Emigrant Trail Gas Plant - Executive Summary |
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Risk Management Plan Duke Energy Field Services Emigrant Trail Gas Plant Rock Springs, Wyoming Executive Summary Accidental Release Prevention and Response Policies The Emigrant Trail Gas Plant 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, our trained personnel will respond to control and contain the release. We also work closely with our public emergency responders providing them with training and equipment so that they can respond safet y and efficiently to emergencies that might occur at our facility. Description of the Stationary Source and Regulated Substances The Emigrant Trail Gas Plant, located 46 miles west of Rock Springs, WY off I-80, operates a variety of processes to produce petroleum products (e.g., natural gas, propane, butane, condensate) from oil and gas wells. The Emigrant Trail Gas Plant handles methane, ethane, propane and butane which are regulated flammables. It processes approximately 72 million cubic feet a day of raw natural gas and natural gas liquids. The Emigrant Trail Gas Plant does not use, process or store a reportable quantity of toxic regulated substances. Hazard Assessment Results The Worst Case Scenario (WCS) associated with a release of flammable materials in processes at the gas plant is a vapor cloud (VCE) involving the full inventory of the largest process vessel containing 274,560 pounds of a propane, ethane mix. The maximum distance to the 1-psi endpoint for this WCS is 0. 54 miles. No passive mitigation measures were taken into account in evaluating this WCS. Five-Year Accident History Within the past five years the processes have had no accidental release that caused offsite impacts provided in the risk management program rule (40 CFR 68.10(b)(1)). General Accidental Release Prevention Program/Chemical-Specific Prevention Steps The following is a summary of the accident prevention program in place at the Emigrant Trail Gas Plant. Because processes at the Emigrant Trail Gas Plant that are regulated by the EPA Risk Management Program (RMP) regulation are also subject to the OSHA 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. Employee Participation The Emigrant Trail Gas Plant provides for and encourages employees to participate in all facets of process safety management and accident prevention. Exampl es 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 Emigrant Trail Gas Plant 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 Emigrant Trail Gas Plant and addresses each accident prevention program element. In addition, The Emigrant Trail Gas Plant has a number of initiatives under way that address process safety and employee safety issues. These initiatives include a safety committee to promote both process and personal safety. The committee typically has members from various areas of the plant, including operations, maintenance, and local plant management. Process Safety Information The Emigrant Trail Gas Plant keeps a variety of technical documents 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 chemical inventories, and equipment design basis/configuration information. Specific employees within the Emigrant Trail Gas Plant are assigned responsibility for maintaining up-to-date process safety information. This information 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. This information specifically addresses known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For specific process areas, the Emigrant Trail Gas Plant has documented safety-related limits for specific process parameters (e.g., temperature, level, composition). The Emigrant Trail Gas Plant ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems). The Emigrant Trail Gas Plant 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, electrical rating of equipment, etc. This information, in combination with written procedures and trained personnel, 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 Emigrant Trail Gas Plant has a comprehensive program to help ensure that hazards associated with the various processes are identified and co ntrolled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. The Emigrant Trail Gas Plant primarily uses the What If / Checklist (DP-10) analysis technique to perform these evaluations. This analysis is recognized as one of the most systematic and thorough hazard evaluation techniques. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. The PHA team findings are forwarded to local and corporate management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention. All 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. To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the Emigrant Trail Gas Plant periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 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 finds is documented and retained. Operating Procedures The Emigrant Trail Gas Plant maintains written procedures that address various modes of process operations , such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. 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 to reflect changes made through the management of change process. Training To complement the written procedures for process operations, the Emigrant Trail Gas Plant has implemented a comprehensive training program for all employees involved in operating a process. New employees receive initial training in Emigrant Trail Gas Plant operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate (e.g., tests, sk ill demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can 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. All of this training is documented for each operator, including the means used to verify that the operator understood the training. Contractors The Emigrant Trail 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 Emigrant Trail Gas Plant 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 em ergency, (5) understand and follow site safety rules, and (6) inform gas plant personnel 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 Emigrant Trail Gas Plant evaluates contractor safety programs and performance during the selection of a contractor. Emigrant Trail Gas Plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Pre-startup Reviews The Emigrant Trail Gas Plant conducts a pre-startup safety review (PSSR) for any new facility or facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and the equipment are appropriately prepared for startup prior to plac ing the equipment into service. This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally read. A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that accident prevention program requirements were properly implemented. Mechanical Integrity The Emigrant Trail Gas Plant has well-established practices and procedures to maintain 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, and (5) applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process. Mai ntenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their job in a safe manner. Written procedures help ensure that work is performed in a consistent manner and provide a basis for training. Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits (e.g., adequate wall thickness). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or a group of experts will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. Another integral part of the mechanical integrity program is quality assurance. The Emigrant Trail Gas Plant incorporates quality assurance measures int o equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. Pre-startup safety reviews are also used to support the quality assurance program. Safe Work Practices The Emigrant Trail Gas Plant has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment that is being worked on, (3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to ensure 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 en sure operations and maintenance activities are performed safely. Management of Change The Emigrant Trail Gas Plant has a comprehensive system to manage changes that affect any covered processes. This system requires that changes 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) ensure that adequate controls are in place to manage any new hazards and (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. Incident Investigation The Emigrant Trail Gas Plant promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, 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 Emigrant Trail Gas Plant management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are completed. 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. Compliance Audits To help ensure that the accident prevention program is functioning properly, the Emigrant Trail Gas Plant 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. Personnel from other gas plants compose the Audit Team. Both hourly and staff personnel participate as audit team members. The audit team develops findings that are forwarded to Emigrant Trail Gas Plant management for resolution. Corrective actions taken in response to the audit team's findings are traced until they are completed. The final resolution of each finding is documented, and the two most recent audit reports are retained. Summary of Process Hazards, Safety Features, and Hazard Analysis Findings The processes at the Emigrant Trail Gas Plant have hazards that must be managed to ensure continued safe operations. Universal Prevention Activities The accident prevention program summarized previously is applied to all EPA RMP covered proce sses at the Emigrant Trail Gas Plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failures and (2) human errors. Specialized Safety Features The Emigrant Trail Gas Plant has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate) a release. The following types of safety features are used in the covered processes: Release Detection 1. Hydrocarbon detectors with alarms in all closed compressor buildings Release Containment/Control 1. Process relief valves that discharge to a vent system to handle episodic releases 2. Valves to permit isolation of the process (manual or automated) 3. Automated shutdown systems for specific process parameter (e.g., high level, high temperature) 4. Curbing or diking to contain liquid releases 5. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system) 6. Atmospheric relief devices Release Mitigation 1. Fire suppression and extinguishing systems 2. Trained emergency first-responder personnel 3. Personal protective equipment 4. Spacing of equipment in accordance with IRI spacing guideline. 5. Emergency shutdowns strategically placed around the plant, that automatically shuts in the inlet and outlet and blows the plant down through the vent system. Emergency Response Program The gas plant maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, 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, and post incident cleanup and decontamination procedures. In addition the Emigrant Trail Gas Plant has procedures that address maintenance, inspection and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is updated as necessary. Any significant changes to the emergency response program are administered through the management of change (MOC) process, which includes informing and/or training affected personnel in the changes. The overall emergency response program for the Emigrant Trail Gas Plant is coordinated with the Uinta Fire Department and the local emergency plan ning committee (LEPC). This coordination includes periodic meetings with the LEPC, which includes local emergency response officials, local government officials, and industry representatives. The gas plant has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a 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 gas plant conducts periodic emergency drills. Planned Changes to Improve Safety Although Emigrant Trail Gas Plant management does not believe additional safety measures are necessary to prevent offsite impacts from accident releases, it does resolve all findings from the Process Hazards Analysis and the Compliance Audits. Some of these findings result in modifications to the process. The following types of changes were implemented in response to PHA findings and th e Compliance Audits: 1. Revision to personnel training programs. 2. Revision to operating procedures. 3. Revision to inspection procedures. 4. Modifications to the process instrumentation and control loops. 5. Updates to the Process Safety Information. (P&ID's) |