Red Wing Gas Plant - Executive Summary

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Accidental Release Prevention and Emergency Response Policy 
True Oil Company (TOC) is committed to providing a safe, accident-free work environment.  A safe and accident free workplace is the result of diligent work and ongoing attention to all company policies. 
All True Oil Company employees are knowledgeable of the safe work practices applicable to their area or job, and abide by them.  True Oil Company  employees perform their work with maximum regard  for the safety of themselves, co-workers and the general public.  
Regulated Substances Handled 
The 112(r) regulated flammable substances managed at the Red Wing Creek Gas Plant  facility include  butane, propane, natural gas condensate and B/G mix. Pressure vessels that contain regulated substances onsite include 2-18,000 gallon butane tanks ,  1-37,000 gallon B/G mix tank, 2-18,000 gallon condensate tanks, and 2-37,000 gallon propane tanks. 
Worst-Case Release Scenario 
The worst-case release scenario was modeled using the EPA Offsite Consequence Analysis Model.  The model assumes for each substance, the entire quantity stored in one pressure vessel is instantaneously consumed in a fireball tank explosion.  Scenarios were modeled individually for all four flammable substances. Results of  the modeling indicate the  worst-case endpoint distance (1 psi overpressure) for each of the substances is  approximately 0.4 miles and the distance to the nearest public receptor is 0.58 miles.  These findings indicate that given the rural nature of the facility and the lack of public or environmental receptors, the regulated processes pose little risk to the general public or the environment in the event of fire or explosion. 
Accidental Release Prevention Program 
TOC field personnel are provided various levels of training dependent on their overall job responsibilities. This training is conducted per the appropriate OSHA regulations, as are refresher classes.   
Specific training programs may include respiratory protection, lockout/tagout procedures, worker right to know/hazard communication standard.  Additionally, personnel are knowledgeable as to the characteristics and hazards of  the flammable material stored at the facility, and any conditions likely to worsen emergencies such as weather or mechanical equipment failure.  TOC employees know, in the event an emergency is identified, the steps necessary  to clearly communicate it to the supervisory personnel and the steps to take in the event of an  accidental product release, fire or explosion.  TOC employees are trained in the proper use of chemical extinguishers during the incipient stage of a fire. Inspections of  the pressure vessels, fittings, lines etc. are performed as part of routine facility inspections by the TOC personnel.  
Five-Year Accident History 
This facility has not had any accidental releases of any of the regulated substances  in the past five years. 
Emergency Respons 
e Program 
1.  Operations personnel discovering a release, fire or explosion are to immediately notify the  True Oil Company designated shift supervisor by radio, telephone or by direct contact. These persons are authorized to initiate a response to any emergency reported to Red Wing Gas Plant. 
2.  Depending on the situation, procedures to be followed by the discovering employee(s) to mitigate the emergency may include:  
7 Stop the leak/release if it can be DONE SAFELY WITHOUT RISK. 
7 Shut upstream source off- for example: If in process area, shut down inlet compressors and refrigeration compressor. If in field, shut well in. Never shut valves without knowing the outcome. 
7 If fire has occurred, let vessel or line burn unless leak can be safely stopped. 
7 Evacuate all nonessential personnel and secure all ignition sources. 
7 No vehicles, smoking or any ignition source allowed in hazard area. 
7 Isolate hazard area and limit entry to emergency responders. 
7 Stay upwind and uphill 
away from release. 
7 Remain in a safe location until the designated supervisor arrives. Assist with any immediate response, containment, and equipment utilization as directed. Further secure the site from livestock and unauthorized persons. 
7 In the event of a spill or if heavy equipment is needed, Kehoe Pipeline is certified for emergency response. 
Planned Changes in Safety Program 
Given the remoteness of the facility, lack of proximal off-site receptors  and the excellent accident history that has been demonstrated over time, no specific changes in the TOC safety program are planned.  However, routine training opportunities will continue to be provided to TOC employees.  If in the future, new safety technology relating to the regulated process is developed,  installation of such technology will be further evaluated.
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