Medford Fractionation Facility - Executive Summary

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KOCH HYDROCARBON COMPANY, a Division of Koch Industries, Inc. 
 
Medford Fractionation Facility, Medford, Oklahoma 
 
EXECUTIVE SUMMARY 
FOR  
THE RISK MANAGEMENT PLAN (RMPlan) 
 
 
 
Introduction and Policies 
 
Under the Koch Environmental Excellence Program (KEEP) at Koch Industries, Inc., we are committed to being associated with unmatched environmental performance as measured by our employees, customers, regulators, and the public.  Our KEEP management philosophy goals are achieved by the personal commitments of our employees and contractors, and by open communication with our employees, customers, neighbors, and with regulators. The accidental release prevention and emergency response programs we have at our facilities are part of the high standards we strive for through KEEP.  Our high standards are achieved by operating in compliance with all required environmental permits and regulations, by operating and maintaining our assets in such a manner that any unpermitted release will be uninten 
tional and acknowledged as unacceptable, by remedying any shortcomings found during regular audits of our facilities, and by reporting promptly to regulators any shortcomings found during the course of our audits as required by law. 
 
The Medford Fractionation Facility is one of many facilities operated by Koch Hydrocarbon Company, a Division of Koch Industries, Inc.  At the facility we receive natural gas liquids (demethanized raw feed) from natural gas facilities as feed stock totaling 180,000 barrels per day (bpd).  The liquid feed to the facility is split into five product streams in a series of fractionator columns:  E-P Mix, Propane, Isobutane, Normal Butane, and Natural Gasoline.  These five product streams are further purified to remove contaminants such as water, carbon dioxide, and to convert mercaptans to disulfides.  The purity products are stored and distributed to various customers via pipeline.  The facility is also equipped with three truck loading docks which allow puri 
ty products to be loaded or unloaded.  Methane, Ethane, Propane, Butane, Isobutane, Pentane, and Ethyl Mercaptan are the RMP flammable substances stored or processed at the facility.  There are no toxic substances present at the plant in amounts greater than threshold quantity.  The facility is classified as Program Level 3 under the regulation.  The purpose of this Risk Management Plan (RMPlan) is to provide information about our operations at the facility, our programs to prevent accidental chemical releases, our emergency response plans in case an accidental release should occur, our 5 year accident history, and our planned changes to improve safety at the facility. 
 
 
Worst Case and Alternative Release Scenarios 
 
As specified by the U. S. Environmental Protection Agency (EPA) RMP Regulations, our worst case release scenario for flammables would be the loss of all of the butane in our largest vessel causing a vapor cloud explosion.  In the case of the Medford Fractionation Facility,  
this would involve our 1,930,000 gallon butane tank.  Such a scenario is highly unlikely, however, using the EPA Offsite Consequence Analysis (OCA) methods, the distance that the resulting vapor cloud explosion could cause an overpressure of 1 psi would be approximately 1.7 miles.  An overpressure of 1 psi is EPA's threshold for measurable impacts.  Although we have numerous controls to prevent such releases (high level alarms, emergency shutdown, etc.) and to manage their consequences, no credit for any controls or mitigation measures was taken into account when evaluating this scenario.   
 
The alternative release scenario characterized as a more likely scenario which would involve offsite impacts is calculated to reach approximately 0.2 miles (approximately 1, 100 feet) from the release point.   This distance calculation is also based on the EPA OCA methods, which are known to overpredict the consequences of any potential release from such a scenario.  We have selected the alternativ 
e release scenario based on a release of gaseous EP mix due to the failure of a relief valve on the surge tank.  We have several mitigation measures in place to greatly reduce the chance that such an event could ever occur.  We continuously measure the pressure of all vessels at the plant.  If a pressure becomes too high, pressure transmitters will provide that information to the control room and an alarm will sound. The facility is manned 24 hours per day therefore, corrective action will be taken immediately.  We also conduct regular inspection of all relief valves thereby further reducing the possibility of relief valve failure.  The presence of these active mitigation measures serves to either prevent this scenario from occurring or minimize its impact if it does occur. 
 
We have discussed these potential hydrocarbon releases with our employees and with local emergency response officials in Grant County, thereby further reducing the possibility of any impact on the public. 
 
 
Prevent 
ion Program 
 
The Medford Fractionation Facility has been operating under the strict guidelines of the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) Program since 1992.  Our ongoing analysis of the potential hazards of our process, detailed training of our employees, and constant emphasis on safety have helped us avoid any serious accidents over the last 5 years.  Part of this program has also involved identifying and taking steps to avoid potential accidental chemical releases.  A few examples of the additional prevention features implemented at this facility include: 
 
?We provided overpressure relief valves on all pressurized vessels.  Additionally, level transmitters and alarms are present on all vessels in order to prevent overfilling. 
?We installed a continuous flare to ensure uninterrupted combustion of hydrocarbon vapors. 
?We provided containment berms around all aboveground storage tanks. 
?We installed hydrocarbon gas detectors throughout t 
he facility. 
?We provided a fire water system throughout the facility for fire fighting purposes. 
?We man the facility continuously to ensure immediate response to any emergencies. 
?We provided an evacuation alarm system in order to safely evacuate the facility during emergency situations.  
 
These safeguards as well as the vigilance of our trained employees have helped us operate safely at this facility since we built it in 1972. 
 
 
Five Year Accident History 
 
Two incidents resulting in onsite or offsite impacts from a hydrocarbon release have occurred at the Medford Fractionation Facility within the last five years.  The most recent incident occurred on January 17, 1997 and was due to a propane release during routine maintenance conducted on a process vessel.  The incident resulted in second and third degree cold burns to a Koch employee and subsequent medical treatment.  The second incident occurred on July 5, 1995 when an Op. Tech. lost control of an E/P sample hose and a release of  
EP mix caused cold burns on his left thigh.  There were no other injuries or consequences as a result of these incidents.  After conducting incident reviews, several safety measures including improved operation, maintenance, and employee training procedures were implemented to prevent their recurrence. 
 
 
Emergency Response Program 
 
We will continue to conduct emergency response preparedness activities and coordinate any emergency response actions necessary for the Medford Fractionation Facility with the Pond Creek Volunteer Fire Department (VFD) and the Medford VFD.  Also involved in emergency response for the facility would be the Grant County Sheriff and St. Mary's Hospital in Enid.  The Medford Fractionation Facility Plant Manager is responsible for coordinating all emergency actions.  A specific Emergency Response Plan for the facility is in place and that plan has been discussed with local officials, along with evacuation procedures, regular drilling, and training.  Our Emergency  
Response Program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. 
 
 
Planned Changes to Improve Safety 
 
Diligent compliance with our RMP Prevention Program forms the framework on which we will continue to improve the level of safety at the Medford Fractionation Facility.  Some of the key components of the safety improvements we expect to achieve are as follows: 
 
?The Management of Change provisions ensure that we consider the potential safety and health impacts of any change we make to process chemicals, technology, equipment or procedures. 
?The Process Hazard Analysis (PHA) provisions serve as a tool to ensure continual evaluation of potential hazards, thereby leading to continual improvements in our safety standards. 
?The Mechanical Integrity provisions ensure that process equipment and instrumentation are designed, constructed, installed and maintained to minimize the risk of hazardous releas 
es, thereby serving as an integral part of our safety program. 
?Internal and third party compliance audits will ensure we maintain and increase our level of safety protection. 
?An ongoing dialogue with the Grant County Emergency Management Director or his designate will ensure a constant state of readiness to respond to any potential emergencies, as well as a means to implement improvements as the need develops.  In this way, we shall bolster our strong commitment to the safety of our workers and the community. 
 
We encourage all interested citizens or community organizations to contact the Grant County Emergency Management Director for the latest information on emergency response for the county.  We plan to diligently integrate our response capabilities and personnel with those of the county on an ongoing basis.
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