Antelope Ridge Gas Plant - Executive Summary

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LG&E Natural Gathering and Processing Company 
Antelope Ridge Gas Plant 
Risk Management Plan 
Executive Summary 
1.    Accidental Release Prevention and Emergency Response Policies 
We at the Antelope Ridge Gas Plant are strongly committed to employee, public and environmental safety.  This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility.  It is our policy to implement appropriate controls to prevent possible releases of regulated substances.  However, if such a release were to occur, we are completely coordinated with Eunice Fire Department, which provides trained emergency response personnel to control and mitigate the effects of the release. 
2.    The Stationary Source and the Regulated Substances Handled 
Our facility's primary activity is the operation of a Natural Gas Processing Plant.  We have seven r 
egulated substances present at our facility.  These substances include Methane, Ethane, Propane, Butane, Isobutane [Propane, 2-methyl], Pentane, and Isopentane  [Butane, 2-methyl-].  The regulated substances at our facility are components of the natural gas feed to the plant, the extracted liquid product, and the residue natural gas. 
The maximum inventory of Methane at our facility is 42,000 lb while Ethane, Propane, Butane, Isobutane [Propane, 2-methyl], Pentane, and Isopentane  [Butane, 2-methyl-] are present at our facility in maximum quantities of 35,000 lb, 35,000 lb, 21,000 lb, 13,000 lb, 14,000 lb and 16,000 lb respectively. 
3.    The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario 
To evaluate the worst case and alternative release scenarios, we have used the EPA's Offsite Consequence Analysis Guidance Reference Tables or Equations.  The following pa 
ragraphs provide details of the chosen scenarios. 
The worst case release scenario submitted for Program 3 flammable substances involves a catastrophic release from the "Gas Plant and Associated Operations" process.  The scenario involves the release of 73,012 lb of a flammable mixture that contains Ethane, Propane, Butane, Isobutane [Propane, 2-methyl], Pentane, and Isopentane  [Butane, 2-methyl-].  It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion.  Under worst case weather conditions, the maximum distance of 0.34 mile is obtained, corresponding to an endpoint of 1 psi overpressure. 
The alternative release scenario submitted for Program 3 flammable substances involves a release from the "Gas Plant and Associated Operations" process.  The release is assumed to result in a Vapor Cloud Explosion.  The scenario involves the release of 24,612 lb of a flammable mi 
xture that contains Ethane, Propane, Butane, Isobutane [Propane, 2-methyl], Pentane, and Isopentane  [Butane, 2-methyl-].  Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 PSI overpressure is 0.16 miles. 
4.    The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps 
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out in EPA's RMP (Risk Management Plan) regulations (40 CFR Part 68).  The Antelope Ridge Gas Plant is subject to OSHA's PSM (Process Safety Management) regulations (29 CFR 1910.119).  We have also applied for an air operating permit under Title V of the Clean Air Act.    The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. 
Process Safety Information 
The Antelope Ridge Gas Plant maintains a detailed record of safety information that describes the chemical hazards, op 
erating parameters and equipment designs associated with all processes. 
Process Hazard Analysis 
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently.  The methodology used to carry out these analyses is the "What If" method.  The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at least once every five years.  Any findings related to the hazard analysis are addressed in a timely manner.  The most recent PHA was performed on February 5, 1997. 
Operating Procedures 
For the purposes of safely conducting activities within our covered processes, the Antelope Ridge Gas Plant maintains written operating procedures.  These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround.  The inf 
ormation is regularly reviewed and is readily accessible to operators involved in the processes. 
Antelope Ridge Gas Plant has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes.  Refresher training is provided at least once every three years, and more frequently as needed. 
Mechanical Integrity 
The Antelope Ridge Gas Plant carries out highly documented maintenance checks on process equipment to ensure proper operations.  The most recent review/revision of maintenance procedures was performed on January 27, 1999.  Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps.  Maintenance operations are carried out by qualified personnel with previous training in maintenance practices.  Furthermore, these personnel are offered specialized 
training as needed.  Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. 
Management of Change 
Written procedures are in place at the Antelope Ridge Gas Plant to manage changes in process chemicals, technology, equipment and procedures.  The most recent review/revision of the management of change procedures was performed on December 10, 1998.  Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly notified of the modification.  They are also given any training required to safely deal with the modification. 
Pre-startup Reviews 
Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at the Antelope Ridge Gas Plant.  The most recent review was performed on December 7, 1998.  These reviews are conducted to confirm that construction, equipment, operating and maintenanc 
e procedures are suitable for safe startup prior to placing equipment into operation. 
Compliance Audits 
The Antelope Ridge Gas Plant conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented.  The most recent compliance audit was conducted on September 3, 1998.  These audits are carried out at least once every three years, and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. 
Incident Investigation 
The Antelope Ridge Gas Plant promptly investigates any incident that has resulted in, or could reasonably result in, a catastrophic release of a regulated substance.  These investigations are undertaken to identify the situation leading to the incident, as well as any corrective actions to prevent the release from reoccurring.  All reports are retained for a minimum of five years. 
Employee Participation 
The Antelope Ridge Gas Plant approaches process safety management and acci 
dent prevention on a team basis.  Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements.  In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses. 
On occasion, our company hires contractors to conduct specialized maintenance and construction activities.  Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out.  The Antelope Ridge Gas Plant has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes.  Contractors are also informed of all the procedures for emergency response to an accidental release of a regulated substance. 
5.    Five-year Accident History 
The Antelope Ridge Gas Plant has had an excellent record of preventing accidental releases.  Due to  
our stringent release prevention policies, there has been no accidental release during the last five year reporting period. 
6.    Emergency Response Plan 
The Antelope Ridge Gas Plant maintains a written emergency response plan to deal with accidental releases of hazardous materials.  The plan includes phone numbers for notification of Company response personnel, and notification of local emergency response agencies.  The plan is promptly updated to reflect any pertinent changes that have taken place. 
7.    Planned Changes to Improve Safety 
The developments and findings that result from the implementation of the various elements of our accidental release prevention program are routinely evaluated to determine whether any changes could be made to improve safety at our facility.  All of the changes that have been identified, to date, have been implemented.
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