Greasy Creek Natural Gas Processing Plant - Executive Summary

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Transok / Greasy Creek -RMP / Executive Summary 
A.    Accidental Release Prevention and Response Policies 
The Greasy Creek Plant & Loading Terminal has a 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.  Transok's policy for the design and operation of gas plants (& loading facilities) is to implement reasonable controls to prevent foreseeable releases of regulated substances.  However, if a release does occur, trained personnel will respond to and attempt to control and contain the release. 
B.    Description of the Stationary Source and Regulated Substances 
Transok operates the Greasy Creek Plant located 7 miles South and 4 miles East of Wetumka, Oklahoma in Hughes County.  The plant's propane loading terminal is located 7 miles South of Wetumka on Highway 75.  The Greasy Creek Plant receive 
s natural gas with some condensed hydrocarbon liquids (i.e. condensate) from production wells by pipeline system.  The Plant separates ethane, propane, butanes, and higher molecular weight hydrocarbon components from natural gas by liquefying them at cryogenic temperatures. The natural gas minus these liquefied components (called "residue gas") is delivered back into the pipeline system for ultimate use as fuel.   
The natural gas liquids (NGL's or Raw Mix) are sold separately for petrochemical feedstock, fuel, and other uses.  The NGL's are delivered into a Koch Company pipeline connected to the plant.  Propane is also fractionated from this Y-Grade stream at the plant is delivered by Transok pipeline 4 miles to the highway-loading terminal. 
The Greasy Creek Plant & Loading Terminal was evaluated to determine if any regulated flammable or toxic substances exceeded the threshold quantity.  Based on process knowledge, Transok identified the regulated substances and quantities kept on s 
ite.  The chemicals, largest quantities on site, and associated threshold quantities are presented in Section II - Accident Release Prevention Program, Table 1.   
Listed flammable substances, which are stored above threshold quantities at the Greasy Creek Plant and Loading Terminal, are NGL's (product), methane and condensate.  However, Transok has determined that condensate has an NFPA rating of 3, which exempts this mixture from threshold determination.  There are no listed toxic substances stored above threshold quantities at the Greasy Creek Plant or Loading Terminal. 
Based on worst-case analysis, the distance to the endpoint exceeds the distance to public receptor for the Loading Terminal but not the Plant.   In addition, the Greasy Creek Plant and Loading Terminal are subject to the OSHA Process Safety Management Program (PSM). Therefore, the Greasy Creek Plant is classified a Program 1 process and Loading Terminal a Program 3 process under the Accident Release Program. 
C.    Off 
site Consequence Analysis Results 
1.    Worst-Case Releases 
Flammable Substances 
The endpoint for a worst-case scenario (WCS) release of a flammable substance is a 1 psi overpressure (i.e., 15.7 psia), resulting from a vapor cloud explosion.  The Accidental Release Prevention (ARP) Program requirement for flammables assumes an instantaneous release and vapor cloud explosion.  A yield factor of 10 percent of the available energy released in the explosion shall be used to determine the distance to the explosion endpoint.  Since the worst-case release scenario for a flammable substance is based on the assumption that the entire quantity of the substance forms a vapor cloud, passive mitigation systems are not applicable. 
The worst-case release scenario for the Greasy Creek Plant is from a release of methane with an endpoint 1 psi overpressure distance of 0.31 miles.  The worst-case release for the propane Loading Terminal is 0.49 miles. This is based on using the Environmental Protection  
Agency (EPA) equations found in the "RMP Offsite Consequence Analysis Guidance" dated May 24, 1996.   There is no NGL storage capacity (i.e. surge tank) at the Plant.  It is assumed there was an unmitigated gas (methane) release at maximum pressure for 30 minutes.  The storage capacity of the two propane storage tanks at the Loading Terminal are 65,000 gallons each, which is limited to 80% or 52,000 gallons each by administrative controls.  It assumes the entire contents of one tank (52,000 gallons or 219,960 pounds) is released instantaneously and is involved in the vapor cloud explosion. 
Toxic Substances 
The Greasy Creek Plant and Loading Terminal do not have any toxic substances above the threshold quantity; therefore, analysis of worst-case release scenarios for toxic substances is not required. 
2.    Alternative Releases 
Alternative releases scenarios are those that are more likely to occur than the worst-case release scenario.  Alternative release scenarios for toxic substances 
should be those that lead to concentrations above the endpoints beyond the facility's fenceline.  Alternative release scenarios for flammable substances should have the potential to cause substantial damage, including on-site damage. 
Flammable Substances 
A single alternative release scenario for all flammable substances is required under the ARP program.  A hypothetical, but likely to occur, release scenario has been identified for NGL's (Plant) and propane (Loading Terminal) as follows:   
A two-inch valve on the de-methanizer tower (plant) and a two-inch valve on a 65,000 gallon, 250 psi, propane strorage tank (loading terminal) fails and releases contents undetected for a period of 30 minutes.  This volume released for each of 30,785 pounds then participates in a vapor cloud explosion resulting in a 1 psi overpressure endpoint distance of 0.25 miles. This is based on EPA equations found in the "RMP Offsite Consequence Analysis Guidance" document.  
Toxic Substances 
The Greasy Cr 
eek Plant and Loading Terminal do not have any toxic substances held above the threshold quantity.  Therefore, analysis of each regulated toxic substance is not required. 
D.    General Accidental Release Prevention Program 
The following is a summary of the accident prevention program in place at the Greasy Creek Plant and Loading Terminal.  The processes at the gas plant and loading terminal are regulated by EPA's Risk Management Program (RMP) regulation.  They are also subject to the Occupational Safety and Health Administration's (OSHA's) 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 Release Prevention (APR) Program under EPA's RMP. 
1.    Employee Participation 
Active employee participation and involvement in the development and implementation of the Greasy Creek Plant and Loading Terminal's PSM program is an important step toward achieving the objective to prevent o 
r minimize the consequences of catastrophic releases of the flammable substances at the plant.  Employee involvement will help ensure that all perspectives regarding PSM are considered, and that the best ideas are implemented.  Open communications are encouraged between supervisors and employees regarding all safety and health issues. In addition, this is mandated as part of Transok Corporate Policy #SA4 - Employee Participation and is further identified in Section II, Part C of the PSM Manual. 
The Greasy Creek Plant and Loading Terminal strongly encourages employees to participate in all facets of process safety management and accident prevention.  Examples of this include a cross-section of employees and management ad hoc teams participating in: 
* Process Hazard Analysis  
* Pre-Startup Safety Reviews 
* Audits 
* Operating Procedures Development 
The Greasy Creek Plant and Loading Terminal also actively seek employee involvement in the development and conduct of all accident prevent 
ion activities through existing safety programs.  Accident prevention is discussed at monthly safety meetings and/or during special training sessions if necessary.  Employee suggestions on improving safety processes are encouraged at these meetings. Specific ways that employees can be involved in the accident prevention program are also documented in Section II, Part C of the PSM Manual. 
2.    Process Safety Information 
Complete and accurate written process safety information (PSI) concerning process chemicals, process technology, and process equipment is essential to an effective PSM and RMP program and to completing and maintaining a process hazard analysis (PHA).  The PSI will be useful to the operators; the team performing the PHA; those in charge of training; contractors; those conducting pre-startup safety reviews; and those in charge of updating the emergency preparedness plans.  Process Safety Information is readily available to all employees. 
The Greasy Creek Plant and Loading 
Terminal keep 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.  The documents include the PSM Process Hazard Analysis, process flow diagrams, piping & instrument diagrams, vendor data books (equipment specifications & operation), description of process chemistry, inventory of hazardous chemicals, operating manual (upper/lower operating limits, startup, shutdown, etc.) and electrical classification drawings. 
Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDS's).  The Greasy Creek Plant and Loading Terminal also ensure that operating processes are maintained within limits using process controls and monitoring instruments, highly trained p 
ersonnel, and protective instrument systems (e.g., automated shutdown systems).  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.  
See also Section II, Part D of the PSM Manual. 
3.    Process Hazard Analysis (PHA) 
The Greasy Creek Plant and Loading Terminal have a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled.  Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. 
The Greasy Creek Plant and Loading Terminal primarily use the "What-if / Checklist" method analysis.  The analyses are conducted using a team of people who have extensive operating and maintenance experience as well as enginee 
ring expertise. This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and the team makes recommendations for additional prevention and/or mitigation measures when the team believes such measures are necessary.  
The PHA team recommendations are forwarded to local and corporate management for resolution. The PHA team will ensure that potential accident scenarios with a high risk of imminent danger receive immediate attention.  All approved mitigation options in response to PHA team recommendations are tracked until they are completed.  The final resolution of each recommendation 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 5 years and will be conducted at this frequency unt 
il the process is no longer operating.  The results and recommendations from these updates are documented and retained.  Once again, the team recommendations are forwarded to management for consideration, and the final resolution of the recommendations is documented and retained. 
The details of this program are also identified in Section II, Part E of the PSM Manual. 
4.    Operating Procedures 
The Greasy Creek Plant and Loading Terminal maintain 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 to determine if they are current and accurate.  The procedures are kept current and accurate by revising them as necessary to reflect changes m 
ade through the management of change process.   
The intent of the operating procedures is to provide workable, useful, and clearly written instructions for conducting operating activities.   To have effective operating procedures, the task and procedures directly and indirectly related to the covered process must be appropriate, clear, consistent, and most importantly, communicated to employees.  Operating procedures are specific instructions or details on what steps are taken or followed in caring out the stated procedures.  The specific instructions include the applicable safety precautions and appropriate information on safety implications.  See also Section II, Part F of the PSM Manual. 
5.    Training 
To complement the written procedures for process operations, the Greasy Creek Plant and Loading Terminal have various training programs available for operations personnel.  New employees receive basic training in gas plant operations.  In addition, all operators periodically receive r 
efresher training on operating procedures to ensure that their skills and knowledge are maintained at an acceptable level.  New operators are also paired with a senior operator to learn process-specific duties and tasks.  After operators demonstrate (e.g., through tests, skills demonstration) 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.  All of this training is documented for each operator, including the means used to verify that the operator understood the training.  See training and certification requirements also in Section II, Part G of the PSM Manual. 
6.    Contractors 
The Greasy Creek Plant and Loading Terminal use contractors to supplement its workforce during periods of increased maintenance or construction activities.  Because some contract 
ors work on or near process equipment, the 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 emergency, (5) understand and follow site safety rules, and (6) inform plant personnel of any hazards that they find during their work.   
This is accomplished by providing contractors with an orientation session and video that covers (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, Transok 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.  Detailed contractor orientation and work rules are al 
so identified in Section II, Part H of the PSM Manual. 
7.    Pre-Startup Safety Reviews (PSSRs) 
The Greasy Creek Plant and Loading Terminal conduct PSSR's 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 equipment are appropriately prepared for startup prior to placing 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 ready.  The PSSR review team uses checklists to verify all aspects of readiness.  A PSSR involves field verification of the construction and serves a quality assurance function by requiring verification that Accident Prevention Program requirements are properly implemented. See also Section II, Part I of the PSM Manual 
8.    Mechanical Integrity 
The Greasy Creek Plant and Loading Terminal hav 
e well-established practices and procedures for maintaining process equipment.  The basic aspects of this program include: (1) training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting equipment deficiencies, when identified, (5) applying quality assurance measures.  In combination, these activities form a system that maintains the mechanical integrity of the process. 
Maintenance 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 jobs in a safe manner.   
Procedures are in place to ensure that work is performed in a consistent manner.  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 ident 
ified, 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 mechanical integrity program is quality assurance.  The Greasy Creek Plant and Loading Terminal incorporate quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use and that proper material and spare parts are used when repairs are made.   Mechanical integrity procedures are also covered in Section II, Part J of the PSM Manual. 
9.    Safe Work Practices 
The Greasy Creek Plant and Loading Terminal have 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 s 
ources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous substances 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 ensure that operations and maintenance activities are performed safely.   
See also Section II, Part K "Hot Work Permit"  of the PSM Manual. 
10.    Management of Change 
The Greasy Creek Plant and Loading Terminal have a comprehensive system to manage changes to all 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.  The details of the management of change system are also identified in Section II, Part L of the PSM Manual. 
11.    Incident Investigation 
The Greasy Creek Plant and Loading Terminal promptly investigate all incidents (no later than 48 hours after incident) that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, 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 management for resolution.  Corrective actions taken in response to the investigation team's 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 at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations.  
See also Section II, Part M of the PSM Manual. 
12.    Compliance Audits 
To help ensure that the accident prevention program is functioning properly, the Greasy Creek Plant (includes Loading Terminal) 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 shall be conducted by at least one person knowledgeable in the process.  The audit team develops findings that are forwarded to 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  
See Section II, Part O of the PSM Manual. 
13.    Chemical Specific Prevention Steps 
The processes at the Greasy Creek Plant and Loading Terminal 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 summarized previously is applied to all RMP-covered processes at the Greasy Creek Plant and Loading Terminal.  Collectively, these prevention program activities help prevent potential accident sce 
narios that could be caused by equipment failures and human errors. 
Specialized Safety Features 
The Greasy Creek Plant and Loading Terminal have 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. 
Release Containment/Control 
1. Process relief valves that discharge to a flare to capture and incinerate episodic releases 
2. Valves to permit isolation of the process (manual or automated) 
3.    Automated shutdown systems for specific process parameters (e.g., 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. Deluge system for spec 
ific equipment 
3. Personnel trained in emergency procedures 
4. Personal protective equipment  
E.    Five -Year Accident History 
The Greasy Creek Plant and Loading Terminal have an excellent record of accident prevention.  The plant and loading terminal were initially constructed in 1984 and the plant was expanded in 1985.  There have been no incidents that have had offsite effects for the last five years. 
F.    Emergency Response Program Information 
The Greasy Creek Plant and Loading Terminal maintain written emergency response procedures, which are in place to protect worker and public safety as well as the environment.  The procedures are 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 notification of local emergency response agencies if a release occurs and post incident cleanup and decontamination requirements.  
Employees receive training in emergency p 
rocedures.  The emergency response procedure is updated when necessary based on modifications made to plant facilities.  The emergency response procedure changes 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 Greasy Creek Plant and Loading Terminal is coordinated with the Hughes County, Oklahoma, Local Emergency Planning Committee (LEPC).  This coordination includes periodic meetings of the committee, which may include local emergency response officials, local government officials, and industry representatives.  The Greasy Creek Plant and Loading Terminal have 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 peri 
odic LEPC meetings, the Greasy Creek Plant and Loading Terminal conduct periodic simulated emergency drills in monthly safety meetings.  The Spill Prevention Control and Countermeasure (SPCC) Plan for the plant also identifies emergency response procedures and notification contacts. 
G.    Planned Changes To Improve Safety 
The Greasy Creek Plant (including for Loading Terminal) resolves all findings from PHAs, some of which result in modifications to the process.  The following types of changes are planned over the next few years in response to PHA, safety audit, and incident investigation findings: 
*     Revisions/enhancements to personnel training programs 
*      Revisions to operating procedures 
*     Revisions/enhancements to contractor safety programs 
*     Revisions/enhancements to mechanical integrity program 
Greasy Creek RMP    1     03/11/99 
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