Anton Irish CO2 Re-Injection Facility - Executive Summary
(a), Accidental Release Prevention and Emergency Response Policies |
Occidental Permian Ltd's. Anton-Irish CO2 Re-injection Facility (AICRF) is committed to operating and maintaining all of our processes (especially regarding the use of hazardous substances) in a safe and responsible manner. We use a combination of accidental release safeguards and programs. Along with emergency response programs to address the safety of our employees and the public, and to protect the environment. Our policy is to integrate process controls and administrative procedures that are designed to prevent the release of regulated substances. This document provides a brief overview of the risk management activities we have designed and implemented.
(b), Description of the Stationary Source and Regulated Substance Handled
The primary purpose of the Anton-Irish CO2 Re-Injection Facility is to collect CO2 from an oil production stream and recompress it for injection into oil formations enhancing oil recovery
. The plant includes facilities for the dehydration and compression of the gas up to the required injection pressure. In the future it will include facilities for the recovery and shipping, by truck, of heavier hydrocarbon liquids. In the past this facility did not contain toxics or flammables above the threshold quantities listed in 49 CFR 68. With the addition of the NGL Recovery and Shipping facilities, the quantity of flammable maintained at the facility will exceed the 10000-lbs.-threshold quantity. Our evaluation of the regulated substances involved in the AICRF process resulted in our classifying this as a Program Level 1 process with the pentane inventory being the source of our worst case scenario.
(c), Worst Case Scenario
The worst case scenario (WCS) for AICRF was associated with an instantaneous release and ignition, of material from one of the two pentane storage vessels, resulting in the vapor cloud explosion of the 150,000 lbs. inventory of pentane that will be s
tored in one of the facility's pentane storage tanks. Even though several safeguards and controls will be in place to prevent such a release and to manage the consequences, we took no credit for any passive mitigation in the WCS evaluation. Our WCS results in no offsite impact on any public or environmental receptor.
(d), General Accidental Release Prevention Program
AICRF qualifies as a Program Level 1 and is not required to have a specific prevention program. However, we do have an active PSM program, which incorporates accidental release prevention.
(e), Five-year Accident History
In our review of the AICRF incident records for the past five years, we found that AICRF has not experienced an accidental release, with off-site impact, from a covered process resulting in deaths, injuries, evacuations, sheltering in place, property damage or environmental damage.
(f), Emergency Response Program
AICRF maintains a written emergency action plan to control and contain an accidental
release of a regulated substance. Our plan considers all federal, state, and local regulatory requirements for emergency response planning. The plan is designed to respond to a release of a regulated substance and provides first aid and medical treatment for exposures. It also contains plans for evacuation, accounting for personnel after an evacuation, and notification of local emergency response agencies. We have coordinated our emergency response activities with the Hale County, Texas emergency response agencies. In the event of fire, explosion, or a release of the regulated substance from the process, entry within the distance to the specified endpoints may pose a danger to the public emergency responders. Therefore, public emergency responders should not enter this area except as arranged with the emergency contact indicated in the RMP plan.
(g), Planned Changes to Improve Safety
1. We will continue to develop and utilize a root cause failure methodology in analyzing any A
2. We will continue to develop and share management practices involving operations and maintenance activities between Occidental plants.
3. We will review our active process safety management program from time to time for appropriate improvements to the program.
Based on the criteria in 40 CFR 68.10, the distance to the specific endpoint for the worst case accidental release scenario for the pentane inventory is less than the distance to the nearest public receptor.
Within the past 5 years the AICRF process has had no accidental release that caused offsite impacts provided in 40 CFR 68.10(b)(1). No additional measures are necessary to prevent offsite impacts from accidental releases. In the event of fire, explosion, or a release of the regulated substance from the process, entry within the distance to the specified endpoints may pose a danger to the public emergency responders. Therefore, public emergency responders should not enter this area excep
t as arranged with the emergency contact indicated in the RMP plan. The undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete.