Alto Underground Storage - Executive Summary |
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This document was developed for Ohio Northwest Development, Inc. for their ALTO Underground Propane Storage (ALTO) facility, in an effort to fulfill criteria of the Risk Management Program (RMP), as required by Section 112(r) of the Clean Air Act, and regulated by 40 CFR, Part 68. The facility is located on the southeast corner of Alden Nash Avenue and 60th Street in Alto, Michigan. ALTO is a liquefied petroleum gas storage and distribution facility. ALTO's storage of propane at the facility is defined as a single process under the regulations pertaining to RMP development. Storage vessels at the facility include one 10,000-gallon and three 30,000-gallon, aboveground storage tanks (AST); along with five underground storage tanks (USTs) located in salt caverns 4,000 feet below grade. The total capacity of these five tanks (with administrative controls utilizing 85% tank filling capacity) is 35 million gallons of liquid propane. All storage units for the facility are interconnected through a contiguous piping system. ALTO receives liquid propane, via 30,000-gallon rail cars and tanker trucks. The propane is transferred into the underground storage system, where the propane is held until it is transferred back out into tanker trucks for distribution. The quantity of propane held at the facility is greater than the threshold quantity (TQ) of 10,000 pounds for flammable substances, which is EPA's criteria for requiring the development and submittal of the information found in this RMP. Propane is considered hazardous by EPA standards. The same properties that make propane valuable as a fuel also makes it necessary to observe certain safety precautions in handling propane to prevent unnecessary human exposure and to reduce the impact or threat to nearby members of the community and environment. Safety depends upon the manner in which we handle propane; combined with safety devices inherent in the design of this facility and the training of our personnel. A. A CCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES This facility complies with NFPA-58 requirements for LP-gas storage, and it is our policy to adhere to all applicable federal, state, and local laws. If an emergency were to occur, it is our policy and/or procedure to notify the Alto Fire Department and request that they respond to the emergency. B. THE STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED Propane is received by rail car and tanker trucks and placed in the ASTs. From there, the propane is transferred to the underground storage in the caverns through a piping system. The stored propane is transferred out for distribution through the same piping and ASTs. Propane from the underground cavern storage maintains the liquid levels of the ASTs. The maximum amount of propane that can be stored at this plant, applying administrative controls, is 148,400,000 pounds. C. WORST-CASE RELEASE SCENARIO AND ALTERNATIVE RELEASE SCENARIO Worst-Case Scenario (WCS) - Our WCS is failure of one of the 30,000-gallon ASTs when filled to maximum capacity (85% at 600F), resulting in a vapor cloud explosion. According to EPA's look-up tables, the distance to the endpoint is 0.38 miles. There are eight businesses and nine residences, with an estimated population of 27 individuals, within this radius. Alternative Release Scenario (ARS) - A 32 pipe breaks leading to a 10-minute release of propane. This translates into an 8,250 lb. release with a distance to 1 psi overpressure of 0.16 miles. This ARS was chosen because it is more likely to occur than the WCS and can still reach off-site receptors (criteria specified by RMP development guidelines). There is one residence within this radius. D. THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND THE SPECIFIC PREVENTION STEPS This facility complies with EPA's accidental release prevention rule and with all applicable state codes and regulations. The propane system is designed, constructed, and maintained in accordance with NFPA-58 and other state laws. E. FIVE-YEAR ACCIDENT HISTORY ALTO has never had an accidental release of propane, which resulted in death, injury, property or environmental damage, evacuation, or shelterings in place. F. EMERGENCY RESPONSE PROGRAM We have discussed the content and intent of this program with the Alto Fire Department. Representatives of the Alto Fire Department have visited the plant to conduct site fire prevention inspections and joint training to familiarize themselves with the layout of the facility and to improve response in the event of an emergency. In addition, ALTO has an "Emergency Procedure Plan" for employees to follow in the event of a fire and/or propane gas release. ALTO will utilize and implement the "911" system for emergency response. G. PLANNED CHANGES TO IMPROVE SAFETY There are no immediate changes called for or planned at this time. ALTO intends to continue to safely operate the facility in a safe and compliant mann er and we are prepared to proactively address any process changes in a timely manner. |