Galmish Loading Facilities - Executive Summary |
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General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities Consolidated Natural Gas Transmission's Galmish Loading and Storage Facilities 1. Accidental Release Prevention and Emergency Response Policies Consolidated Natural Gas's Galmish Loading and Storage Facilities are committed to employee, public, and environmental safety. This commitment is demonstrated by our 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. If a release does occur, our regular personnel are at hand to control and mitigate the effects of the release. CNG has contracted Weavertown Environmental Group as an Oil Spill Response Organization to provide additional emergency response expertise. Also, CNG will contact the Wetzel County Emergency Dispatc h to obtain additional resources from local Volunteer Fire Departments ( VFD), law enforcement agencies and emergency medical services. 2. The Stationary Source and the Regulated Substances Handled The title of the Galmish Loading and Storage Facility is self explanatory. This facility handles 4 regulated substances. Propane, Butane, and Isobutane [Propane, 2-methyl] are stored in spheres until loaded on tank cars or tank trucks. Propane can also be pumped back to the Hastings Extraction Plant to replenish the propane refrigeration system during start up operations. The fourth regulated substance at Galmish Loading and Storage Facility is Ethyl mercaptan [Ethanethiol]. Ethyl Mercaptan is used to odorize propane so that a leak of this otherwise odorless substance can be detected by smell. The maximum inventory of Propane at our facility is 1,712,000.00 lb. while Butane, Isobutane [Propane, 2-methyl] and Ethyl mercaptan [Ethanethiol] are present at our facility in quantities of 1,139,000.00 lb., 541,000.00 lb. and 12,700.00 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 scenarios, we have used Equations from Appendix D of the EPA's Off site Consequence Analysis Guidance. For alternative release scenario analyses, we have employed the equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 and 3 flammable substances as a class involves a catastrophic release from Propane Storage Sphere #2 in the Galmish Loading and Storage Facilities process. The scenario involves the release of 1,712,000 lb. of Propane. 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 0.97 miles is obtained corresponding to an endpoint of 1 psi overpressure. The affected population is approximately 200 people. The alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from Normal Butane Storage Sphere in the Galmish Loading and Storage Facilities. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 1,139,000 lb. of Butane in 10 minutes. The release is also controlled by active mitigation measures that include deluge system(s). Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 PSI overpressure is 0.56 miles. The affected population is approximately 100 people. 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 a ccidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with ASME B31.3. A number of processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119. We also have an air operating permit ID pending 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 CNG maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes at Galmish Loading and Storage Facility. Much of this information was discovered and or confirmed during the preparations for the Hazards and Operability Analyses for Process Safety Management. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified a nd controlled efficiently. The methodology used to carry out these analyses was Hazards and Operability Analysis. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of five years. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, Galmish Loading and Storage Facility maintains written operating procedures. These procedures address various modes of operation such as normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after an extended outage. The information is regularly reviewed and is readily accessible to employees involved in the processes. Training Galmish Loading and Storage Facility has a 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 every 3 years and more frequently as needed. Mechanical Integrity Galmish Loading and Storage Facility carries out documented maintenance checks on process equipment to ensure proper operations. 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. Beginning in 1996, Rohrback Cosasco was contracted to perform a mechanical integrity survey of the Galmish Loading and Storage Facility in conjunction with the Process Safety Management program. In the course of this study, Rohrback Cosasco performed ultrasound inspections of process equipment, piping and vessels to establish a baseline against which future corrosion and erosion can be measured. Additionally, this study has established a schedule for future ultrasound and visual inspections. Maintenance oper ations 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 Galmish Loading and Storage Facility to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-startup safety reviews (PSSRs)related to new processes and to modifications in established processes will be conducted as a regular practice at Galmish Loading and Storage Facility. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe st artup prior to placing equipment into operation. . Compliance Audits The Galmish Loading and Storage Facility conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation The Galmish Loading and Storage Facility 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 5 years. Employee Participation The Galmish Loading and Storage Facility believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to e xpress 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 in particular. An audit of the Employee Participation Policy was completed on 2/11/1999. Contractors CNG 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. Before any contractors are allowed to work at Galmish Loading and Storage Facility, they undergo an orientation conducted by the Process Safety Management team. During this orientation contractors are made aware of the known potential hazards related the contractor's work, the hazards of regulated substances within Hastings Extraction Plant, the safe work procedures insisted on by CNG, and familiarized with the Hot Work Permit Policy and the Lock Out/ Tag Out procedures used at the Hastings Extraction Plant. Contractors are informed of all the procedures for emergency response should an accidental release of a regulated substance occur, and this information includes evacuation routes and assembly points. 5. Five-year Accident History The Galmish Loading Facilities has had an excellent record of preventing accidental releases over the last 5 years and no reportable releases have occurred. 6. Emergency Response Plan The Galmish Loading Facilities carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, t he plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. Marshall/Wetzel County LEPC is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Currently, infrared and hydrocarbon detectors are being installed in the tanker truck loading area and a sprinkler system is being added to the same area. Also, emergency traffic control lights have been erected along West Virginia Route 20 to stop traffic in the event of a release of a regulated substance. While these traffic lights have no bearing on preventing releases, they are intended to aid us in controlling ignition sources. These changes are expected to be implemented by 12/31/99. Finally, caution lights which a re activated when tanker trucks begin exiting the facility became operational in January of this year. 8. Certification Statement 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. Name: Signature: Title: Date signed: |