Linden LPG Storage Facility - Executive Summary |
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The Public Service Electric and Gas Company (PSE&G) Linden Liquid Petroleum Gas (LPG) Storage Plant has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in risk management programs, such as training personnel and considering safety in the design, installation, operation and maintenance of processes. The policy is to implement reasonable controls to prevent foreseeable accidents. However, if an accidental release does occur, PSE&G gas plant trained personnel will respond to control and contain the release or contact outside responders, as needed. Description of the Stationary Source and Regulated Substances The PSE&G Linden LPG Storage Plant is located on South Wood Avenue in the city of Linden, New Jersey between the PSEG Linden Electric Generating Station and the New Jersey Turnpike. It is situated in the northwest section of 40 acres of property and is adjacent to a Duke Energy (previously Texas Eastern) metering a nd regulating station at an interconnection between the PSE&G and Duke Energy natural gas pipelines. It was established in 1974 as an ancillary unit to the Synthetic Natural Gas Plant that was closed in 1989 and demolished in 1998. The LPG storage tanks remained as an emergency supply for peak shaving operations. Operations at the facility can be classified using Standard Industrial Classification (SIC) Code 4925 or North American Industry Classification System (NAICS) Code 22121 (Mixed, Manufactured, or Liquefied Petroleum Gas Production and/or Distribution). Operations at the plant consist of eleven horizontal 90,000-gallon LPG storage tanks. Additionally, a material testing laboratory located in buildings formerly used by the Synthetic Natural Gas facility is now used as a base of operations for the field staff in the testing of plastic gas service piping and associated materials. The Linden LPG Storage Plant is not permanently manned and only occasionally has truck deliveries fo r filling and removal of LPG. The only operations that occur at the Plant involve the storage and transfer of LPG. Please note, LPG is composed of primarily propane (>90% by weight) as detailed in the Material Safety Data Sheets (MSDS. Therefore, all references to LPG or propane refer to the same substance unless otherwise specified Offsite Consequence Analysis Results The worst-case scenario (WCS) associated with toxic substances in Program 3 processes at the gas plant is a catastrophic tank failure in the propane storage tank farm, resulting in a release of 302,400 pounds (equivalent to one full storage tank) of propane over a 10-minute period. Although PSE&G has numerous controls to prevent such releases and to manage their consequences, no credit for administrative controls or passive mitigation measures was taken into account in evaluating this scenario. The maximum distance to the toxic endpoint of 1 psi for this WCS is 0.54 miles. For an alternate release scenario (ARS), PSE&G has reviewed possible release scenarios based upon a review of operations at the facility. The release scenarios considered in the alternate release scenario are more probable to occur than the worst-case release scenario, however, PSE&G has implemented numerous process and safety procedures to insure that no release will occur. ARS considered in the analysis include truck pull-away, a process pipe breaking and overfilling of a storage tank. The maximum distance to the 1-psi endpoint for this event is 0.2 mile. This event was selected as being a practical scenario for use in emergency planning and response. Overview of General Accidental Release Prevention Program 4.0 Prevention Program Section 4 of this document contains the detailed explanation of the Linden LPG Storage Plant Prevention Program. The elements presented in the following section incorporate the required elements as presented in 40 CFR 68 Subpart D. 4.1 Process Safety Information (40 CFR 68.65) The PSE& G Linden LPG Storage Plant maintains several of technical documents used to promote safe operation of the process. These documents address the chemical properties of LPG and associated hazards, limits for process parameters, LPG inventories and equipment design basis/configuration information. Specific personnel are assigned responsibility for maintaining up-to-date process safety information. Due to the nature of operations at the facility, minimal documentation is needed to satisfy these requirements. LPG-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). The plant also maintains technical documents that provide information about the design and construction of process equipment. 4.2 Process Hazard Analysis (40 CFR 68.67) The PSE&G Linden LPG Storage Plant has a comprehensive program to help ensure that hazards associated with the various processes are identified and con trolled. Within this program, the LPG storage and transfer process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards. The PSE&G Linden LPG Storage Plant has used the What-If? / Checklist analysis technique to perform these evaluations. This technique has been deemed adequate based upon the selection process presented in "Guidelines for Hazard Evaluation Procedures" (Center for Chemical Process Safety, 1992). The analysis was conducted using a team of people who have operating and maintenance experience as well as engineering expertise. This team identified and evaluated hazards of the process as accident prevention and mitigation measures and the team made suggestions for additional prevention and/or mitigation measures when the team believed such measures were necessary. 4.3 Operating Procedures (40 CFR 68.69) The PSE&G Linden LPG Storage Plant maintains written procedures that address various modes of proces s operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. Due to the nature of operations at the Linden LPG Storage Plant, not all of these modes of operation are applicable. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. The procedures are periodically reviewed and annually certified as current and accurate. The procedures are kept current and accurate by revising them as necessary to reflect changes made through the management of change process. Current operating procedures for the LPG storage process are presented in Appendix D. 4.4 Training (40 CFR 68.71) The PSE&G employees assigned to work at the Linden LPG Storage Plant have already operated this plant before June 21, 1999 and have the required knowledge, skills and abilities to safely carry out the duties and responsibilit ies as specified in the operating procedures. 4.5 Mechanical Integrity (40 CFR 68.73) The PSE&G Linden LPG Storage Plant has well-established practices and procedures to maintain pressure vessels, piping systems, relief and vent systems, controls, pumps, compressors and emergency shutdown systems in a safe operating condition. The basic aspects of this program include: (1) conducting training, (2) developing and/or implementing written procedures, (3) performing inspections and tests, (4) correcting identified deficiencies and (5) applying quality assurance measures. In combination, these activities form a system to maintain the mechanical integrity of the process. 4.6 Management of Change (40 CFR 68.75) The Linden LPG Storage Plant has a system to manage changes to the LPG storage process. This system requires that changes to items such as process equipment, chemical technology (including process operating conditions), procedures, and other facility changes be properly rev iewed and authorized before implementation. Changes are reviewed to (1) ensure that adequate controls are in place to manage any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated to incorporate changes. In addition, operating and maintenance personnel are provided any necessary training on the change. 4.7 Pre-Startup Safety Review (40 CFR 68.77) PSE&G conducts a Pre-Startup Safety Review (PSSR) for any facility modification that requires a change in the process safety information for the LPG storage process not covered by management of change procedures. The purpose of the PSSR is to ensure safety features, procedures, personnel, and equipment are appropriately prepared for startup prior to placing the equipment into service. This review provides one additional check to make sure construction is in accordance wit h the design specifications and all supporting systems are operationally ready and serves a quality assurance function by requiring verification that accident prevention program requirements are properly implemented. Upon completion of the PSSR, the Program document will be updated as required. 4.8 Compliance Audit (40 CFR 68.79) To help ensure that the accident prevention program is functioning properly, the gas plant periodically conducts an audit to determine whether the procedures and practices required by the Risk Management Program are being implemented. Compliance audits are conducted at least every three years. The audit team develops findings that are forwarded to gas plant management for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained. 4.9 Incident Investigation (40 CFR 68.81) The Linden LPG Storage P lant promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, gas release, major property damage or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to gas plant management for resolution. The incident investigation team will begin investigating no later than 48 hours following the incident and summarize the investigation in a report. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. The final resolution of each finding or recommendation is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are r etained for at least five years so that the reports can be reviewed during future PHAs and PHA revalidation. 4.10 Employee Participation (40 CFR 68.83) PSE&G encourages employees to participate in all facets of the Risk Management Program. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team. Employees have access to information created as part of the Risk Management Program document. In addition, the plant has a number of initiatives that addresses risk management and employee safety issues. These initiatives include forming teams to promote both process and personal safety. The teams have members from various areas of the plant, including operations, maintenance, engineering, and plant management. All PSE&G employees assigned to work at the Linden LPG Storage Plant will have access to the Program Manual which is located in the Metering & Regulating ( M&R) office at the Linden LPG Storage Plant site and at the main office of the Harrison Gas Plant. 4.11 Safe Work Practices-Including Hot Work Permits (40 CFR 68.85) The PSE&G Linden LPG Storage Plant has long-standing safe work practices in place to help ensure worker and process safety. Examples of these include (1) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (2) a procedure for safe removal of hazardous substances before process piping or equipment is opened, (3) a permit and procedure to control spark-producing activities (i.e., hot work), and (4) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. PSE&G M&R tagging supplemented by gas plant-specific procedures and hot work procedures, along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely. 4.12 Contractors (40 CFR 68.87) The PSE&G L inden LPG Storage Plant uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the gas plant has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules and (6) inform gas plant personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements and (4) safe work practices prior to their beginning work. In addition, the PSE&G Linden LPG Storage Plant evaluates contractor safety programs and performance during the selection process. Gas plant personnel periodically monitor contract or performance to ensure that contractors are fulfilling their safety obligations. Contractors are required to implement health and safety programs that protect their employees, comply with appropriate laws, regulations, codes, industry standards and local requirements and minimize risks to PSE&G employees. Prior to employing an outside contractor to perform maintenance, repair, major renovation, or specialty work management evaluates the contractors safety performance and programs. Contract employees are informed of the potential hazards such as fire and explosion that is related to their work. They are made aware of emergency action plans and procedures. This information is documented and maintained. All contract employees will follow the safe work practices of the facility. A daily contractor log is maintained on site that is located in the LPG Operators Office in the Materials Testing Lab. This log documents the presence and exit of contract employees. A record of all contra ctor illness and injuries related to work in the process area also be maintained. Overview of Five Year Accident History The PSE&G Linden LPG Storage Plant has an excellent record of accident prevention over the past 5 years. The facility has not had an accidental release of propane in the last 5 years. Should an accidental release occur, PSE&G would investigate every incident very carefully to determine ways to prevent similar incidents from recurring. Overview of Emergency Response Program Information The PSE&G Linden LPG Storage Plant maintains a written emergency response program, which is in place to protect worker and public safety as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if a flammable substance is accidentally released. The procedures address all aspects of emergency response, including proper first aid an me a treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post-incident cleanup and decontamination requirements. In addition, the plant has procedures that address maintenance, inspection, and testing of emergency response equipment, as well as instructions that address the use of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is updated when necessary based on modifications made to gas plant processes or other PSE&G Linden LPG Storage Plant facilities. The emergency response program changes are administered through the management of change process, which includes informing and/or training affected personnel in the changes. The overall emergency response program for the PSE&G Linden LPG Storage Plant s coordinated with the Linden Local Emergency Planning Committee (LEP C). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and industry representatives. The PSE&G Linden LPG Storage Plant has around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. |