Holly Hill Processing Facility - Executive Summary |
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HOLLY HILL PROCESSING FACILITY RISK MANAGEMENT PLAN: EXECUTIVE SUMMARY ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES The Holly Hill Processing Facility 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 the facility's processes. Carnegie's policy is to implement reasonable controls to prevent foreseeable releases of substances. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES Carnegie operates the Holly Hill Processing Facility located in Greene County, Pennsylvania. This facility is a liquid extraction plant capable of recovering ethane in addition to propane, butanes, and gasoline from the inlet gas. As evidenced in the ensuing text and based on criteria outlined in the Accidental Release Prevention Program (ARP), the Holly Hill Processing Facility is a Program 3 p rocess. The Holly Hill Processing Facility was evaluated to determine if any regulated flammable or toxic substances exceeded the threshold quantity. Based on process knowledge, Carnegie identified the regulated substances and quantities kept on site. Carnegie identified three RMP-regulated flammable mixtures at the facility. The maximum quantity of RMP-regulated flammable mixtures at the facility is approximately 530,000 pounds, contained in five storage tanks. The flammable mixtures include the following RMP-regulated substances: butane, isobutane, pentane, isopentane, propane, and ethane. OFFSITE CONSEQUENCE ANAL YSIS RESULTS Worst-case Release Scenario The worst-case scenario for flammable materials is a release of 123,000 pounds of a butane mixture from a storage tank. This represents 85% of the total vessel capacity, as administratively controlled by Carnegie. The released material ignites, resulting in a vapor cloud explosion. The pressure wave resulting from the explo sion is expected to reach offsite locations. Alternative Release Scenario The alternative release scenario selected by Carnegie is a seal failure on the depropanizer pump. This event was selected based on a review of operations and the release history at the facility. Approximately 4,160 pounds of propane mixture are assumed to be released before the operator isolates the release (within 15 minutes). The released material ignites, resulting in a vapor cloud explosion. The pressure wave resulting from the explosion is expected to reach offsite locations. FIVE-YEAR ACCIDENT HISTORY There have been no offsite releases or onsite incidents that are required to be reported under the ARP at the facility within the past 5 years. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM The following is a summary of the accident prevention program in place at the plant. Because processes at the facility are also subject to OSHA's PSM standard, this summary addresses each of the OSHA PSM elements and describes the management system in place to implement the accident prevention program. Employee Participation Carnegie actively encourages all levels of employees and contract employees to participate in creating a safe work environment. This participation begins with well-established mechanisms of communication with all employees regarding covered process information. Employees are involved in maintaining PSM rule compliance based on their knowledge, skill, job responsibilities, and experience. Process Safety Information The facility maintains written information intended to provide a foundation for identifying and understanding the hazards involved in the process. This information addresses chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information. Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is pro vided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For specific process areas, the facility has documented safety-related limits for specific process parameters (e.g., temperature level, composition). The facility ensures that the process is maintained within these limits using process controls and monitoring instruments, trained personnel, and protective instrument systems (e.g., automated shutdown systems). The facility also maintains numerous technical documents 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. In combination with written procedures and trained personnel, this information provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised. Process Hazard Analysis (PHA) The facility has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. A what-if method PHA is in place to identify hazards and ensure that hazard controls are in place to manage these hazards. To help ensure that the process controls and/or process hazards do not eventually deviate from the original design safety features, the plant periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years by a PHA team. Operating Procedures The facility maintains written procedures that address various modes of process operations, such as (1) initial startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) emergency operations, (6) normal shutdown, and (7) startup following a turnaround or after an 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. Training To complement the written procedures for process operations, the facility has implemented a comprehensive training program for all employees involved in operating a process. New employees receive job-specific basic training in gas plant operations. This includes both classroom and on-the-job training followed by demonstrations, observations, and written tests. After operators demonstrate having adequate knowledge to perform the duties and tasks in a safe manner, they can work independently. Contractors The facility periodically uses contractors to perform maintenance or repair, turnaround, major renovations, or specialty work on or adjacent to a covered process. Because some contractors work on or near process equipment, the plant has procedures in place to ensure that contractors (1) are trained in the work practices necessary to safely perform his/her job, (2) have received and understood the training and carry a training document card while on location, (3) follow the safety rules of the location, including the safe work practices, (4) advise the plant of any unique hazards presented by the contractor, and (5) notify the facility of all illnesses and injuries that occur in the process areas. This information is in addition to maintaining their own OSHA 200 log. Hot Work Permit The facility issues a hot work permit for all hot work operations conducted on or near a covered process. Procedures for issuing a hot work permit are clearly outlined in the Company Standard. The facility provides hot work permit training to all plant employees. Pre-startup Safety Reviews (PSSRs) The facility conducts a PSSR for any facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that safet y features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides an additional check to make sure that construction and equipment are in accordance with design specification; adequate safety, operating, maintenance, and emergency procedures are in place; training of each employee involved in operating the process or equipment has been completed; and when significant modifications are made to a plant. Mechanical Integrity The facility has well-established programs, procedures, and practices that are required to ensure that equipment used to process, store, or handle highly hazardous chemicals and/or flammable gas or liquid is designed, constructed, installed, and maintained to minimize the risk of a release. Examples of the equipment include vessels; storage tanks; piping systems (including piping components such as valves); relief and vent systems, including associated devices; pumps; emergency s hutdown systems; and controls (including monitoring devices and sensors, alarms, and interlocks). Management of Change The facility has a system to manage and document changes to all covered processes. Its systematic approach is followed to control and manage changes to process facilities in order to minimize the probability that such changes will have an adverse impact on the safety of personnel, equipment, or the environment. Employees involved in operating a process and maintenance and contract employees whose job tasks might be affected by a change in the process are informed of, and trained in, the change prior to startup of the process. Incident Investigation The facility promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. An incident investigation is initiated as promptly as possible to thoroughly investigate and analyze the incident. Th is investigation is lead by an incident investigation team consisting of those with appropriate knowledge and experience in the process. The findings and recommendations made by the incident investigation team are promptly addressed and resolved in a timely manner. 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. Emergency Planning and Response The Holly Hill Processing Facility is not required by the RMP rule to develop or maintain an emergency response plan. However, the facility is included in the community emergency response plan. In addition, the facility retains a written emergency action plan, which includes the designated actions that personnel will take to ensure personal safety from fire and other emergencies. The plan outlines actions that company technicians and contract employees are to take when there is an unwanted release of highly hazardous chemicals. The intent of the action plan is to facilitate the prompt evacuation of employees, account for all personnel, and notify the local emergency responders (local fire department, emergency medical services, police, etc.) as needed. Compliance Audits To help ensure that the accident prevention program is functioning properly, Carnegie periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted at least every 3 years. The audit team includes those knowledgeable in the process, operations personnel, and at least one person trained in audit techniques and practices. The audit team develops findings, and corrective actions are tracked until they are complete. The final resolution of each finding is documented. Planned Changes to Improve Safety The Holly Hill Processing Facility periodically conducts reviews of its process equipment and proc edures. When necessary, the facility will make changes to processing equipment or procedures to enhance both employee and public safety. At the time this risk management plan was submitted to EPA, no specific safety-related process/procedure changes were in progress or planned. |