Moores Orchard Plant - Executive Summary |
|
Accidental Release Prevention and Emergency Response Policies The Moores Orchard Plant is committed to protecting the health and safety of the two full-time contractors working in the facility, our neighbors in the surrounding community and the environment. This commitment is strongly supported by senior management, the Production Superintendent who offices at the plant, and is demonstrated by the resources invested in accident prevention, such as employee/contractor 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 th at could occur to protect plant personnel and the surrounding area. Description of the Stationary Source and Regulated Substances The Moores Orchard Plant is a facility that 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, butane and a pentane-natural gasoline mixture 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 an NGL storage tank releasing the entire contents instantaneously to the atmosphere and having an offsite impact. EPA's OCA Guidance was used to calculate this release scenario. This type of scenario is ve ry unlikely to occur. In addition, qualified individuals operate this facility daily. 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 a valve near the NGL storage tank, thus releasing NGL to the atmosphere over a 15-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 preventive maintenance schedule, which futher 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 Emegency Response), 40CFR 112 (Spill Prevention Control and Countermeasure), 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 proactive 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 (including Contractor) Participation Program requires the development of the necess ary expertise, experiences, judgement, and proactive initiative within the on-site workforce. An established comprehensive training program has been developed and implemented at the facility. All plant personnel 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 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 plant personnel 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 ha s established an audit procedure to assure the continued integrity of the prevention program so as to ensure the safety and well being of employees and the surrounding area. Five-Year Accident History The Moores Orchard Plant has had an excellent accident prevention program over the five years. There have been no releases of listed Hazardous Substances which resulted in offsite effects. Emergency Response Program The Moores Orchard 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. The Production Superint endent and contractors 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 the Production Superintendent 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. |