Exxon Company, U.S.A. Cordona Lake Gas Plant - Executive Summary

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Accidental Release Prevention and Response Policies 
Exxon modified its safety programs in 1992 by implementing structured safety management systems entitled Operations Integrity Management System (OIMS).  In 1997, Lloyd's Register Quality Assurance reviewed OIMS and evaluated it against the international standard for Environmental Management Systems (ISO 14001) to determine if OIMS meets the requirements of ISO 14001.  After an extensive review which included a number of facility audits, they concluded that the "environmental components of OIMS are consistent with the intent and meet the requirements of the ISO 14001 Environmental Management Systems Standard."  They went on to say, "We further believe Exxon to be among the industry leaders in the extent to which environmental management considerations have been integrated into its ongoing business processes." 
The Cordona Lake Gas Plant has a long-standing commitment to worker and public safety.  This commitment is demonstrated by the  
resources invested in accident prevention (e.g., training of personnel, considering safety in the design, installation, operation, and maintenance of the facility, etc.).  Our approach is to implement reasonable controls to prevent foreseeable releases of regulated substances as well as other substances.  If a release does occur, our trained personnel will take steps to control and contain it until local emergency response organizations arrive.  Additional details are included in other sections of this RMPlan. 
Description of the Stationary Source and Regulated Substances  
This plant, located 15 miles SW of Crane, Texas, consists of one Program Level 1 process, which utilizes several operations (e.g., separation, dehydration, compression, refrigeration) to produce petroleum products (e.g., natural gas liquid mixture, methane) from a naturally occurring hydrocarbon gas mixture.  This plant could contain up to 140,000 pounds of regulated flammables (e.g., mixture containing methane, etha 
ne, propane, butane, iso-butane, pentane, and iso-pentane), but no regulated toxic inventories in excess of the threshold quantities established in the regulation.  All transportation of regulated flammables into and out of the facility is handled via pipelines.  The adjacent tank farm operation handles condensate and lube oil (no regulated flammables) and is not considered part of the stationary source's covered process.  This plant  is surrounded by pasture. 
Offsite Consequence Analysis Results 
Worst Case Scenario (WCS) -  
The flammable WCS, as defined in the regulation, is a release of a mixture of natural gas liquids resulting in a vapor cloud explosion (VCE) involving the maximum inventory of the largest vessel.  Even though the normal operating inventory for this equipment is significantly less than the maximum capacity and this equipment is protected by high level alarms/shutdowns, pressure relief valves, periodic inspections, and routine monitoring by operating personnel, this 
maximum inventory must be assumed to be released in 10 minutes and ignited at the point of release.  No mitigation measures were taken into account in evaluating this WCS.  The WCS could have some off-site impacts, but the impact area does not include any public or environmental receptors.  
General Accidental Release Prevention Program 
The following is a summary of the accident prevention program in place at this plant.  Because processes at this plant regulated by EPA's Risk Management Program (RMP) regulation are also subject to (and in compliance with) 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 - 
This plant provides for and encourages employees to participate in all aspects of process safety management and accident prevention.  Examples of employee participation range from updating/compiling technical informat 
ion and drawings to participating on process hazard analysis (PHA) or incident investigation teams.  Employees have access to all information related to the accident prevention program.  Specific ways that employees can be involved in the accident prevention program are detailed in an Employee Participation Plan that is maintained at this plant and addresses each program element.  In addition, this plant has other initiatives that address process and employee safety issues (e.g., hazard reporting/resolution process and numerous safety meetings [daily, monthly, pre-job], etc.). 
Process Safety Information (PSI) - 
This plant keeps a variety of technical documents that are used to help maintain safe operation of the facility.  These documents address chemical properties and associated hazards, safe operating limits for key process parameters, specific chemical inventories, and equipment design basis/configuration information.  The OIMS contact for this plant is responsible for coordinatin 
g the PSI updates. 
Chemical-specific information (including exposure hazards, emergency response, and exposure treatment considerations) is provided in material safety data sheets.  For specific process areas, this plant has documented safety-related operating limits for process parameters (e.g., temperature, pressure, and level).  This plant ensures processes are maintained within these limits using process controls/monitoring equipment, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems, pressure relief valves). 
This plant also maintains numerous technical documents that provide information about the design and construction of the process equipment.  This information includes the materials of construction, design pressure, temperature ratings, and electrical rating of equipment.  This information, in combination with written procedures and trained personnel, provides a basis for inspection/maintenance activities and the evaluation of propo 
sed process or facility changes. 
Process Hazard Analysis (PHA) - 
This plant has a comprehensive program to help ensure hazards associated with the various processes are identified and controlled.  Within this program, each process is systematically examined to identify hazards and ensure adequate controls are in place to manage these hazards. 
This plant uses the Hazard and Operability (HAZOP) study analysis technique to perform these evaluations.  This technique is recognized by OSHA as an acceptable hazard evaluation technique for PSM-covered processes.  The analyses are conducted using a team of plant operating/maintenance personnel and facility engineers, and technical consultants (as necessary).  This team identifies and evaluates hazards of the processes as well as the accident prevention and mitigation measures.   
The PHA team findings are forwarded to management to coordinate further evaluation and resolution.  This process involves field level business teams, which include e 
ngineering personnel, operations personnel, and management.  Operating personnel are also involved in the evaluation of resolution options.  Implementation of the resolutions is prioritized for accomplishment based on a relative risk.  All resolution plans are tracked until completed.  The final resolution of each finding is documented and retained. 
To help ensure the process controls and/or hazards do not eventually deviate significantly from the original design, this plant updates and revalidates the process hazard analysis at least every 5 years.  The results of these updates are also documented and retained.  Similarly, the team's findings are forwarded to management to coordinate further evaluation and resolution, and the final resolution of findings are documented and retained. 
Operating Procedures - 
This plant maintains written procedures that address the various modes of process operations (e.g., startup, normal, temporary, emergency shutdown, normal shutdown, cold startup) a 
nd provide guidance on how to respond to upper/lower limit exceedances for specific equipment or process parameters.  Procedures are readily available to operators and other personnel to use as necessary to safely perform their job tasks.  These procedures provide a consistent basis for training new operators and are annually reviewed and certified as current/accurate.  Procedures are maintained current/accurate by revising them as necessary to reflect changes made through the management of change process. 
Training - 
To complement the written operating procedures, this plant has implemented a comprehensive training program for all employees involved in operating process equipment.  New employees receive basic training in plant operations (e.g., process overview, applicable procedure reviews, etc.).  New operators are then paired with experienced operators (i.e., subject matter experts) to learn process-specific duties and tasks.  After the new operators demonstrate (e.g., hands-on ski 
lls demonstration) that they have adequate knowledge to perform the duties and tasks in a safe manner on their own, they are certified and allowed to work independently.  In addition, all personnel who operate process equipment receive refresher training at least every 3 years on the applicable procedures to help ensure their skills and knowledge are maintained at an acceptable level.  This training and the means used to verify that the employee understood the training is documented for each employee. 
Contractors - 
This plant uses contractors to supplement its workforce during periods of increased maintenance or construction activity.  Because some contractors work on or near process equipment, this plant has procedures in place to help ensure contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in the workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow safety  
rules, and (6) inform plant personnel of any hazards they find during their work.  This is accomplished by providing contractors an orientation prior to their working in this plant, which includes (1) process overview, (2) information about safety and health hazards, (3) applicable emergency action plan provisions, and (4) information on safe work practices.  Also, a job safety analysis is reviewed/updated or developed by the contractors (with plant personnel assistance as needed) prior to each maintenance/construction job. 
Plant personnel routinely monitor contractor job performance to help ensure they are fulfilling their safety obligations.  Contractor safety programs/performance are evaluated during the initial selection process, and the plant supervisor conducts periodic evaluations of safety performance. 
Pre-Startup Safety Reviews (PSSR) - 
This plant conducts a PSSR for any  modification that requires a change in the process safety information.  The purpose of the PSSR is to en 
sure 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 that construction is in accordance with the design specifications and all supporting systems are operationally ready.  A PSSR involves field verification of the construction and serves a quality function by verifying that the requirements of this accident prevention program are properly implemented. 
Mechanical Integrity (MI) - 
This plant has well-established practices and procedures to maintain pressure vessels, piping systems, relief/vent systems, controls, pumps, compressors, and emergency shutdown systems in a safe operating condition.  The basic aspects of this MI program include (1) training, (2) written procedures, (3) inspections/tests, (4)correction of identified deficiencies, and (5) quality assurance measures.  In combination, these activities form a system that maintains the mec 
hanical integrity of the process.  Maintenance personnel receive training on the (1) process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency procedures, and (5) applicable safe work practices to help ensure they perform their jobs in a safe manner.  Written procedures and equipment manuals help ensure work is performed in a consistent manner and provide a basis for training.   
Inspections/tests and preventive maintenance are performed on a scheduled basis to help ensure equipment and safety devices function as intended and to verify that equipment is within acceptable limits (e.g., adequate wall thickness, etc.).  If a deficiency is identified, employees correct the deficiency before placing the equipment back into service or a group of experts (e.g., engineers, etc.) review the use of the equipment and determine what actions are necessary to ensure safe operation of the equipment until the deficiency can be corrected. 
Another integral part of the 
MI program is quality assurance.  This plant incorporates quality assurance measures into equipment purchases and repairs to help ensure new equipment is suitable for its intended use and proper materials/spare parts are used for repairs. 
Hot Work and Other Safe Work Practices - 
This plant has long-standing safe work practices in place to help ensure worker and process safety.  These include orientations for visitors/contractors, control of the entry/presence/exit of support personnel, energy isolation for equipment being worked on, procedures for the safe removal of hazardous materials before opening of process piping/equipment, hot work permit/procedure to safely manage spark-producing activities, vehicle entry into process area, confined space entry permit/procedure to help ensure precautions are taken before entering confined spaces, job safety analyses to identify and mitigate hazards associated with maintenance tasks).  These practices, along with related procedures and trainin 
g of affected personnel, form a system to help ensure operations and maintenance activities are performed safely. 
Management of Change (MOC) - 
This plant has a comprehensive system to manage changes.  This system requires that changes to 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 adequate controls are in place to manage any new hazards and to verify that existing controls have not been compromised by the change.  Affected chemical hazard information, process operating limits, equipment information, drawings, and procedures are updated for these changes.  In addition, operating and maintenance personnel are provided any necessary training related to the change. 
Incident Investigation - 
This plant promptly investigates all incidents that resulted in (or could have reasonably resulted in) a fire, explosion, release,  
major equipment/property damage, environmental loss, or personal injury.  The goal of each investigation is to determine the facts and develop corrective actions to prevent recurrence of the incident or a similar incident.  The investigation team documents its findings, develops recommendations, and forwards these results to management for resolution.  Corrective actions taken in response to the investigation team's findings are tracked until completed.  The final resolution of each finding is documented, and investigation results are reviewed with all employees (including contractors) who could be affected.  Incident investigation reports are retained for at least 5 years so that reports can be reviewed during the next PHA revalidation. 
Compliance Audits - 
To help ensure the accident prevention program is functioning properly, an audit is conducted at this plant at least once every 3 years to determine whether the program's procedures and practices are being implemented.  An audit te 
am consisting of both plant and technical personnel evaluate the implementation/effectiveness of the processes in this accident prevention program and develop findings that are documented and forwarded to management to coordinate resolution.  Corrective actions are taken in response to the audit team's findings, and resolution status is tracked until actions are completed.  The final resolution of each finding is documented and the two most recent audit reports are retained. 
Chemical-Specific Prevention Steps 
The processes at this plant have hazards that are managed to help ensure continued safe operation.  The following is a description of existing safety features applicable to the prevention of accidental releases of the specific regulated substances (i.e., flammables). 
Universal Prevention Activities - 
The accident prevention program summarized previously is applied to the RMP-covered process at this plant.  These prevention program activities help prevent potential accident scena 
rios that could be caused by equipment failures and human errors. 
Specialized Features - 
This plant has safety features on many units to (1) quickly detect a release, (2) contain/control a release, and (3) reduce/mitigate the consequences of a release.  The following types of safety features are used: 
Release Detection ...  
- Hydrogen sulfide detectors around compressors 
- Lower Explosive Limit (LEL) gas detectors around towers 
Release Containment/Control ... 
- Pressure relief valves that discharge into a flare system for incineration 
- Automatic isolation valves between compressors and Ryan-Holmes Unit 
- Automated shutdown systems for specific process parameter (e.g., low and high level shut downs on NGL drum) 
- Redundant equipment and instrumentation (e.g., dual relief valves, back-up process pumps) 
Release Mitigation ...  
- Fire extinguishing systems (e.g., portable fire extinguishers, halon system in control room) 
- Personal protective equipment (e.g., self-contained breathing  
- Trained personnel 
Five Year Accident History 
This plant has had an excellent record for accident prevention over the past 5 years.  In fact, there have not been any incidents, as defined in the regulation. 
Emergency Response Program Information 
This plant maintains an emergency action program to protect the workers, public, and environment.  The program consists of procedures for handling releases of regulated substances (i.e., flammables) including the possibility of fires or explosions.  The procedures address facility/equipment isolation and shutdown, initial first aid and medical treatment for exposures (i.e., Material Safety Data Sheet information), evacuation plans for this plant, accounting for plant personnel after an evacuation, notification of local emergency response agencies, and post-incident cleanup/decontamination requirements.  In addition, this plant has procedures that address the maintenance, inspection, and testing of emergency equipment and alarms.   
Plant personnel receive training in these procedures as necessary to perform their specific duties.   
The emergency action program is reviewed annually and updated when necessary.  Plan changes required because of modifications to the  facility or emergency equipment are administered through the Management of Change process, which includes informing and/or training affected personnel. 
The overall emergency response program for this plant is coordinated with the Crane County Local Emergency Planning Committee (LEPC), City of Crane Volunteer Fire Department, Crane County Sheriff's Department, and local ambulance services.  This plant has around-the-clock communications capability with these emergency response organizations, and these organizations are responsible (if necessary) for notifying the public, coordinating the community response (e.g., blocking off roads, evacuation, etc.), and providing onsite response (e.g., fire fighting, medical treatment, etc.).  This plant conducts peri 
odic emergency action drills and provides periodic refreshers to the local emergency response organizations on the hazards associated with the plant operations. 
Recent Changes to Improve Safety 
Our Operations Integrity Management Systems form the cornerstone for continuous improvement in our safety-related systems.  These systems are evergreen and are in a continuous state of improvement, usually through many small improvement steps.  These improvement steps are tightly integrated with our training programs.  This plant resolves all findings from PHAs, incident investigations, and safety audits.  The following are some of the changes that are currently being implemented (or were recently completed) to improve the safety of this operation: 
1. Working to alleviate any means of trapping cold liquid. 
2. Installed block and bleed valves for isolation of side heater.
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