EAST VEALMOOR GAS PLANT - Executive Summary
WTG Gas Processing, L. P. |
East Vealmoor Gas Plant
Risk Management Plan
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES
The WTG East Vealmoor Gas Plant has a long-standing commitment to worker and public safety. This commitment is demonstrated by our efforts in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, facility trained personnel will evaluate the situation, take actions within the capabilities of the facility, and/or notify the necessary outside agencies.
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES
The WTG East Vealmoor Gas Plant, located in Coahoma Texas, U.S.A., operates a variety of processes to produce Y-Grade petroleum products from natural gas. The WTG East Vealmoor Gas Plant has regulated flam
? Normal Butane
OFFSITE CONSEQUENCE ANALYSIS RESULTS
The worst-case scenario (WCS) associated with a release of flammable substance(s) at the WTG East Vealmoor Gas Plant is a vapor cloud explosion (VCE) involving the largest inventory of propane contained in a single vessel/storage tank. The maximum inventory in this vessel/storage tank is 180,000 pounds. The entire inventory is assumed to release and ignite, resulting in a Vapor Cloud Explosion (VCE). The maximum distance to the 1-psi endpoint for this WCS is 0.45 miles. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for passive mitigation measures was taken into account in evaluating this WCS.
Check Alternate Release
The alternative release scenario (ARS) for flammable substances at the WTG East Vealmoor Gas Plant is a vapor cloud explosion resulting from the release of propane from a transfer line, 46,000 pounds re
leased in 15 minutes. The maximum distance to the 1-psi endpoint for this event is 0.18 mile. This event was selected as being a practical scenario for use in emergency planning and response. There are no toxic substances held above the threshold quantities at the WTG East Vealmoor Gas Plant.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM
Following is a summary of the accident prevention program in place at the WTG East Vealmoor Gas Plant. Processes at the WTG East Vealmoor Gas Plant which are regulated by the Environmental Protection Agency's (EPA's) risk management program (RMP) regulation are also subject to the Occupational Safety and Health Administration's (OSHA's) process safety management (PSM) standard. This summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program.
The WTG East Vealmoor Gas Plant encourages employees to participate in all facets of process safety man
agement 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 part of the facility's accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that is maintained at the facility and addresses each accident prevention program element. In addition, the WTG East Vealmoor Gas Plant has a number of initiatives under way to address process safety and employee safety issues. These initiatives include forming teams to promote both process and personal safety. The teams typically have members from various areas of the plant, including operations, maintenance, engineering, and plant management.
Process Safety Information
The WTG East Vealmoor Gas Plant keeps a variety of technical do
cuments 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 inventories, and equipment design basis/configuration information. The WTG East Vealmoor Gas Plant currently has a Process Safety Management/Risk Management (PSM/RMP) Coordinator on site that assists in maintenance of up-to-date process safety information. A table summarizing the reference documents and their location is readily available as part of the written employee participation plan to help employees locate any necessary process safety information.
Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). For specific process areas, the facility has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in Operator Procedures Manual. The
facility maintains the process within these limits by using process controls and monitoring instruments, trained personnel, and protective instrument systems (e.g., automated shutdown systems).
The facility also maintains files that provide information about the design and construction of process equipment. This information includes materials of construction, design pressure and temperature ratings, and electrical rating of equipment. This information, in combination with procedures and equipment operating history, provides a basis for inspection and maintenance activities, as well as for evaluating proposed process and facility changes so that safety features in the process are not compromised.
Process Hazard Analysis (PHA)
The WTG East Vealmoor Gas Plant has a comprehensive program to identify and control hazards associated with the various processes. Within this program, each process is systematically examined to identify potential hazard controls in place to manage thes
e hazards, and recommend additional controls, as appropriate.
The WTG East Vealmoor Gas Plant uses hazard and operability studies (HAZOP's) which are conducted using a team of employees who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates potential hazards of the process as well as accident prevention and mitigation measures, and the team makes suggestions for additional prevention and/or mitigation measures.
The Process Hazard Analysis (PHA) team findings are forwarded to local management for resolution. Implementation of mitigation options in response to PHA findings are based on a relative risk ranking assigned by the PHA team. The approved mitigation options in response to PHA team findings are tracked until they are completed. The final resolution of each finding is documented and retained.
The facility periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least e
very 5 years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained.
The WTG East Vealmoor Gas Plant maintains written procedures that address various modes of process operations, such as:
(1) Initial startup
(2) normal startup
(3) normal operations
(4) temporary operations
(5) consequences of deviation
(6) normal shutdown
(7) emergency shutdown
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 maintained current and accurate by revising them as necessary through the management of change procedure to reflect the changes. In addi
tion, the WTG East Vealmoor Gas Plant maintains information on how to respond to upper or lower limit exceedances for specific process or equipment parameters. This information, along with written operating procedures, is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks.
To complement the written procedures for process operations, the WTG East Vealmoor Gas Plant has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in process operations if they are not already familiar with such operations. After successfully completing this training, a new operator is paired with a Head operator to learn process-specific duties and tasks. After operators demonstrate adequate knowledge to perform the duties and tasks in a safe manner on their own, they are allowed to work independently. In addition, all operators periodically
receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every 3 years, or more frequently upon request. All training is documented for each operator, including the means used to verify/demonstrate (e.g., via performance review, skill demonstrations and written tests) that the operator understood the training.
The WTG East Vealmoor Gas Plant uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the facility has 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 what they should do in the event of an emergency
(5) understand and follow site safety rules, and
(6) inform facility perso
nnel of any hazards that they 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, the WTG East Vealmoor Gas Plant evaluates contractor safety programs and performance during the selection of a contractor. Facility personnel periodically monitor contractor performance with regard to their safety obligations.
Pre-startup Safety Reviews (PSSRs)
The WTG east Vealmoor 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 see that safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check that construction is in accordance with the design specification
s and that all supporting systems are operationally ready. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented.
The WTG East Vealmoor Gas Plant has established practices and procedures to maintain
process equipment, pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems] 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
(5) applying quality assurance measures
In combination, these activities form a system that maintains the mechanical integrity of the process
Maintenance personnel receive training on:
(1) an overview of the process
(2) safety and health hazards
(3) applicable maintenance p
(4) emergency response plans
(5) applicable safe work practices to help ensure that they can perform their jobs in a safe manner.
Written procedures provide that work is performed in a consistent manner and serve as basis for training. Inspections and tests are performed to help verify that equipment functions, as intended and that equipment is within acceptable limits (e.g., adequate wall thickness for pressure vessels). If a deficiency is identified and the situation presents an immediate safety concern, the deficiency is corrected before placing the equipment back into service. This may require that a management of change team review the use of the equipment and determine what actions are necessary.
An integral part of the mechanical integrity program is quality assurance. The WTG East Vealmoor Gas Plant incorporates quality assurance measures into equipment purchases and repairs. This helps determine that new equipment is suitable for its intended use and that prope
r materials, and spare parts are used when repairs are made.
Safe Work Practices
The WTG East Vealmoor Gas Plant has long-standing safe work practices in place to help provide worker and process safety. Examples of these include
(1) control of the entry/presence/exit of support personnel
(2) a lockout/tagout procedure to isolate energy sources for equipment undergoing maintenance
(3) a procedure for safe removal of hazardous substances before process piping or equipment is opened
(4) a permit and procedure to control spark-producing activities (i.e., hot work)
(5) a permit and procedure to verify that adequate precautions are in place before entry into a confined space
These procedures (and others), along with training of affected personnel, form a system to help perform operations and maintenance activities safely.
Management of Change
The WTG East Vealmoor Gas Plant has a comprehensive system to manage changes to all covered processes. This system requires that chang
es 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) determine that adequate controls are in place to manage any new hazards
(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.
The WTG East Vealmoor Gas Plant promptly investigates all incidents related to a covered process that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective
actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to facility management for resolution. Corrective actions taken in response to the investigation team's 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 that the reports can be reviewed during future PHAs and PHA revalidations.
To help determine that the accident prevention program is functioning properly, the WTG East Vealmoor Gas Plant periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Complian
ce audits are conducted at least every 3 years. Both hourly and staff personnel participate in these audits. Any audit findings are developed by the audit team and are forwarded to facility 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 WTG East Vealmoor Gas Plant have hazards that must be managed for continued safe operation. Following is a description of 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 the WTG East Vealmoor Gas Plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be
caused by equipment failures and human errors.
Specialized Safety Features
The WTG East Vealmoor Gas Plant has safety features on many units to help:
(1) contain/control a release
(2) quickly detect a release
(3) reduce the consequences of (mitigate) a release
The following types of safety features are used in the covered processes:
1. Hydrocarbon and hydrogen sulfide detectors with alarms
1. Process relief valves that discharge to a flare to capture and incinerate episodic releases
2. Automated and manual valves to permit isolation of the process
3. Automated shutdown systems for specific process parameters (e.g., high temperature)
4. Curbing and/or diking to contain liquid releases
5. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system.
6. Atmospheric relief devices.
1. Fire suppression and extinguishing systems
2. Deluge system for specific equipmen
3. Personnel trained in emergency action
4. Personal protective equipment (e.g., chemical protective clothing, self-contained breathing apparatus)
FIVE-YEAR ACCIDENT HISTORY
The WTG East Vealmoor Gas Plant has an excellent record of accident prevention over the past 5 years. There have been no accidental releases of regulated substances that resulted in onsite or offsite effects during the prior five years at the WTG East Vealmoor Gas Plant. We investigate all incidents to determine ways to prevent similar incidents from recurring. The following table summarizes the number of incidents that have occurred during the past 5 years which had onsite or offsite effects.
1. There has been no accidents to report in the last five years.
Number of RMP Events with Onsite and Offsite Effects
1. There has been no events.
EMERGENCY RESPONSE PROGRAM INFORMATION
The WTG East Vealmoor Gas Plant maintains a written emergency response plan which is in place to help protect wor
ker and public safety as well as the environment. The plan identifies steps to be taken in case of an accidental release including: proper first aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs. In addition, the plant has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions, which address the use of emergency response equipment. Employees receive training on these procedures as necessary to perform their specific emergency duties. The emergency response plan is updated when necessary based on modifications made to processes or other WTG East Vealmoor Gas Plant facilities. The emergency response plan changes are administered through the MOC process, which includes informing and/or training affected personnel in the changes.
The overall emergency response program for the WTG East V
ealmoor Gas Plant has been coordinated with the Howard County, Local Emergency Planning Committee (Fire Marshal). The WTG East Vealmoor Gas Plant has around-the-clock communications capability with appropriate emergency response organizations (e.g., fire department, Police and Sheriff's office). This interface provides the means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, the WTG East Vealmoor Gas Plant conducts emergency drills that involve the LEPC and emergency response organizations, and the facility provides annual refresher training to local emergency responders regarding the hazards of regulated substances in the facility.
PLANNED CHANGES TO IMPROVE SAFETY
The WTG East Vealmoor Gas Plant resolves findings from PHAs, some of which result in modifications to the process. The following types of changes are expected over the next few years in response to PHA, safety audit
, and incident investigation findings:
(REVIEW HAZOPS FOR ITEMS)
? Hydrocarbon release detection system in the Clark compressor building
? Revisions to personnel training programs