Williams Field Service - Executive Summary

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Accidental release prevention and response policies: 
We at the Opal Plant are strongly committed to employee, public and environmental safety.  This commitment 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 appropriate controls to prevent possible releases of regulated substances.  Our emergency response plan includes procedures for notification of trained personnel to respond, control and contain the release. Opal Plant is in  compliance of Process Safety Management and of the elements of PSM are in place at the Opal Plant. 
Opal Plant has an Emergency Policy/Procedure manual. This manual and its procedures are updated as needed and annually. The local Emergency Management is located in Kemmerer Wyoming. The plant works closely with this agency and keeps them up to date  
on our Emergency Plan.  
The Stationary Source and Regulated substances: 
The Opal Plant operates a cryogenic gas liquid extraction process This process consists of 3 cryogenic gas plants. Commercial grade Methane is produced by extracting Propane, Butane, and flammable mixture of natural gas liquids from the inlet gas stream of unprocessed natural gas. The Opal plant also is equipped with a load out facility. 
Worst Case Release Scenario and Alternative Release Scenarios: 
The first worst case scenario with a release of flammable substances is a vapor cloud explosion involving a rail car full of propane at our load out facility.  
The amount released would be 36,000 gallon of liquid propane or 152,000 pounds. The distance to a 1psi over pressure (ENDPOINT) would be .4312 miles. The second WCS is the inlet liquid slug catcher had a release. This product would be Pentane. The amount released would be 304,000 gallons or 1,584,000 pounds. The (ENDPOINT) is .9417 mile. There are procedures, 
employee training,  gas detection alarms, fire detection and shutdowns  in the facility to help prevent this from occuring. The facility also is equipped with a deluge fire water system. 
The alternative release scenario for flammable substance at Opal plant is a vapor cloud explosion resulting in the release of propane from a ruptured loading hose at the load out facility. The release would be 1939 gallons or 8195 pounds. The (ENDPOINT) for this release is .1654 miles. There are procedures, employee training, gas detection alarms and shutdowns to help prevent this from occuring.  
General Accidental Release Prevention Program:  
Opal Plant encourages employee participation in all aspects of Process Safety Management and Accident Prevention.  Employee's participation ranges from updating and compiling technical data for Operating Procedures and Process Safety information to participating as a member of a Process Hazard Analysis team.  In addition, Opal plant has a number of initi 
atives that 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 area of the plant, including operations, maintenance, technicians, and plant management. Opal plant has a written safety program. 
Opal has an Emergency Policy/ Procedure manual. The plant works closely with the Lincoln county Emergency Management and the local LEPC of Kemmerer Wyoming. 
Process Safety Information: 
Opal 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 information.  This information, in conjunction 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: 
Opal Plant has a comprehensive program to help ensure that hazards associated with the 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.   
Operating Procedures: 
Opal Plant maintains written procedures that address various modes of process operations, such as (1) initial start-up,  (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) emergency operations, (6) normal shutdown, (7) start-up after turnaround. (8) Upper & lower alarm set points and deviation. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators.  These procedures are reviewed and verified as current and accurate annually. 
Opal Plant uses contractors to supplement its wor 
kforce during periods of increased maintenance or construction activities.  Because some contractors work on or near process equipment we have procedures in place to ensure that contractors, (1) perform their work in a safe manner, (2) are aware of any hazards in the workplace, (3) understand what they should do in the event of an emergency, (4) understand and follow site safety rules, and (5) inform plant personnel of any hazards that they find during their work.  This is accomplished by providing them with a process overview, information about safety and health hazards, emergency response plan requirements and safe work practices prior to beginning their work.  Opal Plant personnel periodically conduct safety audits on contractor performance to ensure that they are working in a safe manner. 
Pre-startup Safety Reviews: 
Opal Plant conducts a PSSR on any Plant modification that requires a change in the process safety information. The Opal plant attaches a PSSR anytime an MOCR is origi 
nated.  The purpose of the PSSR is to ensure that safety features, procedures, personnel, and equipment are appropriately prepared for startup before 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 uses a checklist to verify the modification readiness; it involves field verification of the construction and serves a quality assurance function by requiring verifications that accident prevention program requirements are properly implemented. 
Mechanical Integrity: 
Opal 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 employee training, developing written procedures, performs inspection, and testing, correcting i 
dentified deficiencies and applying quality assurance measures.  Collectively, these activities form a system that maintains the Mechanical Integrity of the process. 
Safe Work Practices: 
Opal has established safe work practices to help ensure worker and process safety, examples of these include, control of the entry, presence and exit of support personnel, Lockout/ tagout to ensure isolation of energy sources for equipment undergoing maintenance.  Hot work permits to control spark-producing activities and confined space entry 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 from a system to help ensure that operations and maintenance activities are performed safely. 
The Opal 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 th 
ey are not already familiar with such operations, after successfully completing this training a new operator is paired with an experienced operator to learn process specific duties and tasks.  After operators demonstrate having adequate knowledge to perform the duties and tasks in a safe manner they can work independently, this is measured with test questions and skill demonstration.  In addition, all operators receive refresher training to ensure that their skills and knowledge are maintained at an acceptable level, this refresher training is conducted at least every 3 years, all training is documented for each operator including the means used to verify that the operator understood the training. 
Management of Change: 
Opal plant has a comprehensive system to manage change 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 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.  Process operating limits equipment information as well as procedures we update to incorporate these changes.  In addition, operating and maintenance personnel are provided any necessary training on the change. 
Incident Investigation: 
Opal plant employees along with management promptly investigates all incidents that resulted in, or could have resulted in a fire / explosion, gas release, 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.  The final resolution of each finding 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 lest 5 years so they can be reviewed during future PHA's and PHA revalidation. 
Compliance Audits: 
Opal Plant personal conduct audits on a regular basis to determine whether the provision set out under the RMP and PSM rules are being implemented.  These audits are carried out at least every 3 years, any corrective actions taken is response to the audit teams findings are tracked until they are completed.  The final resolution of each finding is documented and the two most recent audit reports are retained. 
Five-year Accident History: 
Due to our  release prevention policies there has not been a reportable release of any regulated substance. 
Emergency Response Program Information: 
Opal Plant maintains a written emergency response program to protect worker and public safety as well as the environment. The program consi 
sts 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 evacuation plans, accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs.  Employees receive training in these procedures annually to perform emergency response duties.  The program is updated when necessary based on modifications made to the gas plant processes.  
The overall emergency response program for Opal Plant is coordinated with Local Emergency Planning Committee (LEPC) and Local Emergency management.  This coordination includes attending periodic meetings of the committee, which includes local emergency response officials and industry representatives. Opal has 24-hour communications capability with local Kemmerer LEPC, in addition Opal Plant conducts periodic emerge 
ncy drills that involve the LEPC and emergency responses organizations. 
The Opal plant held a Public Awareness day at the plant September 26 1998. The town of Opal and the LEPC, Kemmerer Fire Department, Police, & Sheriffs office and Local emergency responders attended this event. There was a RMP presentation gave at this meeting. The presentation involved letting the public see and here our emergency response for an accidental release. 
Planned changes to improve safety:  
The Opal plant will continue safety by practicing Process safety management and all of its elements. Review and continue
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