Lone Camp Gas Processing Plant - Executive Summary

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                       EXECUTIVE SUMMARY 
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. 
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.  
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. 
Operating Procedures 
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. 
Our emp 
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. 
Mechanical Integrity 
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. 
Incident Investigation 
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 
Release Detection 
1.    Hydrocarbon detection sensors around the facility perimeter. 
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 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. 
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.
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