Fort Lupton Compressor Station - Executive Summary |
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Executive Summary This executive summary is a brief overview of the Risk Management Program and the associated policies at the HS Gathering Fort Lupton Compressor Station. Accidental Release Prevention and Response HS Gathering LLC has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested 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, HS Gathering personnel are trained on how to respond to such emergencies. If the situation requires, HS Gathering will notify, cooperate with, and support the various emergency response agencies. Location and Regulated Substances HS Gathering's Fort Lupton Compressor Station is located in Weld County, Colorado about three (3) miles east of Highway 85 on WCR 22 in a rural area which is used primarily for farming. NARCO's Gas Plant is across the road. The Fort Lupton Compressor Station is made up of two systems: a high pressure and a low pressure system. Units #31, #32, #34,and #35 are the high pressure units with discharge pressure not to exceed 1220 psig. The high pressure throughput is 25 MMCF/D. The high pressure discharge goes through glycol dehydration and is discharged to delivery points via 12" and 20" cleanable pipelines. The low pressure system consists of units #33, #36, and #37. Discharge pressure of the low pressure system shall not exceed 280 psig. The low pressure throughput is 150 MMCF/D. Gas is discharged to Hudson Compressor Station for recompression via 24" cleanable low pressure pipeline. The station is equipped with inlet seperation. Liquids separation goes to five 225 barrel product storage tanks. The purpose of a compressor station is to increase the pressure of the gas being transported in the pipel ines and to reduce the dew point of the gas to a level that is acceptable for pipeline transmission. Each compressor station receives gas from various gathering lines and supplies the pipeline(s) that transports the gas to a processing plant. Control of the dew point is critical since the incoming gas contains moisture (water and heavy hydrocarbons). The amount of moisture in the gas varies from day to day depending on a great number of variables at the well heads. The dew point increases as the concentration of moisture in the inlet gas increases. As gas flows through the pipeline, its temperature will decrease to about the same temperature as the surrounding environment. If this temperature is below the dew point of the gas, the water and heavy hydrocarbons will tend to condense. The resulting buildup of hydrates can begin to restrict gas flow, particularly at orifices and bends in the pipe. In extreme cold, the hydrates may form a potentially dangerous ice plug. In order t o reduce the dew point of the gas (minimize the formation of hydrates), the inlet gas is put through a slug catcher, an inlet separator, and a glycol contactor with scrubber to remove moisture. Compression of the gas causes some of the naturally occurring hydrocarbons, which are in the vapor phase of the inlet gas stream, to condense out of the stream. This allows heavy hydrocarbons and water to condense out of the gas resulting in a lower dew point. These condensed raw natural gas liquids (NGL), also called condensate, are stored in tanks until there is a sufficient volume to be pumped into a tank truck for transportation for processing into marketable products. The glycol is regenerated and used again. The flammability and volume of the raw NGL stored at The Fort Lupton Compressor Station triggered coverage under the EPA RMP Standard. History and Ownership The Fort Lupton Compressor Station was built by Panhandle Eastern Co in the early 1970's. HS Resources entered into a pur chase and sale agreement with Kinder Morgan Inc., formerly known as KN Energy, in December of 1999. KN Energy operated the system from April 1993 through December 1, 1999. Program Level HS Gathering has determined that Program Level 3 applies to the Fort Lupton Compressor Station since it is under OSHA,s PSM Standard and less than 0.2 miles from the condensate tanks to NARCO's laboratory across the road. The Fort Lupton Compressor Station has a documented Emergency Response Plan which has been coordinated with the local Fire Department and has had no accidental release of the regulated substance (condensate) that directly or indirectly caused a death, injury, or response or restoration activity for an environmental receptor in the previous five years. Offsite consequence Analysis Results The worst-case scenario (WCS) associated with flammable substances stored at the Fort Lupton Compressor Station is a vapor cloud explosion resulting from a catastrophic tank failure in the conden sate tank storage area. A written procedure is in place to limit the storage inventory to 80% of the maximum tank capacity. Therefore the reduced inventory is assumed, resulting in a release of 31,000 lbs. (approximately 5700 gals.) of condensate over a 10-minute period. Although we have various controls to prevent such releases and to manage their consequences, no credit for passive mitigation measures (such as dikes or berms) was taken into account in evaluating this scenario. The maximum distance to the 1-psi overpressure from a vapor cloud explosion of this material was 0.2 miles. No other Program Level 2 or 3 processes containing regulated substances were identified at the Fort Lupton Compressor Station. The alternative release scenario was assumed to be a half filled tank failure resulting in a vapor cloud explosion. No credit for passive mitigation measures (such as dikes or berms) was taken into account in evaluating this scenario. The maximum distance to the 1-psi over pressure from a vapor cloud explosion of this material was 0.1 miles. The distance from the nearest storage tank in the tank storage area was measured to be more than 660 feet from the Laboratory building at the NARCO plant. This means the nearest NARCO building is beyond the 0.10 mile (528 feet) radius for the 1-psi overpressure result. Prevention Program The prevention program steps are described in detail in the HS Gathering PSM/RMP manual. The prevention program includes the Program Level 3 elements: ? Employee participation, which includes provisions for active participation by plant employees in the development and implementation of the facility PSM/RMP program, as well as ready access to program information ? Process safety information, which has been collected in the Brighton Office, control room and is summarized in the PSM/RMP manual ? Operating procedures for the facility operations, which are included in the control room and the Brighton Office ? Training for all HS G athering personnel involved in the operation and maintenance of the Compressor Station ? Contractor management program, which includes provisions for the evaluation and selection of contractors to work on the regulated process, exchange of hazard information, system access control, and oversight during work activities on site ? Pre-startup safety review procedure for implementation for significant system changes to ensure that the construction and equipment installation is according to design specification, appropriate procedures are in place and accurate, a PHA has been done when required and the recommendations resolved, and employees are trained prior to startup of the modified system ? Mechanical integrity program to insure that the system equipment is maintained in good and safe working condition ? Hot work procedures to require controls as specified in the Gas Standards Manual before hot work is performed within the plant premises ? Management of change program to ensure that pro posed system changes are comprehensively evaluated before implementing the change ? Incident investigation procedures for the investigation of any catastrophic (or potentially catastrophic) incident associated with the covered processes ? Compliance audits are to be conducted at least once every three years to ensure the continued compliance of the HS Gathering RMP program ? Process hazard analysis (PHA) is a systemic approach to identifying and determining the level of hazards of a covered system. Recommendations are made and a follow-up system is in place to ensure follow-up occurs. Emergency Response Program The Fort Lupton Compressor Station has established and maintains an emergency response plan that is coordinated with local response agencies. The goals of the program are to protect employees and the general public from the hazardous effects of releases and to minimize the effects of any releases. The program is routinely reviewed and updated to reflect station, personnel, and regulatory changes. Accident History During the last five years, there have been no accidents that meet the criterion for inclusion in this submittal Planned Changes for Improved Safety Ideas for changes to improve safety are actively sought from employees. Employee safety meetings that focus on safety issues, such as flammable substances, are held regularly. Employees are encouraged and trained to recognize hazards and present ideas to eliminate them or to minimize the potential consequences of those hazards. |