TXU Processing Springtown Plant - Executive Summary

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The Springtown gas plant has a long-standing commitment to employee and public safety.  This 
commitment is demonstrated by the resources invested in accident prevention, such as training of 
personnel and considering safety in the design, installation, operation, and maintenance of our 
processes.  Our standing practice is to implement reasonable controls to prevent foreseeable 
releases of regulated flammable substances.  However, if a release does occur, trained gas plant 
personnel will take appropriate action to control/mitigate the release. 
The Springtown gas plant, located in Springtown, Texas, operates a variety of processes to 
recover petroleum products (e.g., natural gas, propane, butane, condensate) from field gas.  The 
gas plant also recovers the regulated flammables, pentane and ethane.  There are no threshold 
quantities of toxic substances present. 
The worst-case scenario (WCS) associated with a release of flammable substances in Program 3 
processes at the gas plant is a vapor cloud explosion (VCE) involving the full inventory of the 
storage tank containing 84,000 lb of natural gas liquids (NGL).  The maximum tank capacity is 
assumed to release and ignite.  The maximum distance to the 1-psi endpoint for this WCS is 0.4 
mile.  Although we have a number of controls to prevent such releases, no credit for mitigation 
measures were taken into account in evaluating this WCS. 
The alternative release scenario (ARS) for flammable substances at the gas plant is a vapor cloud 
fire (VCF) involving the storage tank containing 125,100 lb of propane.  The maximum distance 
to the 1-psi endpoint for this ARS is 0.1 mile.  No credit for mitigation measures were taken into 
account in evaluating this ARS. 
The following is a summary of the accident prevention program in place 
at the 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 Springtown gas plant encourages employees to participate in all facets of process safety 
management and accident prevention.  Examples of employee 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 pla 
n that is 
maintained at the gas plant and addresses each accident prevention program element.  In 
addition, the gas plant has a number of initiatives in place that address process safety and 
employee safety issues. 
Process Safety Information 
The Springtown gas plant keeps 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.  Specific departments within the gas plant are assigned 
responsibility for maintaining up-to-date process safety information.  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 provide 
d in material safety data sheets (MSDSs).  This information is 
supplemented by documents that specifically address known corrosion concerns and any known 
hazards associated with the inadvertent mixing of chemicals.  For specific process areas, the gas 
plant has documented safety-related limits for specific process parameters (e.g., temperature, 
level, composition).  The gas plant ensures that the process is maintained within these limits 
using process controls and monitoring instruments, highly trained personnel, and protective 
instrument systems (e.g., automated shutdown systems). 
The gas plant also maintains numerous technical documents that provide information about the 
design and construction of process equipment.  This information includes materials of 
construction, design pressure and temperature ratings, and electrical rating of equipment.  This 
information provides a basis for establishing inspection and maintenance activities, as well as 
evaluating proposed changes to ensure  
that safety features in the process are not compromised. 
Process Hazard Analysis (PHA) 
The Springtown 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 gas plant primarily uses the What If analysis technique to perform these evaluations.  The 
analyses are conducted using a team of people who have operating and maintenance experience 
as well as engineering expertise.  The 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 sent to local and corporate management for resolution.  
Implementation of mitigation options in response to  
PHA findings is guided by a relative risk 
ranking assigned by the PHA team.  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 Springtown 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 procedures are kept current and accurate by revising them as necessary 
to reflect changes made through the management of change process.  These procedures are 
readily available in the process unit for operators and other personnel to use as necessary to 
safely perform their job task. 
To complement the written procedures for process operations, the Springtown 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) having 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.  This training is documented for each operator, including the means 
used to verify that the operator understood the training. 
The Springtown gas plant uses contractors to supplement its work force 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 know 
ledge 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 plant safety rules, and (6) inform gas plant personnel of any hazards that 
they find during their work.  This is accomplished by providing contractors with (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 
Springtown 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 Springtown gas plant conducts a PSSR for any new facility or process modification that 
requires a change in the process safety information.  The purpose of the PSSR is to ensure that 
safety features, procedur 
es, personnel, and equipment are appropriately prepared for startup prior 
to placing the equipment into service.  This review provides an additional check to make sure 
construction is in accordance with the design specifications and that all supporting systems are 
operationally ready.  The PSSR team uses checklist(s) to verify startup 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. 
Mechanical Integrity 
The Springtown gas plant has well-established practices and procedures to maintain pressure 
vessels, piping systems, relief valves, controls, pumps and compressors, and emergency 
shutdown systems in a safe operating condition.  The basic aspects of this program include:  (1) 
conducting training, (2) scheduled preventive maintenance, (3) performing inspections and tests, 
(4) correcting identified deficiencies, and (5) applying quali 
ty assurance measures.  In 
combination, these activities form a system that maintains the mechanical integrity of the 
Maintenance personnel receive training on (1) an overview of the process, (2) safety and health 
hazards, (3) applicable maintenance procedures, (4) emergency action plan, and (5) applicable 
safe work practices to help ensure that they perform their jobs in a safe manner.  Scheduled 
preventive maintenance helps ensure that work is performed in a timely and 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 identified, employees will correct the deficiency before placing the 
equipment back into service (if possible), or plant management will review the use of the 
equipment and determine what actions are necessary to ensure the safe operation of the 
Another integral  
part of the mechanical integrity program is quality assurance.  The Springtown 
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 Springtown 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 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. 
Management of Change 
The Springtown 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.  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 Springtown gas plant promptly investigates all incidents that resulted in, o 
r reasonably could 
have resulted in, a fire/explosion, 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 plant 
management for resolution.  Corrective actions taken in response to the investigation team's 
findings and recommendations are tracked until completed.  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 
Compliance Audits 
To help ensure that the accident prevention program is functioning properly, the S 
pringtown 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 may participate as audit team members.  
The audit team findings are forwarded to plant management for resolution.  Corrective actions 
taken in response to the audit team's findings are tracked until completion.  The final resolution 
of each finding is documented, and the two most recent audit reports are retained. 
The processes at the Springtown gas 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 summarized above is applied to all RMP covered processes a 

the Springtown gas plant.  Collectively, these prevention program activities help prevent 
potential accidents that could be caused by equipment failures and human errors. 
Specialized Safety Features 
The Springtown gas plant has safety features 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 
7 Hydrocarbon detectors with alarms 
Release Containment/Control 
7 Process relief valves that discharge to a vent stack 
7 Valves to permit isolation of the process (manual or automated) 
7 Automated shutdown systems for specific process parameters (e.g., high temperature) 
7 Curbing or diking to contain liquid releases 
7 Redundant equipment and instrumentation (e.g., uninterruptible power supply for process 
control system, backup pumps) 
7 Atmospheric relief devices 
Release Mitigation 
7 Fire extinguishers 
7 Trained personnel 
7 Personal protective equipment 
The Springtown gas plant has an excellent record of accident prevention over the past five years.  
There have been no releases of regulated substances that resulted in deaths, injuries, property or 
environmental damage, evacuations, or sheltering in place.  Also, there has been a decreasing 
trend in the frequency of incidental releases. 
The Springtown gas plant maintains a written emergency action plan, which is in place to protect 
the safety of workers and the public, as well as the environment.  There are no 112(r) threshold 
toxic substances on the plant site.  For a non-incidental release of a flammable substance, 
including the possibility of a fire, response actions have been coordinated with the local fire 
department, and mechanisms for notification are in place.  Employees receive training as 
necessary to perform their specific emergency actions.  The emergency action plan is updated 
when necessary, and affected personnel are informed and/or trained in the changes.   
The gas plant has around-the-clock communications capability with appropriate 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. 
The Springtown gas plant resolves all findings from PHAs, some of which result in 
modifications to the process.  No changes are currently planned.
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