Lone Camp Gas Processing Plant - Executive Summary
LONE CAMP RISK MANAGEMENT PLAN |
The Lone Camp 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 Lone Camp gas plant, located 3 miles west of Lone Camp on Highway 3137 (across from the
power plant on Lake Palo Pinto) in Palo Pinto 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, b
utane, ethylene glycol and diethanolamine.
OFFSITE CONSEQUENCE ANALYSIS RESULTS
There are no toxic chemicals stored at the Lone Camp 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 sce
nario would be approximately 0.42 miles, based on EPA
A more probable release scenario would involve the release of natural gas condensate from a
transfer line during unloading. 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 Lone Camp 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 Lone Camp 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 Lone Camp 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 haz
ards of the process, as well as accident prevention and
mitigation measures, and makes 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 Lone Camp gas plant periodically updates and revalidates the hazard analysis
results. These periodic reviews will be conducted at least every 5 years.
The Lone Camp 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.
loyees at the Lone Camp plant have an average experience of over 10 years. This level of
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 Lone Camp 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 Lone Camp gas plant has well-established practices and procedures to maintain our
equipment in a safe opera
ting condition. The basic aspects of this program include inspections,
tests and corrections 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 equipment.
Safe Work Practices
The Lone Camp 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 C
The Lone Camp gas plant has a comprehensive system to manage changes to all covered
processes. 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 Lone Camp 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 Lone Camp 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 specific regulated substances in the facility.
The Lone Camp 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 around the facility perimeter.
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 plants, the control of fire is more dependent on restricting
sources of fuel than on putting out the fire.
The Lone Camp plant has not had an incident over the past five years which has impacted off-site
people or structures.
EMERGENCY RESPONSE PROGRAM INFORMATION
The Lone Camp 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 Lone Camp gas plant
has procedures that address maintenance, inspection and
testing of emergency response equipment, as well as 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 Lone Camp 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 facility recently had a simulated emergency drill with the local
emergency planning coordinator of Palo Pinto County and local emergency response agencies.
Not only did we learn more about their capability, but they became more familiar with our
ns and how to respond in case of an incident.
The Lone Camp 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 facility and the emergency
responders is an integral part of our operations.