Texon L.P. Propane Terminal - Executive Summary

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A. Texon L.P. is committed to the safety of its workers, the public and the environment.  Its accidental release policy is an integrated approach, involving employee participation, management practices, written procedures and training.  Texon has created a comprehensive propane accident prevention program considering all aspects of process operation and maintenance.  It has also developed a written emergency action plan and coordinated these efforts with local emergency responders (local fire department). 
B. Texon L.P. operates a propane terminal in Lebanon, IN.  Propane is received from a pipeline and by rail and is distributed by truck. There are seventeen 90,000-gallon tanks at the site, holding approximately 310,000 pounds each of liquid propane.  There are emergency shutdown systems on all LPG equipment at the site. 
C. The offsite consequence analysis considers a worst case and an alternative scenario involving a propane release and subsequent vapor cloud explosion. The RMP Rule 
says the explosion endpoint is 1 psia overpressure. The Risk Management Program Guidance for Propane Storage Facilities was used to determine distances to explosion endpoint for each scenario. 
The worst-case scenario involves the failure of one of the 90,000-gallon tanks holding approximately 310,000 lb. of propane. It assumes all of the propane is released and ignited. No passive mitigation is considered.  A lookup table in the EPA guidance gives a 0.5-mile distance to explosion endpoint.  This clearly extends offsite and there are public receptors within the distance to the endpoint. Texon has many safeguards in place, which make this scenario very unlikely, including an aggressive maintenance and inspection program. 
The alternative scenario involves a propane release from a Multiport 2.5-inch relief valve over a 5-minute period at a rate 863 pounds per minute.  An excess flow check valve is the active mitigation considered in this scenario.  A total of 4,315 pounds of propane is  
ignited, resulting in a vapor cloud explosion.  This would generate a pressure wave with a minimum 1 psi overpressure extending 0.1 miles. This distance extends past the facility boundary and there are public receptors within it. 
D. Texon complies with the Risk Management Program and OSHA Process Safety Management Rules. Taken together, the components its prevention program are designed to ensure that: 
 Process equipment is in proper working order 
 Employees are trained in safety and aware of correct operating procedures 
 Changes to the process or personnel do not result in accidents 
 The hazards of the process are identified and addressed.   
 In addition, Texon follows NFPA-58 (National Fire Protection Association) guidelines regarding liquefied petroleum gases. 
E. No significant accidental release of propane has occurred at this facility in the past five years. 
F. For the purposes of the RMP Rule emergency response provisions, Texon can be considered a non-responding facili 
ty.  Texon has implemented an emergency action plan in accordance with the OSHA's Standard 1910.120 and it includes procedures for evacuation, medical care, reporting, critical equipment operation, alarm systems, severe weather and handling small spills.  In addition, Texon is in contact with its LEPC (Boone County LEPC) and is included in the community emergency response plan prepared under EPCRA. Texon has compiled a list of emergency contacts and coordinates emergency planning with the local fire department (including a yearly walk-through and training program), since they would be the emergency responders.   
G. Texon has an ongoing commitment to all elements of it risk management program and is always striving to improve safety at the site.  However, there are additional no activities beyond the  safety and prevention program underway at this time.
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