Huckabay Gas Plant - Executive Summary

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                       EXECUTIVE SUMMARY 
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. 
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. 
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. 
Operating Procedures 
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. 
Mechanical Integrity 
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. 
Incident Investigation 
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. 
The processes at the Huckabay gas plant have hazards that must be managed to e 
nsure continued 
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 
Release Detection 
1.    Hydrocarbon detection sensors within the facility. 
Release Containment/Control 
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. 
Release Mitigation 
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. 
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.
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