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Exxon Company, U.S.A. Tom O'Connor Gas Plant


Facility #1 : Exxon Company, U.S.A. Tom O'Co

Basic Facility Info facility_Basic_Facility_Info help link help link  
Facility ID100000082554
Deregistered (Yes/No)Yes
Facility NameExxon Company, U.S.A. Tom O'Connor Gas Plant
Street Address Line 17 miles N. of Refugio on Hwy 77
Street Address Line 22.5 miles E. of Hwy 77
Zip Code78377
CountyRefugio County
113th Congressional DistrictTX27: Texas 27
Owner or Operator NameExxon Company, U.S.A.
Parent CompanyExxon Corporation
Number of RMP Submissions1

Most Recent Submission Info facility_Most_Recent_Submission_Info help link help link  
RMP ID11028
Submission Typefirst submission for facility
Submission Date06/21/1999
Deregistration Date02/07/2000
Deregistration Effective Date02/01/2000
Process Toxic Amount Total (lbs)0
Process Flammable Amount Total (lbs)240,000
Process Amount Total (lbs)240,000
Number of Potential Offsite Consequence Processes0
Potential Offsite Consequence Toxic Amount Total (lbs)0
Potential Offsite Consequence Flammable Amount Total (lbs)0
Potential Offsite Consequence Amount Total (lbs)0
All Process NAICS211112
Exec Summary Submission Date06/21/1999

Executive Summary facility_Executive_Summary help link help link (Facility #1 : Exxon Company, U.S.A. Tom O'Co, executive summary: all)

Executive Summary
Accidental Release Prevention and Response Policies
Exxon modified its safety programs in 1992 by implementing structured safety management systems entitled Operations Integrity Management System (OIMS). In 1997, Lloyd's Register Quality Assurance reviewed OIMS and evaluated it against the international standard for Environmental Management Systems (ISO 14001) to determine if OIMS meets the requirements of ISO 14001. After an extensive review which included a number of facility audits, they concluded that the ""environmental components of OIMS are consistent with the intent and meet the requirements of the ISO 14001 Environmental Management Systems Standard."" They went on to say, ""We further believe Exxon to be among the industry leaders in the extent to which environmental management considerations have been integrated into its ongoing business processes."

The Tom O'Connor Gas Plant has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention (e.g., training of personnel, considering safety in the design, installation, operation, and maintenance of the facility, etc.). Our approach is to implement reasonable controls to prevent foreseeable releases of regulated substances as well as other substances. If a release does occur, our trained personnel will take steps to control and contain it until local emergency response organizations arrive. Additional details are included in the other sections of this RMPlan.

Description of the Stationary Source and Regulated Substances
This plant, located approximately 7.5 miles northeast of Refugio, Texas, consists of one Program Level 1 process which utilizes several operations (e.g., separation, dehydration, compression, cryogenic) to produce petroleum products (e.g., natural gas liquid mixture, methane) from a naturally occurring hydrocarbon gas mixture. This plant could contain up to 240,000 pounds of regulated flammables (e.g., mixture
containing methane, ethane, propane, butane, iso-butane, pentane, and iso-pentane), but no regulated toxic inventories in excess of the threshold quantities established in the regulation. All transportation of regulated flammables into and out of the facility is handled via pipelines. This plant is surrounded by ranch land.

Offsite Consequence Analysis Results
Worst Case Scenario (WCS) -
The flammable WCS, as defined in the regulation, is a release of a mixture of natural gas liquids resulting in a vapor cloud explosion (VCE) involving the maximum inventory of the largest vessel. Even though the normal operating inventory for this equipment is significantly less than the maximum capacity and this equipment is protected by high level alarms/shutdowns, pressure relief valves, periodic inspections, and routine monitoring by operating personnel, this maximum inventory must be assumed to be released in 10 minutes and ignited at the point of release. No mitigation measures were taken into account in evaluating this WCS. The WCS could have some off-site impacts, but the impact area does not include any public or environmental receptors.

General Accidental Release Prevention Program
The following is a summary of the accident prevention program in place at this plant. Because processes at this plant regulated by EPA's Risk Management Program (RMP) regulation are also subject to (and in compliance with) 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 -
This plant provides for and encourages employees to participate in all aspects of process safety management and accident prevention. Examples of employee participation range from updating/compiling technical information and drawings to participating on process hazard analysis (PHA) or incident investigation teams. Employees have access to all infor
mation related to the accident prevention program. Specific ways that employees can be involved in the accident prevention program are detailed in an Employee Participation Plan that is maintained at the plant and addresses each program element. In addition, this plant has other initiatives that address process and employee safety issues (e.g., hazard reporting/resolution process and numerous safety meetings [daily, monthly, pre-job], etc.).

Process Safety Information (PSI) -
This plant keeps a variety of technical documents that are used to help maintain safe operation of the facility. These documents address chemical properties and associated hazards, safe operating limits for key process parameters, specific chemical inventories, and equipment design basis/configuration information. The OIMS contact at this plant is responsible for coordinating the PSI updates.

Chemical-specific information (including exposure hazards, emergency response, and exposure treatment considerations) is provided in material safety data sheets. For specific process areas, this plant has documented safety-related operating limits for process parameters (e.g., temperature, pressure, level). This plant ensures processes are maintained within these limits using process controls/monitoring equipment, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems, pressure relief valves).

This plant also maintains numerous technical documents that provide information about the design and construction of the process equipment. This information includes the materials of construction, design pressure, temperature ratings, and electrical rating of equipment. This information, in combination with written procedures and trained personnel, provides a basis for inspection/maintenance activities and the evaluation of proposed process or facility changes.

Process Hazard Analysis (PHA) -
This plant has a comprehensive program to help ensure hazards associated
with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure adequate controls are in place to manage these hazards.

This plant primarily uses the Hazard and Operability (HAZOP) study analysis technique to perform these evaluations. This technique is recognized by OSHA as an acceptable hazard evaluation technique for PSM-covered processes. The analyses are conducted using a team of plant operating/maintenance personnel and facility engineers, and technical consultants (as necessary). This team identifies and evaluates hazards of the processes as well as the accident prevention and mitigation measures.

The PHA team findings are forwarded to management to coordinate further evaluation and resolution. This process involves field level business teams, which include engineering personnel, operations personnel, and management. Operating personnel are also involved in the evaluation of resolution options. Implementation of the resolutions is prioritized for accomplishment based on a relative risk. All resolution plans are tracked until completed. The final resolution of each finding is documented and retained.

To help ensure the process controls and/or hazards do not eventually deviate significantly from the original design, this plant updates and revalidates the process hazard analysis at least every 5 years. The results of these updates are also documented and retained. Similarly, the team's findings are forwarded to management to coordinate further evaluation and resolution, and the final resolution of findings are documented and retained.

Operating Procedures -
This plant maintains written procedures that address the various modes of process operations (e.g., startup, normal, temporary, emergency shutdown, normal shutdown, cold startup) and provide guidance on how to respond to upper/lower limit exceedances for specific equipment or process parameters. Procedures
are readily available to operators and other personnel to use as necessary to safely perform their job tasks. These procedures provide a consistent basis for training new operators and are annually reviewed and certified as current/accurate. Procedures are maintained current/accurate by revising them as necessary to reflect changes made through the management of change process.

Training -
To complement the written operating procedures, this plant has implemented a comprehensive training program for all employees involved in operating process equipment. New employees receive basic training in plant operations (e.g., process overview, applicable procedure reviews, etc.). New operators are then paired with experienced operators (i.e., subject matter experts) to learn process-specific duties and tasks. After the new operators demonstrate (e.g., hands-on skills demonstration) that they have adequate knowledge to perform the duties and tasks in a safe manner on their own, they are certified and allowed to work independently. In addition, all personnel who operate process equipment receive refresher training at least every 3 years on the applicable procedures to help ensure their skills and knowledge are maintained at an acceptable level. This training and the means used to verify that the employee understood the training is documented for each employee.

Contractors -
This plant uses contractors to supplement its workforce during periods of increased maintenance or construction activity. Because some contractors work on or near process equipment, this plant has procedures in place to help ensure contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in the workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow safety rules, and (6) inform plant personnel of any hazards they find during their work. This is accomplished by providing contracto
rs an orientation prior to their working in the plant, which includes (1) process overview, (2) information about safety and health hazards, (3) applicable emergency action plan provisions, and (4) information on safe work practices. Also, a job safety analysis is reviewed/updated or developed by the contractors (with plant personnel assistance as needed) prior to each maintenance/construction job.

Plant personnel routinely monitor contractor job performance to help ensure they are fulfilling their safety obligations. Contractor safety programs/performance are evaluated during the initial selection process, and the plant supervisor conducts periodic evaluations of safety performance.

Pre-Startup Safety Reviews (PSSR) -
This plant conducts a PSSR for any modification that requires a change in the process safety information. The purpose of the PSSR is to ensure 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 that construction is in accordance with the design specifications and all supporting systems are operationally ready. A PSSR involves field verification of the construction and serves a quality function by verifying that the requirements of this accident prevention program are properly implemented.

Mechanical Integrity (MI) -
This plant has well-established practices and procedures to maintain pressure vessels, piping systems, relief/vent systems, controls, pumps, compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of this MI program include (1) training, (2) written procedures, (3) inspections/tests, (4)correction of identified deficiencies, and (5) quality assurance measures. In combination, these activities form a system that maintains the mechanical integrity of the process. Maintenance personnel receive training on the (1) process, (2) safety and health hazards,
(3) applicable maintenance procedures, (4) emergency procedures, and (5) applicable safe work practices to help ensure they perform their jobs in a safe manner. Written procedures and equipment manuals help ensure work is performed in a consistent manner and provide a basis for training.

Inspections/tests and preventive maintenance are performed on a scheduled basis to help ensure equipment and safety devices function as intended and to verify that equipment is within acceptable limits (e.g., adequate wall thickness, etc.). If a deficiency is identified, employees correct the deficiency before placing the equipment back into service or a group of experts (e.g., engineers, etc.) review the use of the equipment and determine what actions are necessary to ensure safe operation of the equipment until the deficiency can be corrected.

Another integral part of the MI program is quality assurance. This plant incorporates quality assurance measures into equipment purchases and repairs to help ensure new equipment is suitable for its intended use and proper materials/spare parts are used for repairs.

Hot Work and Other Safe Work Practices -
This plant has long-standing safe work practices in place to help ensure worker and process safety. These include orientations for visitors/contractors, control of the entry/presence/exit of support personnel, energy isolation for equipment being worked on, procedures for the safe removal of hazardous materials before opening of process piping/equipment, hot work permit/procedure to safely manage spark-producing activities, vehicle entry into process area, confined space entry permit/procedure to help ensure precautions are taken before entering confined spaces, job safety analyses to identify and mitigate hazards associated with maintenance tasks). These practices, along with related procedures and training of affected personnel, form a system to help ensure operations and maintenance activities are performed safely.

t of Change (MOC) -
This plant has a comprehensive system to manage changes. This system requires that changes to 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 ensure adequate controls are in place to manage any new hazards and to verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, equipment information, drawings, and procedures are updated for these changes. In addition, operating and maintenance personnel are provided any necessary training related to the change.

Incident Investigation -
This plant promptly investigates all incidents that resulted in (or could have reasonably resulted in) a fire, explosion, release, major equipment/property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations, and forwards these results to management for resolution. Corrective actions taken in response to the investigation team's findings are tracked until completed. The final resolution of each finding is documented, and investigation results are reviewed with all employees (including contractors) who could be affected. Incident investigation reports are retained for at least 5 years so that reports can be reviewed during the next PHA revalidation.

Compliance Audits -
To help ensure the accident prevention program is functioning properly, an audit is conducted at this plant at least once every 3 years to determine whether the program's procedures and practices are being implemented. An audit team consisting of both plant and technical personnel evaluate the implementation/effectiveness of the processes in this ac
cident prevention program and develop findings that are documented and forwarded to management to coordinate resolution. Corrective actions are taken in response to the audit team's findings, and resolution status is tracked until actions are completed. The final resolution of each finding is documented and the two most recent audit reports are retained.

Chemical-Specific Prevention Steps
The processes at this plant have hazards that are managed to help ensure continued safe operation. The following is a description of existing safety features applicable to the prevention of accidental releases of the specific regulated substances (i.e., flammables).

Universal Prevention Activities -
The accident prevention program summarized previously is applied to the RMP-covered process at this plant. These prevention program activities help prevent potential accident scenarios that could be caused by equipment failures and human errors.

Specialized Features -
This plant has safety features on many units to (1) quickly detect a release, (2) contain/control a release, and (3) reduce/mitigate the consequences of a release. The following types of safety features are used:

Release Detection ...
- Hydrocarbon gas detectors/alarms in control room building

Release Containment/Control ...
- Pressure/thermal relief valves that discharge either to atmosphere or into a flare system for incineration
- Manual/automatic isolation valves
- Automated shutdown systems for specific process parameter (e.g., pressure, high level, etc.)
- Redundant equipment and instrumentation (e.g., dual relief valves)

Release Mitigation ...
- Fire extinguishing equipment (e.g., portable fire extinguishers)
- Personal protective equipment (e.g., self-contained breathing apparatus)
- Trained personnel

Five Year Accident History
This plant has had an excellent record for accident prevention over the past 5 years. In fact, there have not been any incidents, as defined in the regulation.

Response Program Information
This plant maintains an emergency action program to protect the workers, public, and environment. The program consists of procedures for handling releases of regulated substances (i.e., flammables) including the possibility of fires or explosions. The procedures address facility/equipment isolation and shutdown, initial first-aid and medical treatment for exposures (i.e., Material Safety Data Sheets information), evacuation plans for this plant, accounting for plant personnel after an evacuation, and notification of local emergency response agencies. In addition, this plant has procedures that address the maintenance, inspection, and testing of emergency equipment and alarms. Plant personnel receive training in these procedures as necessary to perform their specific duties.

This emergency action program is reviewed annually and updated when necessary. Changes required because of modifications to the facilities or equipment are administered through the Management of Change process, which includes informing and/or training affected personnel.

The overall emergency response program for this plant is coordinated with the Refugio County Local Emergency Planning Committee (LEPC), Refugio Volunteer Fire Department, Refugio County Sheriff's Department, and the local ambulance services. This plant has around-the-clock communications capability with these emergency response organizations, and these organizations are responsible (if necessary) for notifying the public, coordinating the community response (e.g., blocking off roads, evacuation, etc.), and providing on-site response (e.g., fire fighting, medical treatment, etc.). This plant conducts periodic emergency action drills and provides periodic refreshers to the local emergency response organizations on the hazards associated with the plant operations.

Recent Changes to Improve Safety
Our Operations Integrity Management Systems form the cornerstone for continuous improvement in our
safety-related systems. These systems are evergreen and are in a continuous state of improvement, usually through many small improvement steps. These improvement steps are tightly integrated with our training programs. This plant resolves all findings from PHAs, incident investigations, and safety audits. The following are some of the changes that were recently implemented to improve the safety of this operation:
1. Reduced maximum potential inventory of hazardous chemicals (chlorine and sulfuric acid).
2. Added engine lube oil hi-lo level shutdowns.
3. Added sump to capture process drain fluids.
4. Implemented pressure relief valve sizing and design basis documentation software.
Submission - Other Facility Info facility_Submission_-_Other_Facility_Info help link help link  
Number of Full Time Employees18
Owner or Operator NameExxon Company, U.S.A.
Owner or Operator Address Line 1396 West Greens Road
Owner or Operator CityHouston
Owner or Operator StateTX
Owner or Operator Zip77067
Parent Dun and Bradstreet Number1213214
Second Parent Dun and Bradstreet Number0
Number of Full Time Employees18
Number of FTE CBI FlagNo
Other Facility IDTXD000778837
Covered by OSHA PSM StandardYes
Covered by EPCRA Section 302Yes
Covered by CAA Title VYes
CAA Title V Air Operating Permit IDO-00569
Last Safety Inspection Date19941110
Last Safety Inspection ByRisk Consultant
OSHA Star or Merit RankingNo
LEPC NameRefugio County LEPC

Submission - Contact Info facility_Submission_-_Contact_Info help link help link (Facility #1 : Exxon Company, U.S.A. Tom O'Co, RMP submission #1 : 19990621)
Owner or Operator Phone7134311442
Facility Dun and Bradstreet Number156080194
RMP Contact TitleProduction Manager

Submission - Additional Info facility_Submission_-_Additional_Info help link help link  
RMP Complete FlagYes
Predictive FilingNo
No RMP Accidents Last 5 YearsYes
Complete Check Date19990702
Error Report Datenull
Postmark Date19990618
Anniversary Date20040618
Confidential Business InformationNo

Submission - Lat/Long Info facility_Submission_-_Lat_Long_Info help link help link  
Valid Lat/LongYes
Lat/Long MethodInterpolation - Map
Lat/Long Location TypeCenter of Facility
FRS Latitude28.3739
FRS Longitude-97.1692

Submission - Counts and Totals facility_Submission_-_Counts_and_Totals help link help link (Facility #1 : Exxon Company, U.S.A. Tom O'Co, RMP submission #1 : 19990621)
Number of RMP Accidents0
RMP Accident Flammable Total (lbs)0
RMP Accident Toxic Total (lbs)0
RMP Accident Amount Total (lbs)0
Number of RMP Accidents0
Number of Processes1
Number of Process Chemicals1
Number of Toxic Worst-case Scenarios0
Number of Toxic Alternate Case Scenarios0
Number of Flammable Worst-case Scenarios1
Number of Flammable Alternate Case Scenarios0
RMP Accident Flammable Total (lbs)0
RMP Accident Toxic Total (lbs)0
RMP Accident Amount Total (lbs)0
Total RMP Accident Deaths0
Total RMP Accident Injuries0
Total RMP Accident Evacuated/Sheltering In Place0
Total RMP Accident Property Damage$0

Processes facility_Processes help link help link (Facility #1 : Exxon Company, U.S.A. Tom O'Co, RMP submission #1 : 19990621, process #1 : Gas Plant)
Process DescriptionGas Plant
Program Level1
Confidential Business InformationNo
Toxic Amount Total (lbs)0
Flammable Amount Total (lbs)240,000
Process Amount Total (lbs)240,000
Number of Process Chemicals1
Number of Toxic Worst-Case Scenarios0
Number of Toxic Alternate Scenarios0
Number of Flammable Worst-Case Scenarios1
Number of Flammable Alternate Scenarios0

Process Chemicals facility_Process_Chemicals help link help link  
Process Chemical IDFlammable Mixture
CAS number000001111
Chemical TypeFlammable
Process Chemical Amount (lbs)240,000
Confidential Business InformationNo

Process Flammable Mixture Chemicals facility_Process_Flammable_Mixture_Chemicals help link help link (Facility #1 : Exxon Company, U.S.A. Tom O'Co, RMP submission #1 : 19990621, process #1 : Gas Plant, process chemical #1, process flammable chemical: all)
Chemical ID
Isobutane [Propane, 2-methyl]
Isopentane [Butane, 2-methyl-]

Process Chemicals facility_Process_Chemicals help link help link  
Process Chemical IDPublic OCA Chemical
CAS number000000000
Process Chemical Amount (lbs)0
Confidential Business InformationNo

Worst-Case Flammable Scenarios facility_Worst-Case_Flammable_Scenarios help link help link  
Model UsedEPA's RMP*Comp(TM)
Passive Mitigation - Blast WallsNo
Confidential Business InformationNo

Process NAICS facility_Process_NAICS help link help link (Facility #1 : Exxon Company, U.S.A. Tom O'Co, RMP submission #1 : 19990621, process #1 : Gas Plant, process NAICS code #1 : 211112)
NAICS Code211112: Natural Gas Liquid Extraction

Emergency Response Plan Info facility_Emergency_Response_Plan_Info help link help link  
Facility In Community PlanNo
Facility Own Response PlanNo
Specific Facility Response PlanNo
Inform. Procedures in Response PlanNo
Emergency Care in Response PlanNo
Plan Review Datenull
Response Training Datenull
Local Response AgencyRefugio Volunteer Fire Department
Local Response Agency Phone3615262222
Subject To - OSHA EAPYes
Subject To - CWAYes
Subject To - RCRAYes
Subject To - OPANo
Subject To - State EPCRAYes

Search Criteria Used
RMP Facility ID100000082554