Dome Petroleum - Green Springs - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At Dome Petroleum Corp - Green Springs Propane Terminal, we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: * A description of our facility and use of substances regulated by EPA's RMP regulation * A summary of results from our assessment of the potential offsite consequences from accidental chemical releases * An overview of our accidental release prevention programs * A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule * An overview of our emergency response program * An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment * The certifications that EPA's RMP rule requires us to provide * The detailed information about our risk management program STATIONARY SOURCE AND REGULATED SUBSTANCES Our facility takes propane off the Eastern Delivery System pipeline operated by Dome Pipeline Corporation, and stores it in various aboveground bullets, the largest being 103,000 gallons. Ethyl mercaptan, an odorant, is also stored at the facility and is injected into the propane stream prior to truck and rail loading. Due to the executive order staying propane coverage from the RMP regulation, ethyl mercaptan is our only covered substance. In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a sub stantial accidental release: Toxics Not applicable Flammables Butane Propane (court stay) Ethyl mercaptan Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: Worst-case Release Scenario(s) - Regulated Toxic Chemicals Not applicable Alternative Release Scenario(s) - Regulated Toxic Chemicals Not applicable Worst-case Release Scenario(s) - Regulated Flammable Chemicals Dome Pipeline Corporation has determined the worst case scenario a t the Green Springs Propane Terminal is a vapor cloud explosion of the 103,000 gallon propane/butane interface aboveground storage tank. The tank contains a maximum of 87,550 gallons (85% storage capacity) of a butane/propane mixture. The scenario was based on the remote possibility of the tank being compromised due to physical or mechanical damage. The distance to 1 PSI overpressure has been calculated at .59 miles. Based upon 1990 census data, US Geological Survey maps and aerial photography, Dome Pipeline Corporation has determined the following public receptors are within the .59 miles ( 52 residents, 17 homes and 2 commercial businesses). No environmental receptors were found. To eliminate potential fuel sources, the following control measures are: (1) the area near the storage tanks is rocked, (2) a vegitation control program is in place and (3) the facility is wired according to National Fire Protection Association Standard 70. The area is also continuously monitored by c omputer supervised fire and gas detection systems. Alternative Release Scenario(s) - Regulated Flammable Chemicals Dome Pipeline Corporation has determined the alternate case scenario at the Green Springs Propane Terminal is a vapor cloud explosion (VCE) of a 2750 gallon above ground ethyl mercaptan storage tank. This tank contains a maximum of 2337 gallons (85% storage capacity) of ethyl mercaptan. This scenario was based on the remote possibility of the tank being compromised due to physical or mechanical damage. The distance to 1 PSI overpressure has been calculated at .17 miles. Based upon 1990 census data, US Geological Survey maps and aerial photography, Dome Pipeline Corporation has determined the following public receptors are within the .17 miles (1 residence and 1 commercial business). No environmental receptors were found. To eliminate potential fuel sources, the following control measures are: (1) the area near the storage tanks is rocked ; (2) a vegetation con trol program is in place; and (3) the facility is wired according to National Fire Protection Association Standard 70. The area is also continuously monitored by computer supervised fire and gas detection systems. We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL SPECIFIC PREVENTION STEPS Process safety information Process hazard analysis Operating procedures Training Mechanical integrity Management of change Pre-startup review Compliance audits Incident investigation Employee participation Hot work permit Contractors As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: Gas detection system Fire detection system Emergency shut off valves Air operated fail close valves Air gates on truck fill connections These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. Below is a copy of our employee participation statement, the key elemenet to our Process Safety Management and Risk Management prevention programs. Employee Participation Statement DOME PIPELINE/DOME PETROLEUM CORPORATION Employee Participation in Process Safety Management: Dome is committed to the involvement of employees in all facets of the safe operations of its processing facilities and encourages the participation of employees in all aspects of process safety management. 1. Employees will have access to all information pertaining to the processes they operate. Individuals may be asked periodicall y to participate in gathering this information. 2. Employees will be contributing members of the process hazards analysis team. The process hazards analysis report will be accessible and available to all affected employees. 3. Employees directly responsible for using operating and maintenance procedures shall participate in their development and continued improvement. 4. Employees involved in operations or maintenance will be trained to safely conduct their respective assignments. Training shall be periodically provided. Employees shall be required to demonstrate proficiency in their job assignments. 5. Employees shall be asked to eveluate contractor performance. 6. Employees are required to adhere to all established safety procedures. 7. Employees will participate in emergency planning development, investigations of incidents and accidents, Management of Change procedures, ongoing reviews of process safety and operability, Pre-Startup Safety Reviews, an d Compliance Audits. 8. Employees are required to adhere to the tenets of Dome's trade secret and license agreements, where applicable. Safe operation and maintenance requires the involvement of both employer and employee. Dome maintains an open access policy to employees regarding process safety. Employees are responsible to operate and maintain the processes and equipment in a safe manner. Employees will have the opportunity for involvement in all aspects of process safety management through voluntary direct participation, through consultation as affected employees, and through methods such as anonymous communication and employee representation. FIVE-YEAR ACCIDENT HISTORY We keep records for all significant accidental chemical releases and incidents that could have reasonably resulted in a significant accidental chemical release that occur at our facility. For each of these incidents, we have conducted formal incident investigations to identify and correct the root ca uses of the events. We have not had any releases meeting the requirements of part 68.42 of the regulation. EMERGENCY RESPONSE PROGRAM We maintain an integrated contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan. Below is a copy of our managements philosophy regarding emergency preparedness. Dome Pipeline Corporation's pledge is to excel in protecting the environment and the health and safety of its employees, the users of its products, and the communities in which it operates. An effective and viable Emergency Procedures Manual is recognized as a necessary tool to guide correct emergency response. Dome Pipeline Corporation places such importance on emergency pr eparedness that all company operations have and maintain an emergency procedures manual. PLANNED CHANGES TO IMPROVE SAFETY The following is a list of improvements that we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases: Improve truck driver training. Implementing a new contractor safety program. Determine practicality of upgrading the fire detection system. CERTIFICATIONS The undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the other information submitted in this RMPlan is true, accurate, and complete. Signature Title Date RMP DATA ELEMENTS The following pages present additional information about our risk management program that EPA's RMP rule has asked us to provide. This information is categorized as follows: Executive Summary Registration Offsite consequence analysis Five-year accident history Program 3 prevention pr ogram Emergency response program Certification |