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Cowtown Gas Plant

Parent Companies:
Cowtown Gas Processing Partners L.P.
EPA Facility ID:
Other ID:
Facility DUNS:
Parent Company DUNS:


2400 County Road 326
Cleburne, TX 76033
Lat / Long:
32.335, -97.681 (Get map)
GPS - Unspecified
Plant Entrance (General)
Horizonal accuracy:
10 m
Horizontal reference datum:
World Geodetic System of 1984
Source map scale:


Cowtown Gas Processing Partners L.P
(817) 709-7015
801 Cherry St.
Suite 3800 - Unit 20
Fort Worth, TX 76102
Foreign Address:

Person responsible for RMP implementation:

Jayson Treadaway
Director of Operations

Emergency contact:

Vic Connor
Plant Manager
(817) 709-7015
24-hour phone:
(817) 339-5493
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
Facility (or company) URL:


Local Emergency Planning Committee:
Hood County LEPC
Full-Time Equivalent Employees:
Covered by OSHA PSM:
EPCRA section 302:
CAA Title Air Operating Permit:
CAA Permit ID#:
OSHA Star/Merit Ranking
Last Safety Inspection Date:
Sept. 8, 2013
Inspecting Agency:
Using Predictive Filing:


CBI claimed:
Program Level:
Natural Gas Liquid Extraction (211112)
Chemical name
Quantity (lbs.)
Public OCA Chemical
Public OCA Chemical
Public OCA Chemical

RMP Preparer:

Garrett Wimberley
6221 Chapel Hill Blvd.
Suite 300
Plano, TX 75093
Foreign Address:

(469) 467-8296

Latest RMP Submission:

July 21, 2015
Voluntary update (not described by any of the above reasons)


Effective Date:
Other Reason:

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:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Facility)
CBI claimed:
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
  • berms
not considered:
  • Blast walls

5. Flammables: Alternative release

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:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Facility)
CBI claimed:
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
  • berms
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Excess flow valve

6. Five-year accident history

May 25, 2007 at 18:00
Natural Gas Liquid Extraction (211112)
1 minutes
Chemicals involved:
  • Methane
Release events:
Weather conditions at time of event
Wind speed:
None ℉
Atmospheric stability:
Precipitation present:
Unknown weather conditions:
On-site impacts
Deaths of employees or contractors:
Deaths of public responders:
Deaths of public:
Injuries of employees or contractors:
Injuries of public responders:
Injuries of public:
Property damage:
Known off-site impacts
Medicals treatments:
Property damage:
Environmental damage:
  • None
Initiating event:
Contributing factors:
  • gas accumulated and ignited while lighting gas fired heater
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Administrative PSM Process Controls Implimented

7. Prevention: Program level 3

Facility, Natural Gas Liquid Extraction (211112)
Prevention Program ID:
Safety Review Date
Feb. 1, 2014, since latest RMP submission
PHA Update Date
Oct. 30, 2010, since latest RMP submission
PHA Techniques
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Equipment failure
  • Floods
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Grounding Equipment
  • Excess Flow Device
Mitigation Systems
  • Dikes
Monitoring Systems
  • Process Area
Changes since PHA
  • Process Controls
Training Type
  • None
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 2, 2014, since latest RMP submission
Training Review Date
Sept. 15, 2013, since latest RMP submission
Maintenance Review Date
July 1, 2013, since latest RMP submission
Maintenance Inspection Date
Feb. 1, 2014, since latest RMP submission
Equipment Tested
Management of Change Most Recent Date
April 15, 2014
Management of Change Review Date
May 1, 2013
Pre-startup Review Date
April 15, 2014
Compliance Audit Date
Oct. 22, 2012
Compliance Audit Change Completion Date
Dec. 30, 2014
Incident Investigation Date
April 16, 2014
Incident Invest. Change Completion Date
April 30, 2014
Participation Plan Review Date
Oct. 22, 2012
Hot Work Review Date
Oct. 22, 2012
Contractor Safety Review Date
Oct. 22, 2012, since latest RMP submission
Contractor Safety Eval. Date
Oct. 22, 2012, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Facility Own Response Plan:
Specific Facility Response Plan:
Inform. Procedures in Response Plan:
Emergency Care in Response Plan:
Plan Review Date:
Response Training Date:
Feb. 23, 2014
Local Response Agency:
Local Response Agency Phone:
(817) 579-3335
Subject To - OSHA EAP:
Subject To - CWA:
Subject To - RCRA:
Subject To - OPA:
Subject To - State EPCRA:
Subject To - Other:

Executive Summary

Executive Summary - Cowtown Gas Plant

Cowtown Gas Processing Partners L.P., owner and operator of the Cowtown 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. Cowtown's 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

Natural gas is gathered from wells in the surrounding fields and sent to Cowtown for processing prior to being sold for domestic consumption. This gas contains impurities in the form of carbon dioxide (CO2) and water. These impurities must be brought into specification before residue companies will purchase this gas. Cowtown inlet gas contains enough natural gas liquids that extraction is desirable.

Two Cryogenic plants are in place to remove liquids prior to sales of residue gas. The plants together are capable of handling 225 MMSCFD.

Gas flow into this facility is at low pressure; approximately 90 psig. Processing and sales line pressures range from 1000 to 1050 psig; therefore this gas requires boost compression. Cowtown has several gas fired engine driven compression units that boost gas pressure up to processing pressure. Gas is treated with triethylene glycol (TEG) and molecular sieve beds to remove any water that may be entrained in the gas. Cryogenic processing at very low temperatures removes virtually all of the ethane and heavier components.

Cowtown is designed to remove CO2 from liquid product with a solution of amine and water. Once these liquids are sweetened, product is sweet and any entrained water is removed using coalescer type filters. The amine unit operates in a conti
nuous loop treating, regenerating, cooling and back to treating. This system is highly automated and operates with minimal interruptions.

Residue gas, after liquid removal, is at 250 psig. Gas fired compression units' compress this gas up to sales line pressure and it is sold at the tailgate of the plant.

A dry gas system is in place to bypass Cryogenic Processing and send dry inlet gas directly to sales.

Auxiliary equipment consists of glycol, amine, lube oil, heat medium oil, methanol, antifreeze, and drain system storage. Cowtown Gas Plant has air compression systems, instrument air drying equipment, and a heat medium system. This facility is also equipped with a control room, various motor control centers, vapor recovery systems, and finally, a flare system for plant blow down/vent systems.

The processes at the plant are interconnected by piping and fit the EPA's definition of a stationary source in 40 CFR part 68. The facility contains three sources of regulated substances held over their respective threshold quantities; propane refrigerant, plant gas consisting of mostly methane, and condensate.

General Accident Release Prevention and Program Information

The following is a summary of the accident prevention program in place for the process at the facility. Because the processes at the Cowtown Gas Plant 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.

Employee Participation

Cowtown Gas Processing Partners L.P. 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 in
formation 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

Cowtown Gas Processing Partners L.P. 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 Cowtown 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 written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluatin
g proposed process and facility changes to ensure that safety features in the process are not compromised.

Process Hazard Analysis (PHA)

Cowtown Gas Processing Partners L.P. 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.

Cowtown Gas Processing Partners L.P. primarily used the hazard and operability (HAZOP) analysis technique to perform this evaluation. 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 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 Cowtown Gas Plant periodically updates and revalidates the hazard analysis results. These periodic reviews are conducted when major changes occur at the facility. The results and findings from these updates are documented and retained. Once again, the team findings ar
e forwarded to management for consideration, and the final resolution of the findings is documented and retained.

Operating Procedures

Cowtown 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 Cowtown Gas Plant maintains key process parameter documents that provide guidance on how to respond to upper or lower limit exceedence 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 Cowtown 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-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 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 i
s conducted on an as needed basis. All of this training is documented for each operator, including the means used to verify that the operator understood the training.


The Cowtown 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, Cowtown Gas Processing Partners L.P. has a program in place to evaluate contractor safety programs and performance. Facility personnel periodically monitor contractor performance to ensure that contractors are fulfilling their safety obligations.

Pre-startup Safety Reviews (PSSRs)

Cowtown Gas Processing Partners L.P. 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. The PSSR 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.

Mechanical Integrity

Cowtown Gas Processing Partners L.P. 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 integrity program is quality assurance. The Cowtown 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

Cowtown Gas Processing Partners L.P. 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/tagout 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

Cowtown Gas Processing Partners L.P. 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.

Incident Investigation

Cowtown Gas Processing Partners L.P. promptly investigates all incidents that resulted in, or reasonably could 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 PHAs and PHA revalidations.

Compliance Audits

To help ensure that the accident prevention program is functioning properly, Cowtown Gas Processing Partners L.P. periodically conducts an audit to determine whether the procedures and practices required by the accident prevention program are being implemented. Compliance audits are conducted on a periodic basis. 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 Cowtown Gas Plant have hazards that must be managed to ensure continued safe operation. The following is a description of existing safety features applicable to the 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 Cowtown 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 Cowtown 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:

Release Detection

1. Tanks are gauged

2. Tanks/vessels are equipped with level and pressure sensors

Release Containment/Control

1. Berms around condensate tanks

2. Process relief valves venting vapors to the atmosphere to prevent vessels from rupturing

3. Process relief valves that discharge to a flare to capture and incinerate episodic releases

4. Valves to permit isolation of the process (manual and automated)

5. Automated shutdown systems for specific process parameters (e.g., high temperature)

6. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control system)

Release Mitigation

1. Personal protective equipment

2. SPCC Plan

Emergency Response Program Information

The Cowtown 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 the 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 mad
e to facility processes. 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. Periodic drills or tabletop exercises are conducted to test the response plan.

The overall emergency response program for the Cowtown Gas Plant is coordinated with the Hood County Local Emergency Planning Committee (LEPC). The Hood County LPEC contact is Ray Wilson (817/579-3335). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The Cowtown Gas Plant has around-the-clock communications capability. Cowtown Gas Processing Partners L.P. operators are automatically called in the event of a process upset. The operator will then call the fire department. This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. In addition to periodic LEPC meetings, the Cowtown Gas Processing Partners L.P. conducts periodic emergency drills that involve emergency response organizations, and the Cowtown Gas Plant provides refresher training to local emergency responders every two (2) years regarding the hazards of regulated substances in the facility.

Five - Year Accident History

According to Crestwood Personnel, Cowtown Gas Plant has had no accidents in the last five years.

Planned Changes to Improve Safety

The Cowtown Gas Plant resolves all findings from PHAs, some of which result in modifications to the process. The most Recent PHA was conducted in October 2010. The following types of changes are planned in response to PHA, safety audit, and incident investigation findings:

Planned Change

* All recommendations from the most recent PHA have been completed and documented.