Laverne Gas Plant - Executive Summary

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The Continental Natural Gas Laverne 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, gas plant trained personnel will respond to 
control and contain the release. 
The Laverne gas plant, located in Laverne, Oklahoma, operates a variety of processes to produce 
petroleum products (e.g., natural gas, propane, butane, condensate) from natural gas. The Laverne 
gas plant has several regulated flammables, such as propane and butane. There are no regulated toxic 
substances at the Laverne f 
The worst-case scenario (WCS) associated with a release of flammable substances in Program Level 
3 processes at the gas plant is a vapor cloud explosion (VCE) involving the full inventory of the 
largest storage tank containing butane. A written procedure is in place to limit the storage inventory 
to 257,600 lb, (90% of the maximum tank capacity); therefore, the reduced inventory is assumed to 
release and ignite, resulting in a VCE. The maximum distance to the 1psi endpoint for this WCS is 
0.51 miles. Although numerous controls are in place to prevent such releases and to manage their 
consequences, no credit for passive mitigation measures was taken into account in evaluating this 
The Alternative Release Scenario (ARS) for flammable substance's At the Laverne gas plant is a VCE 
resulting from the release of propane from a product loading pump. The release is expected to be 
isolated by the operators within 15 minutes (active mitigatio 
n). The maximum distance to the 1 - psi 
endpoint for this event is 0.48 miles. This event was selected as being a practical scenario for use in 
emergency planning and response. Figure 1-1 graphically presents the hazard assessment results for 
the flammable WCS and ARS events. 
The following is a summary of the accident prevention program in place at the Laverne plant. Because 
processes at the gas plant that are regulated by the Environmental Protection Agency's (EPA's) risk 
management program (RMP) regulation 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 
prevention program. 
Employee Participation 
The Laverne gas plant encourages employees to participate in all facets of process safety management 
and accident prevention. Examples of employe 
e 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 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 gas plant and 
addresses each accident prevention program element. In addition, the gas plant has a number of 
initiatives under way which address process safety and employee safety issues. These initiatives 
include forming teams to promote both process and personal safety. The teams typically have 
members from various areas of the plant, including operations, maintenance, engineering, and plant 
Process Safety Information 
The Laverne gas plant keeps a variety of technical documents that are used to help maintain safe 
operation of the processes. These document 
s address chemical properties and associated hazards, 
limits for key process parameters and specific chemical inventories, and equipment design 
basis/configuration information. Specific departments within the gas plant are  assigned responsibility 
for maintaining up-to-date process safety information. A table  summarizing the reference documents 
and their location 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 (MSDSs). The gas plant ensures 
that the process is maintained within acceptable limits using process controls and monitoring 
instruments, highly trained personnel,  and protective instrument systems (e.g., automated shutdown 
The gas plant also maintains numerous technical documents that provide information about the desig 

and construction of process equipment. This information includes materials of construction, design 
pressure and temperature ratings, and electrical rating of equipment. 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 Laverne gas plant has 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 Laverne gas plant primarily uses 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. 
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 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. 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 findings is documented and retained. 
Operating Procedures 
The Laverne 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 procedu 
res are kept current and accurate by  revising them as necessary to reflect changes made 
through the management of change process. In addition, the Laverne plant maintains written 
operating procedures, which are readily available to operators in the process unit and for other 
personnel to use as necessary to safely perform their job tasks. 
To complement the written procedures for process operations, the Laverne gas plant has implemented 
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 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. 
This refresher training is conducted at least every three years. All of this training is documented for 
each operator, including the means used to verify that the operator understood the training.   
The Laverne 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 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 emergency, (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 w 
ith (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 Laverne gas 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. 
Pre-Startup Safety Reviews (PSSRs) 
The Laverne gas plant conducts a 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 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 checkl 
ists to verify all aspects of readiness. A PSSR involves field verification 
that accident prevention program requirements are properly implemented. 
Mechanical Integrity 
The Laverne 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. 
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. 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 mechanical integrity program is quality assurance. The Laverne gas 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 Laverne 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 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 sparkproducing 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. 
Management of Change 
The Laverne gas plant has 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. 
Incident Investigation 
The Laverne gas plant 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. The goal of each investigation is to determine the facts and develop corrective actions to 
prevent a recurrence and forwards these results to gas plant 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 five years so that the reports 
can be reviewed during future PHAs and PHA re-validations. 
Compliance Audits 
To help ensure that the accident prevention program is functioning properly, the Laverne 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 
three years. Both hourly and staff personnel 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. Th 
e final resolution of 
each finding is documented, and the two most recent audit reports are retained.. 
The processes at the Laverne gas plant have hazards that must be managed to ensure continued safe 
operation. 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 Laverne gas plant. Collectively, these prevention program activities help prevent potential 
accident scenarios that could be caused by equipment failures and human errors. 
Specialized Safety Features 
The Laverne 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 Dete 
    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, backup firewater pump) 
    6.   Atmospheric relief devices 
Release Mitigation 
    1.   Fire suppression and extinguishing systems 
    2.   Deluge system for specific equipment 
    3.   Trained emergency response personnel 
    4.   Personal protective equipment (e.g., chemical protective clothing, self-contained breathing 
    5.   Blast-resistant buildings to help protect control systems and personnel 
The Laverne gas  
plant has an excellent record of accident prevention over the past five years. There 
have been no off-site accidents within this time period. 
The Laverne gas plant maintains a written emergency response program that 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, as well as instructi 
ons that address the use of emergency response equipment. 
Employees receive training in these procedures as necessary to perform their specific emergency 
response duties. When necessary, the emergency response program is updated based on modifications 
made to gas plant processes or other Laverne gas plant facilities. The emergency response program 
changes are administered through the MOC process, which includes informing and/or training 
affected personnel in the changes.  
The overall emergency response program for the Laverne gas plant is coordinated with the Laveme, 
Oklahoma Local Emergency Planning Committee (LEPC). This coordination includes periodic 
meetings of the committee, which includes local emergency response officials, local govemment 
officials, and industry representatives. The Laveme 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 p 
ublic of an incident, if necessary, as well as 
facilitating quick response to an incident. In addition to periodic LEPC meetings, the Laveme gas 
plant conducts periodic emergency ddlis that involve the LEPC and emergency response 
organizations, and the gas plant provides annual refresher training to local emergency responders 
regarding the hazards of regulated substances in the gas plant. 
The Laveme gas plant resolves all findings from PHAs, some of which may result in modifications 
to the process. At the current time, no changes are planned over the foreseeable future.
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