Huckabay Gas Plant - Executive Summary
HUCKABAY RISK MANAGEMENT PLAN |
The Huckabay gas 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, trained personnel will respond to control
and contain the release.
The Huckabay gas plant, located 4 miles north of FM 219 near Huckabay in Erath County, Texas,
produces natural gas liquids from natural gas. These natural gas liquids are comprised primarily of
ethane, propane and butane. The plant also treats natural gas liquids to remove CO2. Some of the
chemicals produced or used include methane, ethane, propane, butane, and diethanolamine.
OFFSITE CONSEQUENCE ANALYSIS RESU
There are no toxic chemicals stored at the Huckabay gas plant above the EPA Threshold
Quantity. The threshold quantity is the level set by EPA for each toxic or flammable chemical
which if stored at the site requires compliance with the EPA's Risk Management Program
regulations. Generally, if the amount of a substance stored on-site is less than the threshold
quantity, there is little danger to the public.
There are several flammable substances stored at the site above the 10,000 pound threshold
quantity for flammables. Examples of flammables at the site include ethane, propane and butane.
The worst-case scenario associated with a release of flammable materials is a vapor cloud
explosion (VCE) involving the full inventory of a 30,000 gallon storage tank containing natural
gas liquids. Assuming the material in the tank is primarily propane, the distance away from the
plant affected in this worst-case scenario would be approximately 0.42 miles, based on EPA
A more proba
ble release scenario would involve the release of natural gas condensate from a
transfer line during loading. Based on the pump capacity of approximately 150 gallons/minutes
(9000 gallons in one hour), we would release approximately 1500 gallons in 10 minutes, at which
time our operators or the truck driver would detect and isolate the leak. The affected distance
based on EPA guidance is approximately 0.15 miles, or approximately 780 feet.
GENERAL ACCIDENT RELEASE PREVENTION PROGRAM
The Huckabay gas plant has a very active accident prevention program in place, primarily based
on the OSHA Process Safety Management regulations. A summary of some of the accident
prevention programs that are in place follows.
Process Safety Information
The Huckabay gas plant keeps a variety of technical documents that are used to help maintain safe
operation of the processes. These documents include material safety data sheets for all chemicals
on-site, up-to-date process and instrumentation drawings,
equipment data sheets on all vessels
and equipment and process parameter safety limits. 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 Huckabay gas plant has a very comprehensive program to ensure that hazards associated with
the various processes are identified and controlled. Each process is systematically examined to
identify hazards and ensure that adequate controls are in place to manage these hazards. The
what-if/checklist analysis technique is used to perform these evaluations. The analyses are
conducted using a team of people with operating, maintenance, engineering and safety experience.
This team identifies and evaluates hazards of the process, as well as accident prevention and
mitigation measures, and mak
es suggestions for additional prevention and/or mitigation measures
when the team believes such measures are necessary. All approved recommendations from the
PHA team findings are tracked until they are completed.
To help ensure that the process controls and/or process hazards do not eventually deviate
significantly from the original design and to ensure that new technology is used where
appropriate, the Huckabay gas plant periodically updates and revalidates the hazard analysis
results. These periodic reviews will be conducted at least every 5 years.
The Huckabay gas plant maintains written procedures that address various modes of process
operations. These procedures are used as reference by experienced operators, and provide a basis
for consistent training of new operators. These procedures are periodically reviewed and certified
as current and accurate.
Our employees at the Huckabay plant have an average experience of over 10 years. This level o
experience provides a great level of expertise throughout the facility. Ongoing training is
accomplished through routine safety meetings, scheduled training in new processes and refresher
training on operating procedures.
The Huckabay gas plant uses contractors to supplement its workforce during periods of increased
maintenance or to assist with specialized projects. Contractors are advised about safety and health
hazards, emergency response requirements and safe work practices prior to their beginning work.
In addition, the company evaluates contractor safety programs and performance during the
selection of a contractor. Gas plant personnel routinely monitor contractor performance to ensure
that contractors are fulfilling their safety obligations.
The Huckabay gas plant has well-established practices and procedures to maintain our equipment
in a safe operating condition. The basic aspects of this program include inspections, tests and
ons of identified deficiencies. Inspections and tests are performed to help ensure that
equipment functions as intended, and to verify that equipment operates within acceptable limits. If
a deficiency is identified, employees will correct the deficiency before placing the equipment back
in service or they will determine what actions are necessary to ensure safe operation of the
Safe Work Practices
The Huckabay gas plant has long-standing safe work practices to help ensure worker and process
safety. Examples of these include lockout/tagout to ensure isolation of energy sources for
equipment that is being worked on, a permit and procedure for hot work and a permit and
procedure for confined space entry. These procedures (and others), along with training of affected
personnel, form a system to help ensure that operations and maintenance activities are performed
Management of Change
The Huckabay gas plant has a comprehensive system to manage changes to all covered
This system requires changes to items such as process equipment, chemicals, technology
(including operating conditions), procedures and other facility changes be properly reviewed and
authorized before being implemented. Changes are reviewed to ensure that adequate controls are
in place to manage any new hazards and to verify that existing controls have not been
compromised by the change. Operating and maintenance personnel are provided any necessary
training on the change.
The Huckabay 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 of the incident or a similar incident.
CHEMICAL-SPECIFIC PREVENTION STEPS
The processes at the Huckabay gas plant have hazards that must be managed to e
safe operation. The following is a description of existing safety features applicable to prevention
of accidental releases of specific regulated substances in the facility.
The Huckabay 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 a release. The following types of
safety features are used in the covered process
1. Hydrocarbon detection sensors within the facility.
1. Process relief valves to prevent vessel overpressure.
2. Valves (both manual and automatic) to permit isolation of the process.
3. Automated shutdown systems for specific process parameters (such as high pressure or
high level in a vessel).
4. Curbing or diking to contain liquid releases.
1. Fire extinguishing systems. We have numerous fire extinguishers of several sizes
throughout the facility. In gas pla
nts, the control of fire is more dependent on restricting
sources of fuel than on putting out the fire.
The Huckabay plant has not had an incident over the past five years which has impacted off-site
people or structures.
EMERGENCY RESPONSE PROGRAM INFORMATION
The Huckabay gas plant maintains a written emergency response program, which is in place to
protect worker and public safety. The program consists of procedures for responding to a release,
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.
In addition, the Huckabay gas plant has procedures that address maintenance, inspection and
testing of emergency response equipment, as well a
s instructions that address the use of
emergency response equipment. Employees receive training in these procedures as necessary to
perform their specific emergency response duties. The emergency response program is updated
when necessary, based on modifications made to gas plant processes or other plant facilities
The overall emergency response program for the Huckabay gas plant is coordinated with the local
emergency response organizations and the emergency planning committee. This coordination
provides a means to notify the public in case of an incident, if necessary, as well as facilitating
quick response to an incident.
The Huckabay gas plant has had very safe operations over its history. However, the facility
continually looks for improvements, both to the process and to safety issues at the facility. Our
company is very active in promoting coordination between the local emergency response agencies
and our facility personnel. Ongoing communication between our facili
ty and the emergency
responders is an integral part of our operations.