Laverne Gas Plant - Executive Summary
LAVERNE GAS PLANT
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES
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.
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES
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
OFFSITE CONSEQUENCE ANALYSIS RESULTS
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.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM
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
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
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
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.
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.
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.
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.
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.
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..
CHEMICAL-SPECIFIC PREVENTION STEPS
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:
1. Hydrocarbon detectors with alarms
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
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
FIVE-YEAR ACCIDENT HISTORY
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.
EMERGENCY RESPONSE PROGRAM INFORMATION
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.
PLANNED CHANGES TO IMPROVE SAFETY
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.