Hillsboro Farmers Co-op Grain Storage Facility - Executive Summary |
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EXECUTIVE SUMMARY FOR HILLSBORO FARMERS CO-OP GRAIN STORAGE (PROPANE FACILITY) 1. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES: The primary function of the "Hillsboro Farmers Co-op Grain Storage Facility" is to act as a grain storage facility. This facility uses propane in its operation as a fuel for drying grain. 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 distr ibution facility. Our emergency response program is based upon the NPGA's LP-Gas Safety Handbook, LEPC and 40CFR part 68. In addition to the presence of appropriate controls to prevent possible releases of propane, if a release does occur, we are completely coordinated with the Vernon County Sheriff Department, which provides highly trained emergency response personnel to control and mitigate the effects of a release. 2. THE STATIONARY SOURCE AND THE REGULATED SUBSTANCES HANDLED The primary purpose of this facility is to use propane as a fuel to dry grain from the field to prepare it for storage. Propane arrives at our facility via truck and is stored in one storage tank. This facility has equipment to unload transports and equipment to load 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 o f propane that can be stored at this plant is 107,000 lb. 3. THE WORST CASE SCENARIO AND THE ALTERNATE RELEASE SCENARIO, INCLUDING ADMINISTRATIVE CONTROLS AND MITIGATION MEASURES TO LIMIT THE DISTANCES 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 chosen scenarios. The worst case release scenario submitted for "Hillsboro Farmers Co-op Grain 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 that finds an ignition source, with 10 percent of the released quantity par ticipating in a vapor cloud explosion. Under worst case weather, the maximum distance of 0.31 miles was obtained corresponding to a flammable endpoint of 1 psi overpressure. The alternative release scenario for our facility involves a release resulting in a "Pool Fire". In this scenario 299 lb. of propane is released in 1 minute. Under neutral weather conditions, the maximum distance to the flammable endpoint of 5 kw/m2 for 40 seconds is 0.05 miles. 4. THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND THE CHEMICAL-SPECIFIC PREVENTION STEPS Our facility has taken all the 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 NFPA Standards and all applicable National Propane Standards. The following sections briefly describe the release prevention program that is in place at our stationary source. SAFETY INFORMATION "Hillsboro Farmers Grain S torage Facility" 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 puposes of safely conducting activities within our covered process, "Hillsboro Farmers Co-op Grain Storage Facility" maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turn around. The information is regularly reviewed and is readily accessible to operators involved with the process. TRAINING "Hillsboro Farmers Co-op Grain Storage Facility" has a comprehensive training program in place to ensure that employees that are operating processes are completely competent in the operating procedures associated with the process. 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 as needed. MAINTENANCE "Hillsboro Farmers Co-op Grain Storage Facility" carries ou 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. Furthermore, personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corr ected in a safe and timely manner. COMPLIANCE AUDITS "Hillsboro Farmers Co-op Grain Storage Facility" 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 actions required as a result of the audits are undertaken in a safe and prompt manner. INCIDENT INVESTIGATION "Hillsboro Farmers Co-op Grain Storage Facility" 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 "Hillsboro Farmers Co-op Grain Storage Facility" has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental releases during this period. 6. EMERGENCY RESPONSE PLAN "Hillsboro Farmers Co-op Grain Storage Facility" 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 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. 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. The facility plans to limit access to the storage area to trained and authorized personnel. The company plans to implement a safety and awareness program 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 undesigned 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 |