Altonah Plant - Executive Summary |
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Issue Date: Revision Date: Revision Page 1 06/08/99 05/07/99 Number: 1 1.0 EXECUTIVE SUMMARY Coastal Field Services Company (CFS), operator for the Altonah Gas Processing Plant, is committed to operating in a manner that is safe for CFS workers, the public and the environment. The Altonah Plant qualifies for Program 1 under the RMP rule. 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 intended to satisfy the RMPlan requirement of the RMP rule and to provide the public with a description of the risk management program at CFS. Under Program 1 of the RMP rule, the Plant's RMPlan consists of three (3) elements: 1) A hazard assessment to help understand the potential offsite consequences of hypothetical accidental releases; 2) Accident history documenting that no accidents have occurred during the last five (5) years associated with the use of substances regulated by the RMP rule (regulated substances). 3) An emergency response program coordinated with the community response organizations 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 that the facility is maintained and operated in a safe mann er, it is only one component of the safety program at CFS. In fact, CFS developed a comprehensive safety program applicable to all CFS- operated facilities to safeguard against the release of hazardous substances and limit injuries and damage to its employees, the public and the environment. 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. Issue Date: Revision Date: Revision Page 2 06/08/99 05/07/99 Number: 1 CFS prevents releases of the hazardous substances used at the facility. When a hazardous substance is used at CFS, the equipment is carefully designed, built and o perated 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 Altonah Plant RMPlan is primarily intended to describe those parts required by the RMP rule. New Ownership In March 1999, CFS acquired the Altonah Gas Plant and surrounding pipeline gathering system from Gary Williams Energy Corporation. Since this ownership change, CFS has begun the process of assimilating and reviewing all available Gary Williams Energy 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. 2.0 RELEASE ANALYSIS 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 prevention 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 contain s 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. Issue Date: Revision Date: Revision Page 3 06/08/99 05/07/99 Number: 1 Regulated Substances and CFS The Altonah 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 An alysis 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 evaluate a worst-case release scenario. CFS does not expect a worst-case to ever occur. 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 release scenarios that must be reported by CFS in Program 1 processes. The following information summarizes the offsite consequence analysis performed by CFS. Program 1 P rocesses Flammable Substances: The worst-case release scenario for flammable substances is failure of the 30,000-gallon butane/gasoline mix 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 357 feet (0.06 miles). A multi-energy model was used in performing the worst case release analysis for the storage tank, which takes into account site-specific conditions. This method predicts the actual explosion hazard for the tank in open areas more accurately than various other modeling techniques. There are no offsite receptors located within this distance. The closest public receptor is located 1,685 feet from the storage tank. Issue Date: Revision Date: Revision Page 4 06/08/99 05/07/99 Number: 1 3.0 CHEMICAL-SPECIFI C PREVENTION STEPS The processes at the Altonah 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 Altonah 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 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 systems 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. l Release mitigation: Fire suppression and extinguishing systems. Fire water hydrants for specific process units. Five Year Accident History The Altonah 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. Issue Date: Revision Date: Revision Page 5 06/08/99 05/07/99 Number: 1 4.0 EMERGENCY RESPONSE Emergency Response Program Information The Altonah Gas Processing Plant maintains a emergency r esponse program, which is 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, 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 r esponse 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 Altonah Gas Processing Plant is coordinated with the Duchesne County LEPC located in Duchesne, Utah. This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The Altonah Gas Processing Plant has communications capability with appropriate LEPC officials and emergency response organizations (e.g., Duchesne County LEPC). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. Planned Changes to Improve Safety CFS is committed to operating the Altonah 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. |