Salt Creek Gas Processing Facility - Executive Summary |
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Mobil Producing Texas & New Mexico Inc. Salt Creek Gas Processing Facility Kent County, Texas Risk Management Plan (RMP) Executive Summary June 11, 1999 1.0 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES THE MOBIL PRODUCING TEXAS AND NEW MEXICO, SALT CREEK GAS PROCESSING FACILITY IN KENT COUNTY, TEXAS EXTRACTS CARBON DIOXIDE AND NATURAL GAS LIQUIDS FROM PRODUCED GASES. NATURAL GAS LIQUIDS -- ETHANE, PROPANE, BUTANE, AND PENTANE -- ARE SOLD THROUGH A THIRD-PARTY PIPELINE, AND THE CARBON DIOXIDE GAS IS COMPRESSED FOR REINJECTION INTO THE OIL PRODUCING RESERVOIR. ALTHOUGH THIS FACILITY GENERATES A MINIMAL REVENUE STREAM, ITS PRIMARY PURPOSE IS TO SUPPORT RESERVOIR BALANCE FOR OIL EXTRACTION. TOWARDS THIS END, GAS PLANT OPERATION INVOLVES THE PROCESSING AND STORING OF HAZARDOUS MATERIAL THAT PRESENT SOME DEGREE OF RISK. IN ACKNOWLEGEMENT OF THESE RISKS, THE FACILITY ESTABLISHED AND CONTINUES TO IMPROVE THE SAFETY, HEALTH, AND ENVIRONMENT MANAGEMENT SYSTEM TO: * EFFE CTIVELY MANAGE OUR PROCESS OPERATIONS; * INVEST IN THE LATEST PROCESS SAFETY TECHNOLOGIES; * TRAIN OUR PERSONNEL ON AN ONGOING BASIS; * SYSTEMATICALLY REVIEW OUR PROCESSES FOR HAZARDS ON A CONTINUING BASIS; * ENSURE SAFETY IS CONSIDERED IN PROCESS DESIGN, INSTALLATION, OPERATIONS AND MAINTENANCE; AND * TRAIN AND MAINTAIN AN EFFECTIVE EMERGENCY RESPONSE ORGANIZATION. THE SALT CREEK PLANT MAINTAINS A POLICY TO BE A GOOD BUSINESS PARTNER AND A SAFE AND CONSCIENTIOUS NEIGHBOR WHO WILL OPERATE ITS FACILITY IN COMPLIANCE WITH ALL LAWS AND REGULATIONS. THE SALT CREEK PLANT HAS A STANDING COMMITMENT TO WORKER AND PUBLIC SAFETY. WE ARE PROUD OF OUR SAFETY AND ENVIRONMENTAL PROGRAMS, AND CONTINUOUSLY STRIVE TO BE AMONG THE BEST IN INDUSTRY. 2.0 DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED THE MOBIL PRODUCING TEXAS AND NEW MEXICO SALT CREEK GAS PLANT, LOCATED IN THE SALT CREEK (OIL) FIELD UNIT IN KENT COUNTY, TEXAS, OPERATES A PROCESS TO EXTRACT CARBON DIOXIDE AND NA TURAL GAS LIQUIDS FROM PRODUCED HYDROCARBON GAS STREAMS. THE PRODUCED NGL CONTAINS REGULATED FLAMMABLE SUBSTANCES, INCLUDING ETHANE, PROPANE, ISOBUTANE, BUTANE, ISOPENTANE, AND PENTANE. 3.0 HAZARD ASSESSMENT RESULTS THE RMP RULE REQUIRES COMPANIES TO DEVELOP CHEMICAL RELEASE SCENARIOS THAT ESTIMATE THE POTENTIAL COMMUNITY IMPACT FROM AN ACCIDENTAL RELEASE. THESE SCENARIOS ARE USEFUL FOR EMERGENCY PLANNING IN THE EVENT OF AN ACCIDENT. RMP GUIDANCE FOR PROGRAM LEVEL 1 REQUIRES COMPANIES TO DEVELOP A WORST-CASE SCENARIO (WCS), THE RELEASE OF THE LARGEST STORED QUANTITY OF A REGULATED SUBSTANCE. THE WCS ASSUMES THE WORST CASE METEOROLOGICAL CONDITIONS THAT WOULD ALLOW THE RELEASE TO TRAVEL THE GREATEST DISTANCE. THE WCS FOR THE SALT CREEK GAS PLANT IS THE RELEASE OF NGL. OUR PREVENTION PROGRAMS DESCRIBED IN SECTIONS ONE AND FIVE MITIGATE AND CONTROL IMPACT. 4.0 FIVE YEAR ACCIDENT HISTORY THE MOBIL PRODUCING TEXAS AND NEW MEXICO, SALT CREEK GAS PLANT HAS HAD NO RELEASES OF REGULAT ED FLAMMABLE SUBSTANCES FROM COVERED PROCESSES WITHIN THE PAST FIVE (5) YEARS. 5.0 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM THE FOLLOWING IS A SUMMARY OF THE ACCIDENT PREVENTION PROGRAM IN PLACE AT THE SALT CREEK GAS PLANT. THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) PROCESS SAFETY MANAGEMENT STANDARD ALSO COVER THE REGULATED PROCESS WITHIN THE FACILITIY. THIS SUMMARY ADDRESSES EACH OF THE OSHA PSM ELEMENTS AND OUTLINES THE MANAGEMENT SYSTEM IN PLACE TO IMPLEMENT THE ACCIDENT PREVENTION PROGRAM. PROCESS SAFETY INFORMATION THE SALT CREEK GAS PLANT INVENTORIES A VARIETY OF TECHNICAL DOCUMENTS THAT ARE USED TO MAINTAIN SAFE OPERATION OF THE PROCESS. THESE DOCUMENTS ADDRESS CHEMICAL PROPERTIES AND ASSOCIATED HAZARDS, LIMITS FOR PROCESS PARAMETERS AND SPECIFIC INVENTORIES, AND EQUIPMENT DESIGN BASIS/CONFIGURATION INFORMATION. THE PSM/EHS COORDINATOR WITHIN THE FACILITY IS ASSIGNED RESPONSIBILITY FOR MAINTAINING UP-TO-DATE PROCESS SAFETY INFORMATION. A TABLE SUMMARI ZING 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 IS PROVIDED IN MATERIAL SAFETY DATA BULETINS (MSDBS) AND 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 FACILITY HAS DOCUMENTED SAFETY-RELATED LIMITS FOR SPECIFIC PROCESS PARAMETERS (E.G., TEMPERATURE, LEVEL, COMPOSITION) IN THE OPERATOR'S PROCEDURE MANUAL. THE FACILITY MAINTAINS THE PROCESS WITHIN THESE LIMITS BY USING PROCESS CONTROLS AND MONITORING INSTRUMENTS, TRAINED PERSONNEL, AND PROTECTIVE INSTRUMENT SYSTEMS (E.G., AUTOMATED SHUTDOWN SYSTEMS). THE FACILITY ALSO MAINTAINS NUMEROUS TECHNICAL DOCUMENTS THAT PROVIDE INFORMATION ABOUT THE DESIGN AND CONSTRUCTION OF PROCESS EQ UIPMENT. THIS INFORMATION INCLUDES MATERIALS OF CONSTRUCTION, DESIGN PRESSURE AND TEMPERATURE RATINGS, AND ELECTRICAL RATING OF EQUIPMENT. THIS INFORMATION, IN COMBINATION WITH PROCEDURES AND EQUIPMENT OPERATING HISTORY, PROVIDES A BASIS FOR 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 SALT CREEK GAS PLANT HAS A COMPREHENSIVE PROGRAM TO IDENTIFY AND CONTROL HAZARDS ASSOCIATED WITH THE PROCESS. WITHIN THIS PROGRAM, EACH PROCESS ELEMENT IS SYSTEMATICALLY EXAMINED TO IDENTIFY POTENTIAL HAZARDS, CONTROLS IN PLACE TO MANAGE THESE HAZARDS, AND RECOMMENDATIONS FOR ADDITIONAL CONTROLS, AS APPROPRIATE. THE SALT CREEK GAS PLANT USES THE HAZARD AND OPERABILITY STUDY (HAZOP) TECHNIQUE TO PERFORM THESE EVALUATIONS. HAZOP ANALYSIS IS RECOGNIZED AS ONE OF THE MOST SYSTEMATIC AND THOROUGH HAZARD EVALUATION TECHNIQUES. THE ANALYSIS IS CONDU CTED USING A TEAM OF PEOPLE WITH OPERATING AND MAINTENANCE EXPERIENCE AS WELL AS ENGINEERING EXPERTISE. THIS TEAM IDENTIFIES AND EVALUATES POTENTIAL HAZARDS OF THE PROCESS, ACCIDENT PREVENTION AND MITIGATION MEASURES, AND MAKES SUGGESTIONS FOR ADDITIONAL PREVENTION AND/OR MITIGATION MEASURES. THE PHA TEAM FINDINGS ARE FORWARDED TO LOCAL MANAGEMENT FOR RESOLUTION. IMPLEMENTATION OF MITIGATION OPTIONS IN RESPONSE TO PHA FINDINGS IS BASED ON A RELATIVE RISK RANKING ASSIGNED BY THE PHA TEAM. THE APPROVED MITIGATION OPTIONS IN RESPONSE TO PHA TEAM FINDINGS ARE TRACKED THROUGH COMPLETION. THE FINAL RESOLUTION OF EACH FINDING IS DOCUMENTED AND RETAINED.THE FACILITY PERIODICALLY UPDATES AND REVALIDATES THE HAZARD ANALYSIS RESULTS. THESE PERIODIC REVIEWS ARE CONDUCTED AT LEAST EVERY 5 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 PROCEDURESTHE SALT CREEK GAS PLANT MAINTAINS WRITTEN PROCEDURES THAT ADDRESS VARIOUS MODES OF PROCESS OPERATIONS: UNIT STARTUP, NORMAL OPERATIONS, TEMPORARY OPERATIONS, EMERGENCY SHUTDOWN, NORMAL SHUTDOWN, AND INITIAL STARTUP OF A NEW PROCESS. THESE PROCEDURES ARE USED AS A 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. THE PROCEDURES ARE KEPT CURRENT AND ACCURATE BY REVISING THEM AS NECESSARY TO REFLECT CHANGES MADE THROUGH THE MANAGEMENT OF CHANGE PROCESS.TRAININGTO COMPLEMENT THE WRITTEN PROCEDURES FOR PROCESS OPERATIONS, THE SALT CREEK GAS PLANT HAS IMPLEMENTED A COMPREHENSIVE TRAINING PROGRAM FOR ALL EMPLOYEES INVOLVED IN OPERATING THE PROCESS. NEW EMPLOYEES RECEIVE BASIC TRAINING IN PROCESS OPERATIONS IF THEY ARE NOT ALREADY FAMILIAR WITH SUCH OPERATIONS. AFTER SUCCESSFUL COMPLETION OF THIS TRAINING, A NEW OPERATOR IS PAIRED WITH A SENIOR OPERATOR TO LEARN PROCESS-SPECIFIC DUTIES AND TASKS. WHEN OPERATORS DEMONSTRATE ADEQUATE KNOWLEDGE TO PERFORM THE DUTIES AND TASKS IN A SAFE MANNER ON THEIR OWN, THEY CAN WORK INDEPENDENTLY. 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 3 YEARS, AND IS DOCUMENTED FOR EACH OPERATOR.MECHANICAL INTEGRITYTHE SALT CREEK GAS PLANT HAS 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) A PPLYING QUALITY ASSURANCE MEASURES. IN COMBINATION, THESE ACTIVITIES FORM A SYSTEM THAT MAINTAINS THE MECHANICAL INTEGRITY OF THE PROCESS.MAINTENANCE PERSONNEL RECEIVE TRAINING IN (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 PROVIDE THAT WORK IS PERFORMED IN A CONSISTENT MANNER AND SERVE AS BASIS FOR TRAINING. INSPECTIONS AND TESTS ARE PERFORMED TO HELP VERIFY THAT EQUIPMENT FUNCTIONS AS INTENDED AND 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 SITUATION PRESENTS AN IMMEDIATE SAFETY CONCERN), OR A MANAGEMENT OF CHANGE TEAM WILL REVIEW THE USE OF THE EQUIPMENT AND DETERMINE WHAT ACTIONS ARE NECESSARY. ANOTHE R INTEGRAL PART OF THE MECHANICAL INTEGRITY PROGRAM IS QUALITY ASSURANCE. THE SALT CREEK GAS PLANT INCORPORATES QUALITY ASSURANCE MEASURES INTO EQUIPMENT PURCHASES AND REPAIRS. THIS HELPS DETERMINE THAT NEW EQUIPMENT IS SUITABLE FOR ITS INTENDED USE AND THAT PROPER MATERIALS AND SPARE PARTS ARE USED WHEN REPAIRS ARE MADE. MANAGEMENT OF CHANGETHE SALT CREEK 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) DETERMINE 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 T HESE CHANGES. IN ADDITION, OPERATING AND MAINTENANCE PERSONNEL ARE PROVIDED ANY NECESSARY TRAINING ON THE CHANGE.PRE-STARTUP SAFETY REVIEWS (PSSRS)THE SALT CREEK 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 SAFETY FEATURES; PROCEDURES, PERSONNEL, AND EQUIPMENT ARE APPROPRIATELY PREPARED FOR STARTUP PRIOR TO PLACING THE EQUIPMENT INTO SERVICE. THIS REVIEW PROVIDES AN ADDITIONAL VERIFICATION THAT CONSTRUCTION IS IN ACCORDANCE WITH THE DESIGN SPECIFICATIONS AND THAT ALL SUPPORTING SYSTEMS ARE OPERATIONALLY READY. COMPLIANCE AUDITSTO HELP DETERMINE THAT THE ACCIDENT PREVENTION PROGRAM IS FUNCTIONING PROPERLY, THE SALT CREEK 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 3 YEARS. BOTH HOURLY AND STAFF PERSONNEL PARTICIPATE IN THESE AUDITS. THE AUDIT TEAM DEVELOPS FINDINGS THAT ARE FORWARDED TO FACILITY MANAGEMENT FOR RESOLUTION. CORRECTIVE ACTIONS TAKEN IN RESPONSE TO THE AUDIT TEAM'S FINDINGS ARE TRACKED UNTIL THEY ARE COMPLETE. THE FINAL RESOLUTION OF EACH FINDING IS DOCUMENTED, AND THE TWO MOST RECENT AUDIT REPORTS ARE RETAINED. INCIDENT INVESTIGATIONTHE SALT CREEK GAS PLANT PROMPTLY INVESTIGATES ALL INCIDENTS RELATED TO A COVERED PROCESS 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. THE INVESTIGATION TEAM DOCUMENTS ITS FINDINGS, DEVELOPS RECOMMENDATIONS TO PREVENT A RECURRENCE, AND FORWARDS THESE RESULTS TO FACILITY MANAGEMENT FOR RESOLUTION. CORRECTIVE ACTIONS TAKEN IN RESPONSE TO THE INVESTIGATION TEAM'S FINDINGS AND RECOMM ENDATIONS 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 5 YEARS SO THAT THE REPORTS CAN BE REVIEWED DURING FUTURE PHAS AND PHA REVALIDATIONS. EMPLOYEE PARTICIPATION THE SALT CREEK GAS PLANT ENCOURAGES EMPLOYEES TO PARTICIPATE IN ALL FACETS OF PROCESS SAFETY MANAGTEMENT 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 FACILITY'S 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 FACILITY AND ADDRESSES EACH ACCIDENT PREVENTION PROGRAM ELEMENT. SAFE WORK PRACTICESTHE SALT CREEK GAS PLANT HAS LONG-STANDING SAFE WORK PRACTICES IN PLACE TO HELP PROVIDE WORKER AND PROCESS SAFETY. EXAMPLES OF THESE INCLUDE: (1) CONTROL OF THE ENTRY/PRESENCE/EXIT OF SUPPORT PERSONNEL; (2) A LOCKOUT/TAGOUT PROCEDURE TO ISOLATE 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 VERIFY 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 PERFORM OPERATIONS AND MAINTENANCE ACTIVITIES SAFELY. CONTRACTOR SAFETYTHE SALT CREEK GAS PLANT USES CONTRACTORS TO SUPPLEMENT ITS WORKFORCE DURING PERIODS OF INCREASED MAINTENANCE OR CONSTRUCTION ACTIVITIES. BECAUSE SOME CONTRA CTORS WORK ON OR NEAR PROCESS EQUIPMENT, THE FACILITY 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 FACILITY PERSONNEL OF ANY HAZARDS THAT THEY FIND DURING THEIR WORK IN ADDITION, THE SALT CREEK GAS PLANT EVALUATES CONTRACTOR SAFETY PROGRAMS AND PERFORMANCE PRIOR TO THE SELECTION OF A CONTRACTOR. FACILITY PERSONNEL PERIODICALLY MONITOR CONTRACTOR PERFORMANCE WITH REGARD TO THEIR SAFETY OBLIGATIONS. 7. EMERGENCY RESPONSE PROGRAM INFORMATION THE SALT CREEK GAS PLANT EMERGENCY RESPONSE PROGRAM SERVES AS THE FINAL LINE OF DEFENSE AGAINST ACCIDENTAL RELEASES AND OTHER EMERGENCIES. WHILE THE PURPOSE OF THE OTHER ELEMENTS OF THE RISK MANAGEMENT AND PROCESS SAFETY MANAGEMENT PROGRAMS SERVE TO PREVENT INCIDENTS AND RELEASES OF HIGHLY HAZARDOUS MATERIAL, THE EMERGENCY RESPONSE PLAN SERVES AS THE GUIDELINE FOR REACTING TO ACCIDENTAL RELEASES AND OTHER EMERGENCIES IF THEY OCCUR. THE SALT CREEK PLANT AND FIELD HAS A HIGHLY CAPABLE RESPONSE ORGANIZATION THAT IS WELL EQUIPPED TO RESPOND TO A GAS PLANT EMERGENCY. EMERGENCY DRILLS AND EXERCISES ARE COORDINATED WITH MANY LOCAL AGENCIES, INCLUDING THE CITY OF JAYTON FIRE DEPARTMENT AND EMS, THE CITY OF CLAIRMONT FIRE DEPARTMENT AND EMS, THE CITY OF SNYDER FIRE DEPARTMENT AND EMS, AND THE KENT COUNTY SHERIFF. OTHER FREQUENT DRILL PARTICIPANTS INCLUDE THE KENT COUNTY LEPC, THE TEXAS RAILROAD COMMISSION, AND THE TEXAS NATIONAL RESOURCE CONSERVATION COMMISSION. FINALLY, ALL DRILLS MANDATE PARTICIPATION OF ALL CONTRACT PERSONNEL WITHIN THE PLANT FENCE. TO HELP THE LOCAL COMMUNITY MAINTAIN EMERGENCY RESPONSE READINESS, SALT CREEK PERSONNEL PROVIDE FIRST AID AND CPR TRAINING FOR LOCAL EMTS, SERVE VOLUNTEER TIME WITH LOCAL AMBULANCE SERVICES, ASSIST AS RESPONDERS TO LOC AL VEHICLE ACCIDENTS, AND HAVE ASSISTED IN AN OFFSITE CONFINED SPACE RECOVERY AND INVESTIGATION. IN ADDITION, SALT CREEK ROUTINELY PROVIDES EMERGENCY RESPONSE EQUIPMENT AND SUPPLIES TO LOCAL AGENCIES. 8. PLANNED CHANGES TO IMPROVE SAFETY THE MOBIL PRODUCING TEXAS AND NEW MEXICO, SALT CREEK GAS PLANT CONTINUALLY IMPROVES SAFETY, HEALTH, AND EVIRONMENTAL PROGRAMS. OUR SAFETY HEALTH AND ENVIRONMENTAL MANAGEMENT SYSTEM CONTINUOUS IMPROVEMENT PROGRAM, ALONG WITH OUR INTERNAL AUDIT PROGRAM DEMONSTRATES OUR WILLINGNESS TO IMPROVE. THE FOLLOWING TYPES OF OVER THE NEXT FEW YEARS: ANNUAL REVIEW OF PERSONNAL TRAINING PROGRAMS; ANNUAL REVIEW OF ENERGY ISOLATION PROCEDURES; AND ANNUAL REVIEW OF THE EMERGENCY RESPONSE PLAN. |