North Coles Levee Gas Plant - Executive Summary

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EOTT Energy Operating Limited Partnership (EOTT Energy) acquired the North Coles Levee Gas Plant on December 1, 1998.  The North Coles Levee Gas Plant is a Natural Gas Liquid Extraction and Liquefied Petroleum Gasoline (LPG) processing, storage and transfer facility.  The process is regulated by Cal OSHA Process Safety Management of Acutely Hazardous Materials, Title 8 California Code of Regulations 5189.  The facility has developed the  prevention program described below. 
EOTT Energy has a commitment to employee and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in design, installation, operation, and maintenance of our processes.  Our policy is to implement reasonable controls to prevent foreseeable releases.  However, if a release does occur, trained personnel will respond to control and contain the release.   
The prevention program is based on 40 CFR 68 and Title 19 CCR 2735.  The  
program includes the following areas: Employee Participation, Process Safety Information, Process Hazard Analysis, Operating Procedures, Training, Contractor Evaluation, Contractors and Visitor Orientation, Pre-Job Start-Up Review, Mechanical Integrity, Code of Safe Work Practices (Hot Work Permit, Confined Space Entry, Control of Hazardous Energy), Management of Change, Incident Investigation, Emergency Planning and Response, and Compliance Audits.  All visitors onto the property must undergo a site safety orientation and check in prior to each visit. Planned changes to improve safety have been established based on compliance with the process safety management audits and revalidation of the process hazard analysis.  Training includes employee responsibilities in the process safety management program, emergency response, hotwork permit procedure, code of safe work practices, and operating procedures. 
The facility process, stores and transfers natural gasoline, propane and butane.  The 
re are 32 tanks with capacities ranging from 4,000 to 40,000 gallons, and 1 tank with a capacity of 5,000,000 gallons.  The worst case flammable release scenario is based upon a 5,000,000 gallon release. 
EOTT Energy maintains an emergency response plan in compliance with local emergency response agencies.  The North Coles Levee Gas Plant has a Hazardous Materials Business Plan on file with the Kern County Environmental Health Department - Certified Unified Program Agency.  The facility maintains an air pollution control district permit to operate with the San Joaquin Unified Air Pollution Control District. 
In the event of an accidental release, the facility operators are trained to sound the alarm, shut off the source from a safe location or activate one of the emergency shutdown devices, contact 9-1-1 and secure the area.  The 9-1-1 system is used to notify the Fire Department. 
Based on the criteria set forth 40 CFR 68.10 and 19 CCR 2735.4, this facility has not had an accidental r 
elease.  This information was verified by the reviewing of records from the Kern County Environmental Health Department - Certified Unified Program Agency. 
The worst case scenario and alternate release scenario were based on propane as the modeled substance.  The worst case release of 24,394,500 lbs of liquefied petroleum gas indicates a one psi overpressure distance of 2.35 miles. This distance impacts public receptors of an oil production facility, natural gasoline plant, an adjacent farm, and a resident population of 75.  Although there are numerous controls in place, no allowance for passive mitigation was made in calculating worst case scenario. This scenario is based upon the U.S. EPA Vapor Cloud Explosion Methodology (TNT Equivalency Method).  This same release scenario was also evaluated using the Baker-Strehlow VCE Model.  This method takes into account the flatness of the surrounding terrain and the fact that the propane is stored in a refrigerated tank at -44 degrees Fahren 
heit.  Results of the Baker-Strehlow VCE Model indicate a one psi overpressure distance of only 0.02 miles.  Even though the Baker-Strehlow VCE Model results are also conservative and recognized by the U.S. Environmental Protection Agency, at this time EOTT Energy has elected to submit this RMP program using the more conservative TNT Equivalency Methodology.   
The Alternative Release Scenario for this process is a break in transfer hose connection.  This scenario could result in release of 60 lbs of liquids over a ten minute period. The maximum distance for this scenario is 0.03 miles. The process maintains mitigation measures consisting of relief valves, check valves, manual shutoff valves, automatic shutoffs, startup and operating procedures, grounding equipment, and excess flow devices.  The facility operator and truck driver are in attendance during transfer operations. 
The engineering and administrative controls in place have been established to reduce the risk of an accidental  
release of identified hazards.  EOTT Energy is committed to operations which are safe for employees and the surrounding community.
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