Sunray Gas Plant
Sunray, TX 79086
San Antonio, TX 78258 -3941
Person responsible for RMP implementation:
Lake Charles, LA 70605
Latest RMP Submission:
2. Toxics: Worst-case
3. Toxics: Alternative release
4. Flammables: Worst-case
Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:
- Names of the chemicals in the Off-Site Consequence Analysis
- Amount of chemical released
- Rate of chemical release
- Radius of affected area
- Vulnerable areas affected
- Count of affected population
- Maps or other optionally provided supplementary material
Instructions on how to make an EPA appointment can be found here.
- Blast walls
5. Flammables: Alternative release
6. Five-year accident history
- Flammable Mixture
- Internal corrosion
- Improved/upgraded equipment
- Revised maintenance
7. Prevention: Program level 3
8. Prevention Program level 2
9. Emergency response
EXECUTIVE SUMMARY SUNRAY GAS PLANT
The Sunray 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, facility trained personnel will respond to control and contain the release.
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES
The Sunray Gas Plant is located in a rural area of Moore County, near Sunray, Texas. The plant is a cryogenic natural gas processing plant, which was constructed as a new facility with startup 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. There is one process at the Sunray Gas Plant that contains regulated flammable mixtures. This process is Natural Gas Liquids extraction. This process is a program level 1. 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. Nonetheless, numerous monitoring and control devices are in place to avoid a release of hydrogen sulfide.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM
The following is a summary of the accident prevention program in place for the process at the facility. Because the process at the facility that are regulated by the Environmental Protection Agency's (EPA's) risk management program (RMP) regulation 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 management system in place to implement the accident prevention program.
The Sunray Gas Plant encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team. Employees have access to all information created as part of the facility accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that is maintained at the facility.
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 specific chemical inventories, and equipment design basis/configuration information. The reference documents are maintained on file at the facility to provide open access.
Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address known corrosion concerns and any known hazards associated with the inadvertent mixing of chemicals. For the process, the facility has documented safety-related limits for specific process parameters (e.g., temperature, level, composition) in key process parameter documents. The facility ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems).
The facility 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 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 Sunray Gas Plant has a comprehensive program to help ensure that hazards associated with the process 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. The 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 local and corporate management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned that 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 haz
ards do not eventually deviate significantly from the original design safety features, the facility periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operative. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to management for consideration, and the final resolution of the findings is documented and retained.
The Sunray Gas Plant maintains written procedures that address various modes of 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 and annually certified as current and accurate. 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 maintains key process parameter documents that provide guidance on how to respond to upper or lower limit accedences for specific process or equipment parameters. This information, along with written operating procedures, is readily available to operators in the process unit and for other personnel to use as necessary to safely perform their 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 facility 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-spec
ific 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 own, 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. This refresher training is conduced at least every 3 years. 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 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 event of an emergency, (5) understand and follow site safety rules, and (6) inform facility 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) safe work practices prior to their beginning work. In addition, the Sunray Gas Plant evaluates contractor safety programs and performance during the selection of a contractor. Facility personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations.
Pre-startup Safety Reviews (PSSR's)
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 p
lacing 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. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction and serves as a quality assurance function by requiring that accident prevention program requirements are properly implemented.
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 manner. Job plans/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 integr
ity 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 work practices in place to help ensure worker and process safety. Examples of these include, (1) control of the entry/presence/exit of support personnel, (2) a lockout/tag out procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous 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 safely.
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 to (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.
The Sunray Gas Plant promptly investigates all incidents that resulted in, or reasonably co
uld have resulted in, a fire/explosion, 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 facility management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendation 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 least 5 years so that the reports can be reviewed during PHA's and PHA revalidations.
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. Compliance audits are conducted at least every 3 years. Both hourly and staff personnel participate as audit team members. The audit team develops findings that are forwarded to facility management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained.
CHEMICAL-SPECIFIC PREVENTION STEPS
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 safely 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 al
l RMP-covered processes at the Sunray Gas Plant. Collectively, these prevention program activities prevent or mitigate 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 process:
1. Hydrocarbon detectors with alarms
2. Hydrogen Sulfide detectors with alarms
1. Process relief valves that discharge to a flare to capture and incinerate episodic releases.
2. Valves to permit isolation of the process (manual and 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., uninterruptible power supply for process control system).
FIVE-YEAR ACCIDENT HISTORY
The Sunray Gas Plant experienced an incident on September 16, 2017. A brief summary is listed below and all information pertaining to the incident is in Section
6, Five Year Accident Summary.
Operator A, Operator B, and Operator C were on shift at the Sunray Gas Plant. Operator A and Operator C were in the Control Room, Operator B was in the plant near the Reverse Osmosis system. All three Operators heard what was described as a "loud noise" that was accompanied by what seemed to be a large vapor cloud. According to Operator statements the vapor cloud seemed to be near the Amine Contactor(s). Within seconds, from all indications, the vapor cloud found an ignition source at the Hot Oil Heater. The vapor cloud ignited and a fire proceeded. Operator A immediately noticed that the DCS (Distributed Control System) was inoperable, therefore Operator A initiated the manual ESD (Emergency Sh
ut Down) in the control room before he proceeded to evacuate to the parking lot muster area. Operator C also evacuated with Operator A. Operator B had begun his evacuation as soon as he saw the vapor cloud, through the south emergency exit gate. Operator B made contact with Operator A and Operator C and proceeded to walk around the plant and muster in the parking lot.
EMERGENCY RESPONSE PROGRAM INFORMATION
The Sunray Gas Plant maintains a written emergency response program, 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 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, and post incident cleanup and decontamination requirements. In addition, the facility 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 facility processes. The emergency response program changes are administered through the MOC process, which includes informing and/or training affected personnel in the changes. Periodic drills or tabletop exercises are conducted to test the response plan.
The overall emergency response program for the Sunray Gas Plant is communicated to the Moore County Local Emergency Planning Committee (LEPC). The Sunray Gas Plant has around-the-clock communications capability with appropriate LEPC officia
ls and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident.
PLANNED CHANGES TO IMPROVE SAFETY
The Sunray Gas Plant resolves all findings from PHA's, some of which result in modifications to the process.
All units maintain a common operating and maintenance philosophy using PHA's, MOC's, etc. No major changes are currently planned.