SUNRAY GAS PLANT - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

Crescendo Resources L.P owns and operates the Sunray Gas Plant.  Crescendo is committed to worker and public safety at the Sunray Gas Plant along with all of it's operations.  This commitment is demonstrated by a strong management involvement and resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation and maintenance of our processes.   Numerous prevention and detection controls have been implemented to prevent a release of regulated substances.  If a release were to occur gas plant trained personnel would respond to control and contain the release according to the Sunray Gas Plant Response Plan, which includes notification of the public. 
The Sunray Gas Plant is located in a rural area of Moore County, near Sunray, Texas.  The plant is a cr 
yogenic natural gas processing plant which was constructed as a new facility with start up in late 1993.  Raw natural gas and condensate are processed into residue natural gas and a Y-grade natural gas liquids stream for sales.  The primary regulated substance contained in processes at the Sunray Gas Plant are flammable mixtures. Hydrogen sulfide is removed from some inlet raw natural gas and converted to elemental sulfur.  Hydrogen sulfide is a regulated toxic substance.  There are no processes at the Sunray Gas Plant that contain hydrogen sulfide above the regulated substance threshold.  None the less, numerous monitoring and control devices are in place to avoid a release of hydrogen sulfide. 
There are five (5) processes at the Sunray Gas Plant that contain regulated flammable substances which are flammable mixtures.  All of the processes are program level I. There are no processes that contain toxic regulated substances above the regulated substances 
threshold.  A worst case scenario (WCS) for flammable substances has been completed for each of the five (5) processes:  No credit for administrative controls or passive mitigation measures was taken into account in determining the scenarios.  The following is a summary of the WCS for each of the five (5) processes. 
Process 1:  W. Moore, Sherman Accumulator Tanks 
A vapor cloud explosion (VCE) involving the full inventory of these tanks containing 464,685 lbs of a flammable mixture, assuming they are 100% liquid full.  The maximum distance to the 1-psi endpoint for this WSC is 0.62 mile. 
Process 2: Ochiltree Inlet, SE Moore Accumulator Tanks  
A vapor cloud explosion (VCE) involving the full inventory of these tanks containing 849,947 lbs of a flammable mixture assuming they are 100% liquid full.  The maximum distance to the 1-psi  endpoint for this WCS is 0.76 mile.  This is the WCS with the furthest endpoint, at the Sunray Gas Plant. 
Process 3: Condensate Sales Tank 
A vapor cloud expl 
osion (VCE) involving the full inventory of the tank containing 145,172 lbs of a flammable mixture assuming it is 100% liquid full.  The maximum distance to the 1-psi endpoint for this WCS is 0.42 mile. 
Process 4: Stabilizer Feed Tanks 
A vapor cloud explosion (VCE) involving the full inventory of the tank containing 481,184 lbs of a flammable mixture assuming it is 100% liquid full.  The maximum distance to the 1-psi endpoint for this WCS is 0.63 mile. 
Process 5:  Process Area 
A vapor cloud explosion (VCE) involving the full inventory of all vessels and piping 3" and greater in the core process area containing 435,634 lbs of a flammable mixture.  The maximum distance to the 1-psi endpoint for this WCS is 0.61 mile. 
The Offsite Consequence Analysis Guidance was used to determine the 1-psi endpoint for each WCS.  There are no offsite impacts within the distance to each flammable endpoint. 
The following is a summary of the Accident Preventio 
n Program in place at the Sunray Gas Plant.  Although processes at the Sunray Gas Plant that are regulated by the Environmental Protection Agency's (EPA's) Risk Management Program (RMP) regulation are Program Level 1, they are also subject to the Occupational Safety and Health Administration's (OSHA's) Process Safety Management (PSM) standard.  This summary addresses each of the OSHA PSM elements and describes the system to implement the Accident Prevention Program. 
Employee Participation 
Crescendo Management requires employees to participate in all facets of process safety management and accident prevention.  Examples of employee participation range from updating and compiling technical documents to participating as a member of a process hazard analysis (PHA) team.  Employees have access to all information created as part of the gas plant accident prevention program.  Specific ways that employees can be involved in the accident prevention program are documented in an employee partici 
pation plan that is maintained at the plant and addresses each accident prevention program element.  The Sunray Gas Plant established a safety committee to promote both process and personal safety.  The committee has members including operations, maintenance, engineering and management. 
Process Safety Information 
The Sunray Gas 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 equipment design basis/configuration information. 
Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs).  For specific process areas, the plant has safety-related limits for specific process parameters (e.g., temperature, level, composition).  The plant ensures that the process is maintained within these limits using process controls an 
d monitoring instruments, highly trained personnel and protective instrument systems (e.g., automated shutdown systems). 
The Sunray Gas Plant also maintains numerous technical documents that provide information about the design and construction of process equipment.  This information includes materials of construction, design pressure and temperature ratings, and electrical rating of equipment.  This information, in combination with 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 Sunray Gas Plant has a program to help ensure that hazards associated with the various processes are identified and controlled.  Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. 
The Sunray Gas Plant  
primarily uses the hazard and operability (HAZOP) analysis technique to perform these evaluations.  HAZOP analysis is recognized as one of the most systematic and thorough hazard evaluation techniques.  These analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise.  This team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and the team makes suggestions for additional prevention and/or mitigation measures when the team believes such measures are necessary. 
The PHA team findings are forwarded to management for resolution.  Implementation of mitigation options in response to PHA findings is based on a relative risk ranking.  This ranking helps ensure that potential accident scenarios assigned the highest risk receive immediate attention.  All approved mitigation options in response to PHA team findings are tracked until they are completed.  The final resolution of 
each finding is documented and retained. 
To help ensure that the process controls and/or process hazards do not eventually deviate significantly from the original design safety features, the plant periodically updates and revalidates the hazard analysis results.  These periodic reviews will be conducted at least every 5 years.  The results and findings from these updates will be documented and retained.  The most recent review was in 1998. 
Operating Procedures 
The Sunray Gas Plant maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations,  
(3) temporary operations (4) emergency shutdown, (5) normal shutdown, and  
(6) initial startup of a new process.  These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators.  These procedures are periodically reviewed. The procedures are kept current and accurate by revising them as necessary to reflect changes 
made through the management of change process. 
In addition, the Sunray Gas Plant provides guidance on how to respond to upper or lower limit exceedances for specific process or equipment parameters.  This information is included in written operating procedures, is readily available to operators in the process unit and for other personnel to use as necessary to safely perform the job tasks. 
To complement the written procedures for process operations, the Sunray Gas 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 they are not already familiar with such operations.  After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks.  After operators demonstrate (e.g., through tests, skills demonstration) having adequate knowledge to perform the duties and tasks in a safe manner on their o 
wn, they can work independently.  In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. All of this training is documented for each operator, including the means used to verify that the operator understood the training. 
The Sunray Gas Plant uses contractors to supplement its workforce during periods of increased maintenance or construction activities.  Because some contractors work on or near process equipment, the gas plant 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 plant personnel of any hazards that they find during their work.  This is accomplished by providing contractors with (1) a  
process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safety work practices prior to their beginning work.  In addition, Crescendo evaluates contractor safety programs and performance during the selection of a contractor.  Plant personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations. 
Pre-startup Safety Reviews (PSSRs) 
The Sunray 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 that safety features, procedures, personnel and equipment are appropriately prepared for startup prior to placing the equipment into service.  This review provides one additional check to make sure construction is in accordance with the design specifications and that all supporting systems are operationally ready.  A PSSR involves field verification of the construction 
and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. 
Mechanical Integrity 
The Sunray Gas 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: (1) conducting training, (2) developing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures.  In combination, these activities form a system that maintains the mechanical integrity of the process. 
Maintenance personnel receive training on (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 ma 
nner.  Written procedures help ensure that work is performed in a consistent manner and provide a basis for training.  Inspections and tests are performed to help ensure that equipment functions as intended and to verify 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 possible), or a management of change team will review the use of the equipment and determine what actions are necessary to ensure the safe operation of the equipment. 
Another integral part of the mechanical integrity program is quality assurance.  The Sunray Gas Plant incorporates quality assurance measures into equipment purchases and repairs.  This helps ensure that new equipment is suitable for its intended use and that proper materials and spare parts are used when repairs are made. 
Safe Work Practices 
The Sunray Gas Plant has long-standing safe wor 
k practices in place to help ensure work and process safety.  Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of flammable 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 ensure 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 ensure that operations and maintenance activities are performed. 
Management of Change 
The Sunray 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) ensure 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 these changes.  In addition, operating and maintenance personnel are provided any necessary training on the change. 
Incident Investigation 
The Sunray Gas Plant will promptly investigate 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 investigation team documents its findings, develops recommendations to prevent a recurrence, and  
forwards these results to plant management for resolution.  Corrective actions taken in response to the investigation team's findings and recommendations will be tracked until they are complete.  The final resolution of each finding and recommendation will be documented, and the investigation results reviewed with employees (including contractors) who could be affected by the findings.  Incident investigation reports will be retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations. 
Compliance Audits 
To help ensure that the accident prevention program is functioning properly, the Sunray Gas Plant periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented.   
In addition to the above PSM elements, the Sunray Gas Plant has additional programs that support accident prevention.  A summary of these programs are as follows: 
Near Miss/Hazard Identification 
Employees are encouraged to participated in this program which identifies through a written procedure observed near miss incidents, unsafe acts and/or hazards at the Sunray Gas Plant.  These near miss/hazard identifications are reviewed for actions and trends, categorized and resolved as required. 
Tailgate Safety Meetings 
These informal meetings take place just prior to the start of a job by contractors or employees at the Sunray Gas Plant.  Safety concerns or potential hazards that may be encountered during the job are identified and discussed. 
The processes at the Sunray 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 regulated substances in the facility. 
Universal Prevention Activities 
The accident prevention program summarized previously is applied to all RMP-covered processes at the Sunray Gas Plant. 
 Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors. 
Specialized Safety Features 
The Sunray 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 (mitigate) a release.  The following types of safety features are used in the covered processes: 
Release Detection 
1. Hydrocarbon detectors with alarms/shutdowns 
2. Hydrogen sulfide detectors with alarms 
3. Vibration shutdowns 
4. Fire eyes/shutdowns. 
5. Fire detection/alarm. 
Release Containment/Control 
1. Process relief valves that discharge to a flare to capture and incinerate episodic releases 
2. Valves to permit isolation of the process (manual or automated) 
3. Automated shutdown systems for specific process parameters (e.g., high temperature) 
4. Curbing or diking to contain liquid releases 
5. Redundant equipment and instrumentation (e.g., un 
interruptible power supply for process control system) 
6. Atmospheric relief devices 
7. Fusible plugs 
Release Mitigation 
1. Trained emergency response personnel 
2. Personal protective equipment (e.g., chemical protective clothing, self-contained breathing apparatus, SCBA) 
3. Fire extinguishers 
The Sunray Gas Plant has an excellent record of accident prevention.  There have been no applicable events that have occurred in the 5 year period prior to the submittal date of this Risk Management Plan. 
The Sunray Gas Plant maintains a written emergency response plan, which is in place to protect worker and public safety as well as the environment.  The program consists 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 aspects of emergency response, including proper first aid and medica 
l treatment, 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 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 plant processes or other Sunray Gas Plant facilities.  The emergency response program changes are administered through the Management of Change (MOC) process, which includes informing and/or training affected personnel in the changes. 
The overall emergency response program for the Sunray Gas Plant and this Risk Management Plan have been coordinated with the Moore County, Texas, Local Emergency Planning Committee (LEPC).  The S 
unray Gas Plant has around-the-clock communications capability with appropriate emergency response organizations.  This provides a means of notifying the public of an incident, if necessary.  The Sunray Gas Plant conducts periodic emergency drills and provides annual refresher training to emergency responders regarding the hazards of regulated substances in the plant. 
The Sunray Gas Plant is committed to continuous improvement in safety.  The following types of changes are planned over the next few years in response to Process Hazard Analysis (PHA) and/or incident investigations: 
7 Install larger relief valves as needed for process changes.
Click to return to beginning