Dragon Trail Gas Plant - Executive Summary |
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Issue Date: Revision Date: Revision Page 1 05/14/99 05/05/99 Number: 1 1.0 EXECUTIVE SUMMARY Coastal Field Services Company (CFS), operator for the Dragon Trail Gas Processing Plant, is committed to operating in a manner that is safe for CFS workers, the public and the environment. As part of this commitment, CFS has established a system to help ensure safe operation of the processes at this facility. One component of this system is a Risk Management Plan (RMP) that helps manage the risks at CFS and that complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule). One of the requirements of the RMP rule is to submit a risk management plan (RMPlan) describing the risk management program at CFS. This document is inten ded to satisfy the RMPlan requirement of the RMP rule and to provide the public with a description of the risk management program at CFS. The RMP program at CFS consists of three (3) elements: 1) A hazard assessment to help understand: The potential offsite consequences of hypothetical accidental releases and; l accidents that have occurred during the last five (5) years associated with the use of substances regulated by the RMP rule (regulated substances). 2) A prevention program to help maintain and safely operate the processes containing more than a threshold quantity of a regulated substance (covered processes). 3) An emergency response program to help respond to accidental releases of regulated substances from covered processes. Information further describing these elements is provided in this RMPlan. Although the RMP program at CFS helps provide assurance tha t the facility is maintained and operated in a safe manner, it is only one component of the safety program at CFS. In fact, CFS is presently developing a comprehensive safety program to safeguard against the release of hazardous substances and limit injuries and damage to its employees, the public and the environment. Issue Date: Revision Date: Revision Page 2 05/14/99 05/05/99 Number: 1 CFS limits the use of hazardous substances. Before using a hazardous substance, less hazardous alternatives are considered. When a hazardous substance is used at CFS, consideration is given to the potential for this substance to adversely affect CFS workers, the public, and the environment and CFS takes steps to prevent any such effects. CFS prevents releases of the hazardous substances used at the facility. When a hazardous substance is used at CFS, the equipment is carefull y designed, built and operated to reduce the likelihood of an accidental release. Industry and government standards are closely adhered to in the design, construction, and operation of the equipment. CFS limits damage from a release, if such a release occurs. CFS trains workers to respond to an emergency response, reducing the consequences of a release if it occurs. In addition, CFS works with the local fire department and with the local emergency planning committee (LEPC) to limit injuries and environmental damage if a release does occur. The safety program at CFS consists of a number of elements, many of which are required by the RMP rule. These are the same elements defined under the OSHA Process Safety Management (PSM) Rule, which are required for this facility. This RMPlan is primarily intended to describe those parts of the safety program at CFS that are required by the RMP rule. New Ownership In November 1998, CFS acquired the Dragon Trail Gas Plant and surrounding pipeline gathering system from Conoco Oil, Inc. Since this ownership change, CFS has begun the process of assimilating and reviewing all available Conoco plans, procedures, permits, and other pertinent operating data to ensure it meets CFS's commitment level of safe plant operation. The implementation of the RMPlan relies significantly on these documents, of which several will be rewritten or developed in the future. CFS views the RMPlan as a dynamic document which will change over time as we proceed to create and implement our safety and operational documents. Issue Date: Revision Date: Revision Page 3 05/14/99 05/05/99 Number: 1 2.0 ACCIDENTAL RELEASE Accidental Release Prevention and Emergency Response Policies CFS is committed to the safety of workers and the public and the preservation of the environment, through the pr evention of accidental releases of hazardous substances. CFS implements reasonable controls to prevent foreseeable releases of hazardous substances. These controls include training programs for personnel; programs to help ensure safety in the design, installation, operation, and maintenance of processes at CFS; and programs to evaluate the hazards at CFS. In the event of an accidental release, CFS controls and contains the release in a manner that will be safe for workers and will help prevent injury to the public or the environment. CFS coordinates response efforts with the local emergency response personnel. Response activities have also been discussed with the LEPC. Regulated Substances and CFS The Dragon Trail Gas Processing Plant is a plant primarily involved in the recovery of liquid hydrocarbons from a gas stream. As part of this process, CFS handles several regulated, flammable substances in sufficient quantities to be covered by the RMP rule. There are no such quantities of regulated toxic substances handled at the Plant. The following RMP-regulated flammables are found at the Plant: Ethane Pentane Propane Condensate Butane Offsite Consequence Analysis CFS performed an offsite consequence analysis to estimate the potential for an accidental release of a regulated substance which could affect the public or the environment. The offsite consequence analysis consists of evaluating both worst-case release scenarios and alternative release scenarios. CFS does not expect a worst-case to ever occur. The alternative release scenarios were selected to help the local emergency planning committee improve the community emergency response plan. An alternative release scenario represents a release that: 1) might occur at a facility such as CFS, and/or, 2) would result in the greatest potential offsit e consequences if the release occurred. Issue Date: Revision Date: Revision Page 4 05/14/99 05/05/99 Number: 1 The main objective of performing the offsite consequence analysis is to determine the distance at which certain effects might occur to the public because of an accidental release (called the endpoint distance). Minimal effects could occur at the endpoint distance. At distances less than the endpoint distance, the effects would be greater; at distances greater than the endpoint distance, the effect would be less. The RMP rule includes specific requirements for the worst-case and alternative release scenarios that must be reported by CFS. These requirements are: One worst-case and one alternative release scenario for the class of flammable substances in Program 3 processes. The following information summarizes the offsite cons equence analysis performed by CFS. Program 3 Processes Flammable Substances: The worst-case release scenario for flammable substances is failure of the 60,000-gallon propane storage tank, resulting in a vapor cloud explosion. No administrative controls or passive mitigation were considered for this release scenario. The maximum distance to the 1-psi overpressure endpoint is 0.49 miles. There are no offsite receptors located within this distance. The alternative release scenario for flammable substances is a rupture of a truck transport hose between the truck and the propane loading pumps. This scenario assumes that the flammable substance (propane) is released from a ruptured truck loading hose for 30 minutes before workers detect the release and isolate the ruptured section. The substances form a vapor cloud, resulting in a vapor cloud explosion. The maximum distance to the overpressure endpoint is 0.26 miles. There are no offsite receptors located within this distance. Issue Date: Revision Date: Revision Page 5 05/14/99 05/05/99 Number: 1 Accidental Release Prevention Program CFS uses a prevention program to help prevent accidental releases of hazardous substances. CFS formalized this prevention program for all of our OSHA PSM-regulated natural gas processing facilities to comply with the 14 elements of the PSM prevention program. The EPA RMP rule established two levels of prevention program requirements. The level relevant to the Dragon Trail Plant is: Program 3: Essentially the same as OSHA PSM, except that the program also focuses on protecting the public and the environment. The following sections briefly describe the elements of CFS's prevention program that address the EPA RMP rule prevention program requirements. Program 3 Prevention Program The CFS Program 3 prevention program, which applies to the Plant, consists of the following 12 elements: Employee Participation Process Safety Information Process Hazard Analyses Operating Procedures Training Contractors Pre-Startup Safety Review Mechanical Integrity Hot Work Permits Management of Change Incident Investigation Compliance Audits All elements are presently being reviewed by CFS since the acquisition of the Plant from Conoco. Many modifications and changes are likely to occur as we evaluate each element against CFS practices and standards. Changed and altered elements will be incorporated in the PSM manual and reflected in the RMPlan during the 3-year audit cycle. Issue Date: Revision Date: Revision Page 6 05/14/99 05/05/99 Number: 1 3.0 PROGRAM 3 PREVENTION PROGRAM Proc ess Safety Information CFS acquired a variety of technical documents after the ownership change. Current Process Safety elements are being assessed to ensure existing process information is complete. These documents address: 1) Physical properties of hazardous substances handled, 2) Operating parameters of the equipment, and 3) Design basis and configuration of the equipment. CFS ensures that this process safety information is available to all CFS employees, the LEPC and the fire department. Material safety data sheets (MSDS's) document the physical properties of hazardous substances handled at CFS, including regulated substances in covered processes. The information available for each hazardous substance typically includes: 1) Toxicity information and permissible exposure limits, 2) Physical data (e.g., boiling point, melting point, flash point), 3) Reactivity and corrosivity data, 4) Thermal and chemical stability data, and 5) Ha zards of mixing substances in the process. MSDS's for hazardous substances handled in each process are available in the Plant's MSDS book so the personnel have ready reference to this information. In addition, MSDS's are provided to the LEPC and the fire department for use in helping formulate emergency response plans. Issue Date: Revision Date: Revision Page 7 05/14/99 05/05/99 Number: 1 Egineering design documents include operating parameters and the design basis and configuration of equipment in each covered process. The available information will include: 1) Operating parameters 2) Block flow or simplified process flow diagrams 3) Process chemistry 4) Maximum intended inventories 5) Safe upper and lower limits for parameters such as temperature, pressure or flow 6) Consequences of deviations from established operating limits 7) Design basis and c onfiguration of equipment 8) Piping and instrument diagrams, including materials of construction, 9) Electrical classification 10) Safety systems 11) Applicable design codes and standards, and 12) Design basis for relief and ventilation systems. When important information is not available from the design documents, it will be developed through special projects or, in the case of operating parameters, during process hazard analyses of the process. Many of the operating parameters are included in the operating procedures to help with the safe operation of the process. These documents are used: 1) to train employees; 2) to perform process hazards analyses, and 3) to help maintain the equipment. These procedures are currently under review. Process Hazard Analysis Conoco prepared a Process Hazard Analysis to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systema tically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. The Dragon Trail Gas Processing Plant primarily used the hazard and operability (HAZOP) analysis technique to perform these evaluations. HAZOP 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 the team makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. Issue Date: Revision Date: Revision Page 8 05/14/99 05/05/99 Number: 1 The Process Hazard Analysis (PHA) team findings are forwarded to local an d 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 plant periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every five years and will be conducted at this frequency until the process is no longer operating. A revalidation of the current PHA will occur in June 2000. The results and findings from these updates will be docum ented and retained. Once again, the team findings are forwarded to management for consideration and the final resolution of the findings is documented and retained. Operating Procedures The Dragon Trail Gas Processing Plant will maintain written procedures that address various modes of process operations, such as: Unit Start-up Normal Operations Temporary Operations Emergency Shutdown Normal shutdown Initial start-up 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 will be reviewed and annually certified as current and accurate. The procedures are to be kept current and accurate by revising them as necessary to reflect changes through the management of change process. In addition, the Dragon Trail Gas Processing Plant will maintain Operating Procedures, which will provide guidance on ho w to respond to upper or lower limit exceedances for specific processes or equipment parameters. This information, along with written operating procedures, will be readily available to operators in the process unit and for other personnel to use as necessary to safely perform their job tasks. Issue Date: Revision Date: Revision Page 9 05/14/99 05/05/99 Number: 1 Training To complement the written procedures for process operations, the Dragon Trail Gas Processing Plant will be implementing a comprehensive training program for all employees involved in operating a process. New employees receive basic training in gas plant operations if they are not already familiar with such operations. After successfully completing this training, a new operator is paired with a qualified operator to learn process- specific duties and tasks. After operators demonstr ate (e.g., through tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. All of this training is documented for each operator, including the means used to verify that the operator understood the training. Documentation is maintained at the Plant, which certifies on-the-job experience for each operator. Contractors The Dragon Trail Gas Processing 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 plant is developing procedures to ensure that contractors: Perform their work in a safe manner, Have the appropriate knowledge and skills, Are aware of the hazards in their workplace, Understand what they should do in the event of an emergency, Understand and follow site safety rules, and In form gas plant personnel of any hazards they find during their work. This is accomplished by providing contractors with: A process overview, Information about safety and health hazards, Emergency response plan requirements, and Safe work practices prior to their beginning work. In addition, the plant evaluates contractor safety programs and performance during the selection of a contractor. Gas plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. Issue Date: Revision Date: Revision Page 10 05/14/99 05/05/99 Number: 1 Pre-Startup Safety Reviews (PSSR) CFS conducts a (Pre-Startup Safety Reviews) PSSR for any major facility modifications that require a change in the process safety information. The purpose of the Pre-Startup Safety Reviews (PSSR) is to ensure that safety features, procedures, personnel and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to ensure that construction is in accordance with the design specifications and that all supporting systems are operationally ready. The PSSR review team uses checklists or startup procedures to verify all aspects of readiness. A PSSR involves field verification of the construction and serves as a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. Mechanical Integrity The Dragon Trail Gas Processing Plant is developing Mechanical Integrity (MI) 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 basis aspects of this program include: Conductin g training, Developing written procedures, Performing inspections and tests, Correcting identified deficiencies, and Applying quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process. Maintenance personnel receive training on: An overview of the process, Safety and health hazards, Applicable maintenance procedures, Emergency response plans, and Applicable safe work practices to help ensure that they can perform their jobs in a safe manner. Issue Date: Revision Date: Revision Page 11 05/14/99 05/05/99 Number: 1 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 for pressure vessels). If a deficiency is identified, employees will correct the deficiency before placing the equipment back into service (if possible), or a management of change team 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 MI program is quality assurance. The Dragon Trail Gas Processing Plant incorporates quality assurance measures into 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. Safe Work Practices The Dragon Trail Gas Processing Plant adopted CFS Safe Work Practices standards to help ensure worker and process safety. Examples of these include: Control of the entry/presence/exit of support personnel, A lockout/tagout procedure to ensure isolation of ener gy sources for equipment undergoing maintenance, A procedure for safe removal of hazardous substances before process piping or equipment is opened, A permit and procedure to control spark-producing activities (i.e., hot work), and, 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 ensure that operations and maintenance activities are performed safely. CFS maintains a Safe Work Practices Manual as a guidance document to promote employee safety, comply with applicable safety laws and regulations, eliminate injuries, and prevent accidental damages. Issue Date: Revision Date: Revision Page 12 05/14/99 05/05/99 Number: 1 Management of Change A comprehensive system to manage changes to all covered processes is under preparation for the Dragon Trail Plant. This system will require 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: Ensure that adequate controls are in place to manage any new hazards, and Verify that existing controls have not been compromised by the change. Affected 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 CFS promptly investigates all incidents that result in, or reasonably could have resulted in, a fire/explosion, flammable gas release, major property damage, environmental loss o r 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 recurrence, and forwards these results to gas plant management for resolution. Corrective actions taken in response to the investigation teams findings and recommendations are tracked until they are complete. 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 a least five years so that the reports can be reviewed during future PHA revalidations. Compliance Audits To help ensure that the accident prevention program is functioning properly, the Dragon Trail Gas Processing Plant will periodically conduct an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Issue Date: Revision Date: Revision Page 13 05/14/99 05/05/99 Number: 1 Compliance audits are conducted at least every three (3) years for each relevant CFS facility. Both Operations and Corporate staff personnel may participate as audit team members. The audit team develops findings that are forwarded to gas plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained. 4.0 CHEMICAL-SPECIFIC PREVENTION STEPS The processes at the Dragon Trail Gas Processing Plant have hazards that must be managed to ensure continued safe operation. The following is a description of existing safety features applicable to prevention of accidental releases of regulated substances in the facility. Universal Prevention Activities The accident prevention program is applied to the entire Dragon Trail Gas Processing Plant. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. Specialized Safety Features CFS has safety features on many units to help: Contain/control a release, Quickly detect a release, and Reduce the consequences of (mitigate) a release. The following types of safety features are used in the covered processes. l Release detection: Hydrocarbon detectors with alarms. l Release containment/control: Process relief valves that discharge to a flare to capture and incinerate episodic releases. Valves to permit isolation of the process (manual or automated). Automated shutdown s ystems for specific process parameters (e.g., high pressure and temperature). Curbing or diking to contain liquid releases. Backup power equipment (e.g., 24-volt backup power supply for process control system). Atmospheric relief devices. Release mitigation: Fire suppression and extinguishing systems. Fire water hydrants for specific process units. Trained emergency response personnel. Personal protective equipment (e.g., fire retardant protective clothing). Issue Date: Revision Date: Revision Page 14 05/14/99 05/05/99 Number: 1 Five Year Accident History The Dragon Trail Gas Processing Plant has an excellent record of accident prevention over the past five years. There have been no accidents or incidents in the past five years, resulting in offsite effects. 5.0 EMERGENCY RESPONSE Emergency Response Program Information The Dragon T rail Gas Processing 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 requirements. In addition, the plant has procedures that address maintenance, inspection and testing of emergency response equipment (SPCC Plan Procedures), as well as instructions that address the use of emergency response equipment. Employees receive training in these pro cedures as necessary to perform their specific emergency response duties. The emergency response program is updated when necessary, based on modifications made to gas plant processes or other CFS facilities. The emergency response program changes are administered through the Plant Supervisory approval process, which includes informing and/or training affected personnel in the changes. The overall emergency response program for the Dragon Trail Gas Processing Plant is coordinated with the Rangely County LEPC located in Rangely, Colorado. This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The Dragon Trail Gas Processing Plant has communications capability with appropriate LEPC officials and emergency response organizations (e.g., Rangely Sheriff's Department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. Issue Date: Revision Date: Revision Page 15 05/14/99 05/05/99 Number: 1 Planned Changes to Improve Safety CFS is committed to operating the Dragon Trail Gas Processing Plant in a safe manner for workers, the public, and the environment. CFS will be extensively reviewing and assessing the present safety programs at the Plant. It is anticipated that several modifications and updates will be necessary for many of the Plant documents. Document revisions will be incorporated into the Plant's Process Safety Information as soon as it becomes available. In the event improvements in safety can be realized through auditing efforts, actions are planned and instituted to respond to safety enhancements of operating practices. Improvements to safety are a continual process at the Plant. |