Wilton Bulk Petroleum Plant - Executive Summary |
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EXECUTIVE SUMMARY FOR WILTON PETROLEUM BULK PLANT PROPANE STORAGE AND DISTRIBUTION FACILITIES 1 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The primary function of the "Wilton Bulk Petroleum Plant is to act as a propane distribution facility. By virtue of the flammable effects associated with propane, it is necessary to observe certain safety precautions in handling propane to prevent unnecessary human exposure, to reduce the threat to our own personal health as well as the health of our co-workers, and to reduce the threat to nearby members of the community. We are strongly committed to employee, public and environmental safety. Safety at our facility depends upon the manner in which we handle propane as well as on the various safety devices incorporated into the design of our equipment. Furthermore, comprehensive training received by our employees adds to the inherent safety of our distribution facility. Our emergency response program is based upon the NPGA' s LP-Gas Handbook, "Guidelines for Developing Plant Emergency Procedures", "How to Control LP-Gas Leaks and Fires" and Chapter 40 CFR part 68. In addition to the presence of appropriate controls to prevent possible releases of propane, if a releases does occur, we are completely coordinated with the Monroe County Sheriff Department, which provides highly trained personnel to control and mitigate the effects of a releases. 2. THE STATIONARY SOURCE AND THE REGULATED SUBSTANCES HANDLED The primary purpose of this facility is to repackage and distribute propane to both retail and wholesale customers for use as a fuel. Propane arrives at our facility via truck and is stored in one storage tank. This facility has equipment for unloading transports and equipment for loading transports and containers. Access to this site is restricted to authorized facility employees, authorized management personnel and authorized contractors. The regulated substance handled at this facility is propane . The maximum amount of propane that can be stored at this plant is 107,100 lb. 3. THE WORST CASE SCENARIO AND THE ALTERNATIVE RELEASE SCENARIO, INCLUDING ADMINISTRATIVE CONTROLS AND MITIGATION MEASURES TO LIMIT THE DISTANCE FOR EACH REPORTED SCENARIO We have calculated a worst case release scenario based on the NPGA-EPA approved TNO-Multi energy method. For alternative release scenario analysis, we have employed the equations provided by the EPA in the "RMP Offsite Consequence Analysis Guidance". The following paragraphs provide details of the chosen scenarios. The worst case scenario submitted for "Wilton Bulk Petroleum Plant" involves a catastrophic release from the propane tank. The scenario involves the release of 107,100 lb of propane. The release quantity has been limited by 15 percent resulting from written procedural mechanisms. It is assumed that the entire quantity is released as a vapor and finds an ignition source, with 10 percent of the released quanti ty participating in a vapor cloud explosion. Under worst case weather, the maximum distance of 0.31 mile was obtained corresponding to a flammable endpoint of 1 psi overpressure. The alternative release scenario for our program 2 process, involves a release of propane resulting in a "Pool Fire". In this scenario 299 lb. of propane is released in 1 minute. The release is also controlled by active mitigation measures that include manual and automatic emergency shutoff valves. Under neutral weather conditions, the maximum distance to the flammable endpoint of 5 kw/m2 for 40 seconds is 0.05 mile. 4. THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND THE CHEMICAL-SPECIFIC PREVENTION STEPS Our facility has taken all necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with the NFPA Standards and National Propane Regulations. The following sections brief ly describe the release prevention program thta is in a place at our stationary source. SAFETY INFORMATION "Wilton Bulk Petroleum Plant" maintains a detailed record of written safety information, which describes the chemical hazards, operating parameters and equipment designs associated with all aspects of our distribution facility. HAZARD REVIEW A checklist is used to carry out hazard reviews at our facility. The reviews focus on operating procedures, equipment functions and handling practices to identify possible hazards. The studies are undertaken by a team of qualified personnel with extensive knowledge of facility operations. Any findings related to the hazard reviews are addressed in a safe and timely manner. OPERATING PROCEDURES For the purpose of safely conducting activities within our covered process, "Wilton Bulk Petroleum Plant" maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temp orary operations, emrgency shutdowm, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved with the processes. TRAINING "Wilton Bulk Petroleum Plant" has a comprehensive training program in place to ensure that employees that are operating processes are completely competent in the operating procedures associated with these processes. New employees receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently. Refresher training is provided at least every two years and more frequently if needed. MAINTENANCE Wilton Bulk Petroleum Plant" carries out highly documented maintenance checks on process equipment to ensure proper functioning. Maintenance activities are carried out by qualified personnel with previous training in these practices. Futhermore, personnel are offered specialized training as needed. Any eq uipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. COMPLIANCE AUDITS "Wilton Bulk Petroleum Plant" conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actioins required as a result of the audits are undertaken in a safe and prompt manner. INCIDENT INVESTIGATION "Wilton Bulk Petroleum Plant" promptly investigates any incident that has resulted in, or could reasonably result in, a catastrophic release of propane. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from recurring. All reports are retained for a minimum of 5 years. 5. FIVE-YEAR ACCIDENT HISTORY "Wilton Petroleum Bulk Plant" has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release p revention policies, there has been no accidental release during this period. 6. EMERGENCY RESPONSE PLAN "Wilton Bulk Petroleum Plant" carries a written emergency response plan to deal with accidental releases of propane. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. Our facility's emergency response plan is based upon the NPGA's LP-Gas Handbook, "Guidelines for Developing Plant Emergency Response Procedures", "How to Control LP-Gas Leaks and Fires" and the LEPC requirements. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our process that would require a modified emergency response. Margaret Eddy (Interim Emergency Management Director) is t he Local Emergency Planning Committeee (LEPC) with which our emergency plan has been coordinated and verified. 7. PLANNED CHANGES TO IMPROVE SAFETY Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. A controlled access and a training program that addresses the risks involved with propane will be implemented for all employees involved with the process. These are some of the major steps we want to take to improve safety at our facility. These changes shall be implemented by July 1, 1999. 8. CERTIFICATION STATEMENT The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. Name: Robert Stekel Signature: Title: Safety Coordinator Date signed 05/25/99 |