accidental or diliberate release.  Monitoring of the equipment several times a day for an extended period of time (1-2 hours daily) will provide the opportunity to detect any imminent  condition which may lead to an accidental release. 
Operating Procedures 
A written operating procedure is provided to safely conduct all activities associated with the operation of the refrigeration plant.  These procedures address the following: 
-initial start-up 
-normal operations 
-emergency shut-down 
-normal shut-down 
-start-ups following normal emergency shut-downs 
-consequences of not following operating procedures 
-tell-tale signs of developing problems 
-equipment inspections 
The operating procedures will be updated whenever a change in the operation occurs. 
All operators of the refrigeration plant will be trained and deemed competent to operate the facility.  Constant communication with the operator ensures that the operator understands and adheres to the current operating procedures of the process. 
Ongoing maintenance of the refrigeration plant will be performed to ensure the accuracy and proficient operation of the thermometers, pressure guages, liquid level controllers, dump valves, injection and circulating pumps and refrigerant compressor.  An maintenance concerns which affect the safe, efficient, and sanitary operation of the plant will be addressed immediately.  The operator will be trained in the hazards of the operation, and in how to avoid or correct unsafe conditions.  Daily inspections of the all items of the refrigeration plant will be performed as consis 
tent with good engineering practices. 
Compliance Audits 
The facility will be audited at least every three years by a team that includes a person knowledgable in the practices and procedures of this plan as well as someone knowledgeable in the operation of the equipment.  A report of the audit will be generated and the findings will be documented.  Documentation of the corrective actions taken to address all deficiencies will be provided.  The two most recent compliance audits will be retained. 
Incident Investigation 
Each incident which resulted in, or could have resulted in a catastrophic release will be investigated and will be initiated within 48 hours of the incident.  A summary will be prepared that will include the date of the incident, the date the investigation began, a description of the incident, contributing factors to the incident, and the resulting recommendations.  All recommendations will be addressed promptly and the corrective actions will be documented.  The findin 
gs will be reviewed with all affected personnel affected by the findings and the investigation summaries will be retained for five years.
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