Lost Hills Gas Processing Plant - Executive Summary |
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Aera Energy LLC Lost Hills Gas Processing and Storage Facility Risk Management Plan Executive Summary ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES Aera Energy's Lost Hills Gas Processing and Storage Facility(Gas Plant) has a 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 gas processing facility. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, plant personnel will respond to control and contain the release. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES The Lost Hill Gas Plant located near 15609 Lost Hills Road in Lost Hills, , California was recently acquired in April 1999 from Texaco California Operations. The facility is presently being integrated into Aera Energy LLC operations and management system. The facility compresses , distills, and dehydrates natural gas products from oil and gas wells at Aera Energy's Lost Hills production field. This marketable products produced at the Lost Hills gas plant are natural gasoline/butane mix , and propane. The plant intermittently loads these products through a loading rack into MC 331 tanker transports. The propane is a flammable gas liquefied under pressure. The Natural gasoline is a flammable liquid with mixed with varying amounts of butane and isobutane.. Regulated substances are propane and the natural gasoline/butane mix. OFFSITE CONSEQUENCE ANALYSIS RESULTS The worst-case scenario (WCS) associated with a release incident at the Lost Hills gas plant is a vapor cloud explosion (VCE) involving the full inventory of the largest storage t ank of propane. The release amount would be 270,000 pounds, which is assumed to release and ignite, resulting in a VCE. The maximum distance to the 1-psi endpoint for this WCS is 0.50 miles. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for passive measures was taken into account in evaluating this WCS. No listed public receptor are within this distance. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM The following is a summary of the accident prevention program in place at the facility. Because processes at the gas plant facility are regulated by the Environmental Protection Agency's (EPA) risk management program (RMP) regulation , they are also subject to Cal/OSHA's process safety management (PSM) standard. This summary addresses each of the PSM elements and describes the management system in place to implement the accident prevention plan. Management System for RMP and PSM Aera Lost Hills gas plant management system is under development in order to define all elements required by the process safety standard and risk management program. The management system defines for each program element the following: 1. Purpose and scope of element 2. Specific procedures 3. Responsible and accountable personnel using a RACI (responsible, accountable,consult,inform) chart, 4. Verification and measurement metrics 5. Feedback mechanism 6. Document locations for applicable documents Employee Participation The Lost Hills Gas 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 documents and chemical information, to participating as a member of a process hazard analysis (PHA) team. Employees have access to all information created as a part of the Lost Hills gas plant accident prevention program. Specific ways that employees can be involved in the accident prevention program are doc umented in the employee participation plan that is maintained at the facility and addresses each accident prevention program element. In addition, Aera Lost Hills gas plant is utilizing behavior based safety management (BBSM), an employee directed process to observe and review operations to assure safe behaviors are maintained and unsafe behaviors are corrected with peer feedback and corrective action plans. Process Safety Information The Lost Hills gas plant keeps 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. Specific personnel within the facilities are assigned responsibility for maintaining up-to-date process safety information. A table summarizing the reference documents and their location is readily available as part of the management sy stem. Chemical specific information, including exposure hazards and emergency response/exposure treatment considerations is provided in material safety data sheets (MSDS's). This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For specific process areas, the facility has documented safety related limits for specific process parameters (e.g. pressure, tank levels, temperature) in a key process parameter document. The facility ensures that process is maintained within these limits using process controls, and monitoring instruments, trained personnel, automated shutdown systems. The facility maintains numerous technical documents that provide information about the design and construction of process equipment. The information includes materials of construction, design pressure, temperature ratings, and electrical ratings of equipment. This information, in combination w ith written procedures and trained personnel, provides the basis for establishing inspection and maintenance activities, as well as evaluating proposed process and facility changes to ensure that safety features are not compromised. Process Hazard Analysis (PHA) Lost Hills gas plant PSM facility has a comprehensive program to ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate safeguards are in place to manage these hazards. Aera's Lost Hills gas plant primarily use the hazard and operability (HAZOP) analysis technique to perform these evaluations. The analyses are conducted by a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures. The team makes suggestions for additional prevention and /or mitigation measures when the team believes such measures are necessary. The PHA teams findings are forwarded to local management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. The ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All approved mitigation options 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 eventually deviate significantly from original design safety features, the facilities periodically updates and revalidates the hazard analysis results. The periodic 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 Lost Hills gas plant maintains written procedures that address various modes of pr ocess operations, such as (1) unit start up, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial start up of a new process. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. These procedures are periodically reviewed and annually certified as current and accurate. The procedures are kept current and accurate by revising them as necessary to reflect changes made through the management of change process. Training To complement the written procedures for process operations, Aera's facilities have implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in plant operations if they not already familiar with such operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators dem onstrate (e.g. through tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training on the operating procedures to ensure their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every 3 years. All of this training is documented for each operator, including the means used to verify the operator understood the training. Contractors Aera Energy uses contractors to supplement its workforce for maintenance, inspection and construction activities. Because some of the contractors work on or near process equipment, Aera's facilities have 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 their workplace, (4) understand and follow site safety rules, and (6) inform gas plan t personnel of any hazards that they may find during their work. This is accomplished by providing contractors with (1) a 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, Aera evaluates contractor safety programs and performance during the selection of a contractor. Plant personnel periodically monitor and audit contractor performance to ensure that contractors are fulfilling their safety obligations through the internal safety and environmental auditing (ISEA) process. Pre-startup Safety Reviews(PSSR's) The Lost Hills gas 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 equipment are appropriately prepared for start up prior to placing equipment into service. The review provides one additio nal check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves as a quality assurance function by requiring verification that accident prevention programs are properly implemented. Mechanical Integrity (MI) Aera's facilities has established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems are 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 process that maintains the mechanical integrity of the process. Personnel invo lved in maintenance activities receive training on (1) a overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to ensure that they can perform their job in a safe manner. Written procedures help ensure that work is performed in a consistent manner and provide a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended and to verify that equipment is within acceptable limits (e.g. adequate wall thickness for pressure vessels). If a significant deficiency is identified, employees will correct the deficiency before placing the equipment back in service (if possible), or a management of change team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. Another integral part of the mechanical integrity program is quality assurance. Aera Lost Hills gas plant opera tions incorporate quality assurance measures into the equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. Safe Work Practices Aera's safe work practices are 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 energy control procedure to ensure the safe isolation of energy sources for equipment undergoing maintenance, (3) procedures for safe removal of hazardous substances before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (hot work), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. Management of Change Aera has a comprehensive system to manage changes to all covered processes. The 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 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 training on the change. Incident Investigation Aera promptly investigates all incidents, which results in or could have reasonably resulted in a major accident, which also includes near misses. The goal of each investigation is to determine the facts, iden tify causal factors and root causes, then develop corrective actions to prevent a recurrence of the incident or a similar incident. Aera uses the Taproota root cause methodology for this level of incident investigation. The investigation team documents its findings, develops recommendations to prevent recurrence, and forwards these results to local management for resolution. Corrective actions taken in response to the investigation teams 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 reports can be reviewed during future PHA's and PHA revalidation. Compliance Audits To help ensure that the accident prevention program is functioning properly, Aera periodically conducts an audit to determine whether the p rocedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. Both hourly and staff personnel participate as audit team members. The audit team develops findings that are forwarded to local 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 two most recent audit reports are retained. CHEMICAL-SPECIFIC PREVENTION STEPS The processes at the Lost Hills Gas Plant have hazards that must be managed to ensure continued safe operation. The following is a description of the existing safety features applicable to prevention of accidental releases of regulated substances in the facility. Universal Prevention Activities The accident prevention program summarized previously is applied to all RMP-covered processes at Aera Lost Hills Operating Area. Collectively, these preven tion program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. Specialized Safety Features The Lost Hillse Gas Plant has safety features on many processes to help (1) contain/control a release, (2) quickly detect a release, and (3) to reduce the consequences of a release. The following types of safety features are used in the covered processes: Release Detection 1. Low pressure alarms and subsequent actuation of shutdown valves(SDV's) for loading rack 2. LEL gas detection is present throughout the plant to detect flammable vapors or gases Release Containment/Control 1. Valves to permit isolation of the process 2. Automated and manual shutdown systems for specific process parameters 3. Plant sloping and curbing to contain liquid releases 4. Redundant equipment and instrumentation (e.g. uninterruptible power supply for process control system, generator, process monitoring ) 5. Atmospheric relief devices Rele ase Mitigation 1. 1500 gpm fire loop w/ hydrants attached with 750 gpm fire monitors some with AFFF foam eductors. The fire loop has a diesel fire pump, electric pump and jockey pump. 2. Personal protective equipment (e.g. fire resistive clothing) FIVE-YEAR ACCIDENT HISTORY Lost Hills Gas Plant has had an good record of accident prevention over the last 5 years. There has been no reportable incidents either onsite or offsite at this facility. EMERGENCY RESPONSE PROGRAM INFORMATION Aera Energy maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of fire or explosion. The primary action of Aera gas plant personnel is to actuate emergency shutdown(ESD) and evacuate the plant. The plans address credible events, including proper first aid and medical treatment for exposures, evacuation plan an d accounting for personnel after an evacuation, notification of local emergency response agencies, post incident clean up and decontamination. The primary public response agency is Kern County Fire Department. In addition, both plants have scheduled procedures that address the maintenance, testing, and inspection of emergency equipment. All Aera operation personnel attend a annual 24 to 32 hour health and safety training which involves classroom, field simulations and scenarios. The emergency action plan is updated when necessary based upon modifications to the plants or facilities. PLANNED CHANGES TO IMPROVE SAFETY The following types of changes are planned over the next few years to continuously improve safety and operations: - Upgrade process control system - Upgrade gas detection system - Develop Emergency Response plan to define initial actions (both offensive and defensive) and increase emergency capability of gas plant operations personnel. - Formalize, train and equi p an Emergency Response Team (ERT) to respond to hazmat, process fire, confined space, medical emergencies and directly support public emergency agencies |