The Targa Resources Safety Seminars session in Southern California, Sept. 2016, covered numerous aspects of propane safety, including the importance of written bulk plant operating procedures and of monthly inspections of emergency shut-down systems. Propane company employees from California, Arizona, and other states were in attendance at the event. Targa Resources conducts its safety seminars every three years at 14 locations nationwide. This year’s seminars kicked off in Chattanooga, Tenn. and moved on to Greenville, Miss.; Dallas; and Concord, Calif. before the Long Beach meeting.
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The sessions in Long Beach covered various aspects of propane safety, including general propane safety, material safety data sheets, odorant, and proper incident investigation and reporting.

Don Tomiello, director of terminal operations for Targa Resources, spoke on the topic of “Best Practices,” telling attendees, “You want to test the emergency shut-down system monthly, so it continues to function like it should. You want to be sure you can close it from a remote location. You want to make sure the valves close and that all pieces of equipment work.”

Tomiello explained that according to OSHA regulation 29CFR 1910, each bulk plant must include operating procedures “in a common location.” NFPA 58 also recently incorporated verbiage stating that operating procedures should be part of propane operations. Any time a change of operating procedures occurs, the operator must update the operating procedure documents. If contractors are involved in the operation of the facilities, they also must be trained on the operating procedures.

“That’s not necessarily the contractor’s responsibility; it’s yours,” Tomiello told the audience of propane professionals. Contractors must be trained or “under the immediate supervision of such a trained person performing the maintenance procedures,” according to OSHA 29CFR 1910.119 (h).
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He then discussed maintenance plans, reminding attendees that marketers should keep equipment maintenance manuals in an area where they are available to all employees, and they should be kept for the life of the equipment.

Don Sextro, senior measurement specialist at Targa Resources’ Houston office, also spoke at the event, providing an overview of propane, discussing gas processing and fractionation. He followed with a presentation on propane properties, including its Btu content, density, boiling point, and freezing point. Tom Meriwether, senior counsel for Targa Resources, gave a session on “Propane Litigation and Tort Reform Issues.”

Tomiello also provided an additional presentation on “Emergency Response,” telling the audience that propane marketers should take the following actions in the initial minutes of any emergency situation: warn employees, contractors and visitors; evacuate, take shelter, or go on lockdown; and call emergency services.

He warned that personnel should not enter a vapor cloud to perform emergency procedures, which he illustrated by showing a video of scenes from a propane explosion that took place in Ghent, W. Va. in 2007. In that incident, people didn’t clear the scene of a vapor cloud, and the result was the deaths of two people and injuries to several others.

“Equipment can be replaced. Lives cannot,” Tomiello stressed.

Specifying procedures for handling any sudden unexpected situations should be the overall objective of the written emergency plan. Preventing fatalities and injuries and reducing damage to buildings are top initial priorities. “Once the emergency is done, you want to accelerate the return to business as normal,” Tomiello continued. “Communication, training, and periodic drills will ensure success in the event your plan must be executed.”

Procedures for emergency evacuation are another element of the emergency plan. “Where are your employees supposed to go if they’re in the facility? Where are the muster points [the pre-determined spots that all employees should go to in an emergency], and how do they exit? That can be extremely critical when it comes to establishing a head count,” Tomiello said. Keeping a list of contact information for all employees is also crucial, as is a list of all available emergency equipment.

The water supply source is an extremely critical piece of information for a propane marketer. “Don’t have water? Then you’ll have to take a very defensive [stance] and evacuate the area. If you’ve got a lot of water, that can aid the fire department in how they deal with it.”

Does your facility have an alarm system, and is it tested periodically? Marketers should test their alarm system regularly to make sure it works.

Training is one of the most important factors of the emergency plan. “Hopefully you train on it and train on it and never have to implement the plan. But what you want to do is train and practice a safe and orderly evacuation.” Coordinate the drills with local responders to test their response and to familiarize them with your facilities. Conduct at least one practice drill annually for each facility.

Meriwether, senior counsel for Targa Resources, in his session on litigation and tort reform, pointed out that a negligence claim is one type of claim a plaintiff might file against a propane marketer in the event of a propane accident or explosion. A negligence claim takes place when someone, or the relative of someone, is hurt or killed, and the injured party sues various parties for money to compensate for the loss. A person filing a negligence suit must prove that the defendant owes a certain duty of care.

“You may not know it, but all of us walking around, we all owe each other a duty,” Meriwether explained. “When you’re driving in your car, you owe the people on the road a duty. And what that duty generally is, is a duty to be reasonable.” You must take reasonable precautions and act as a reasonable person in that setting and not injure other people. He added that a propane business has more specialized duties.

“The duty that you’re going to be held to is not just what would any reasonable person off the street do, but what would someone in your industry with your experience do? What would a reasonably prudent propane wholesaler do in this situation? That’s the duty…that you’re going to be held to.”

In October, the remaining sessions rounding out the 2016 schedule took place in Orlando and Fort Lauderdale, Fla; and Philadelphia and Warren, Pa. —Daryl Lubinsky