Dome Pipeline Corporation - Benson Terminal - Executive Summary

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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES 
 
At Dome Pipeline Corporation - Benson 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 o 
ur 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 (called data elements) about our risk management program 
 
 
STATIONARY SOURCE AND REGULATED SUBSTANCES 
 
Our facility takes propane off the Cochin Pipeline, operated by Dome Pipeline Corporation, and stores it in 90,000 gallon above ground bullets.  Ethyl mercaptan, an odorant, is also stored at the terminal and is injected into the propane stream to odorize the propane prior to truck loading.  Due to the current court  order staying propane as a regulated chemical under the RM Plan, we are considering ethyl mercaptan to be our only regulated chemical on site.  All scenarios are consequently based on ethyl mercaptan.  The facility is completely automated and is available for around 
the clock loading by trained, qualified drivers.  The facility is equipped with hand scan devices so only qualified drivers can gain access to the terminal and loading operations.   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 substantial accidental release: 
 
Toxics 
 
   Not applicable 
 
Flammables 
 
   Ethyl Mercaptan 
                    Propane (court stay) 
 
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 mi 
tigation 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 at the Benson Propane Terminal is a vapor cloud explosion (VCE) of a 1,000 gallon above ground ethyl mercaptan  storage bullet.  This bullet contains a maximum of 850 gallons (85% of 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 .124 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 .124 miles ( a propane truck staging parking lot.)  No environmen 
tal receptors were found.  To eliminate potential fuel and ignition sources, the following control measures are:  (1) the area near the storage tanks is rocked and (2) a vegetation 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 computer supervised fire and gas detection systems.     
 
Alternative Release Scenario(s) - Regulated Flammable Chemicals 
 
Dome Pipeline Corporation has reviewed several alternate release scenarios at the Benson Propane Terminal.  The scenario selected was a pool fire of ethyl mercaptan due to the failure of a welded nozzle at the bottom of the 1,000 gallon tank.  The scenario assumes a complete nozzle failure which would release the entire contents of the tank.  As much as 850 gallons(85% of maximum storage capacity) of ethyl mercaptan would be released and subject to a vapor cloud fire.  According to EPA's lookup tables, the distance to the Lower  
Flammable Limit (LFL) is less than .06 miles.  Based on 1990 census data, US Geological Survey maps and aerial photography, Dome Pipeline Corporation had determined there is  a  public receptor (a propane truck staging parking lot). No environmental receptors were found.  Control measures for ethyl mercaptan loading are:  (1) the area near the storage tanks is rocked or concrete, (2) a vegetation 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 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 
 
We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals.  Our management systems ad 
dress each of the key features of successful prevention programs including: 
 
*  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: 
 
Requiring trailer air gates to prevent the movement of the transport while the hoses are connected 
Emergency shutoff valves 
Gas detection systems 
UV fire detection systems 
Trained employees on the use of portable and wheeled fire extinguishers 
Trained employees on the use of flare pistols 
Train and qualify drivers on the safe loading of propane 
Use a hand scan security system so ensure only trained and qualified drivers can access the terminal and initiate the loading process. 
 
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 element 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 periodically to participate in gathering this information. 
 
2.    Employees will be contrib 
uting 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 evaluate 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,  and 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 causes 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 emergency procedures manual, which consolidates 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 Corporations'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 preparedness 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: 
 
Upgrade existing fire and gas detection systems. 
Reduce number of fittings and eliminate unused equipment in the ethyl mercaptan system. 
 
 
 
CERTIFICATIONS 
 
The undersigned  certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the 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 program 
   Emergency response program 
   Certification
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