Suburban Propane - Phoenix - Executive Summary

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                                               SUBURBAN PROPANE 
General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities 
1.    Accidental Release Prevention and Emergency Response Policies 
We at Suburban Propane - Phoenix are strongly committed to employee, public and environmental safety.  This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility.  It is our policy to implement appropriate controls to prevent possible releases of regulated substances. 
2.    The Stationary Source and the Regulated Substances Handled 
Our facility's primary activities encompass LP Gas Distribution - Wholesale.  We have 1 regulated substance present at our facility.  This substance is Propane.  Propane is stored on site pending wholesale transfer. 
3.    The Worst Case Release Scenario(s) and the Altern 
ative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario 
To perform the required offsite consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations.  The following paragraphs provide details of the chosen scenarios. 
The worst case release scenario submitted for Program 2 and 3 flammable substances as a class involves a catastrophic release from LP Gas Storage.  In this scenario 126000 lb. of Propane is released.  The release quantity has been limited to 80 % of the maximum capacity of the source by a system of administrative controls.  It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion.  Under worst case weather conditions, the calculated distance of 0.40 miles is obtained corresponding to an endpoint of 1 psi overpressure. 
One alternativ 
e release scenario submitted for Program 2 and 3 flammable substances involves a release from LP Gas Storage.  The release is assumed to result in a Vapor Cloud Fire.  The scenario involves the release of 129.76 lb. of Propane in 10 minutes.  Under neutral weather conditions, the maximum distance to the flammable endpoint of Lower flammability limit is <0.06 miles. 
Another alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from LP Gas Storage.  The release is assumed to result in a Vapor Cloud Fire.  The scenario involves the release of 2400.00 lb. of Propane in 10 minutes.  Under neutral weather conditions, the maximum distance to the flammable endpoint of Lower flammability limit is <0.06 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 EP 
A.  This facility was designed and constructed in accordance with NFPA 58 and building codes in effect at time of construction.The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. 
Process Safety Information 
Suburban Propane - Phoenix maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with our process. 
Process Hazard Analysis 
Our facility conducts comprehensive studies to ensure that hazards associated with our process are identified and controlled efficiently.  The methodology used to carry out these analyses is HAZOP.  The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of 5 years.  Any findings related to the hazard analysis are addressed in a timely manner.  The most recent PHA/update was performed on 01/15/2000. 

perating Procedures 
For the purposes of safely conducting activities within our covered process, Suburban Propane - Phoenix 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 turnaround.  The information is regularly reviewed and is readily accessible to operators involved in the processes. 
Suburban Propane - Phoenix has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes.  Refresher training is provided at least every 3 years and more frequently as needed. 
Mechanical Integrity 
Suburban Propane - Phoenix carries out highly documented maintenance checks on process equipment to ensure proper operations.  Process equipment examined by these checks includes among others; pressure v 
essels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps.  Maintenance operations are carried out by qualified personnel with previous training in maintenance practices.  Furthermore, these personnel are offered specialized training as needed.  Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. 
Management of Change 
Written procedures are in place at Suburban Propane - Phoenix to manage changes in process, technology, equipment and procedures.  The most recent review/revision of maintenance procedures was performed on 01/15/2000.  Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. 
Pre-startup Reviews 
Pre-start up safety reviews related to modifications in the established process are conducted as a regular practice at Su 
burban Propane - Phoenix.  The most recent review was performed on 01/15/2000.  These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. 
Compliance Audits 
Suburban Propane - Phoenix conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented.  The most recent comliance audit was conducted on 08/20/1998.  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 
Suburban Propane - Phoenix promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance.  These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring.  All 
reports are retained for a minimum of 5 years. 
Employee Participation 
Suburban Propane - Phoenix truly believes that process safety management and accident prevention is a team effort.  Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements.  In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. 
On occasion, our company hires contractors to conduct specialized maintenance and construction activities.  Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out.  Suburban Propane - Phoenix has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes.  Contractors are also informed of all the procedures for emergency response should an accide 
ntal release of a regulated substance occur. 
5.    Five-year Accident History 
Suburban Propane - Phoenix 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 release during this period. 
6.    Emergency Response Plan 
Suburban Propane - Phoenix carries a written emergency response plan to deal with accidental releases of hazardous materials.  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. 
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 processes that would require a modified emergency response. 
Phoenix Fire Department is the Local Emerge 
ncy Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 
7.    Planned Changes to Improve Safety 
Anytime developments and findings result from the implementation of the various elements of our accidental release prevention program, we want to take steps to improve safety at our facility. These steps are expected to be implemented within a 90 day period.
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