Dome Pipeline Corporation - Carrington Terminal - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES |
At Dome Pipeline Corporation - Carrington 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 our 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 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. 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 iden
tified as having the potential to cause significant offsite consequences in the event of a substantial accidental release:
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 mitigation measures to limit the exposure distances for each scenario:
Worst-case Release Scenario(s) - Regulated Toxic Chemicals
Alternative Release Scenario(s) - Regulated Toxic Chemicals
Worst-case Release Scenario(s) - Regulated Flammable Chemi
Scenario addressed within body of report.
Alternative Release Scenario(s) - Regulated Flammable Chemicals
Scenario addressed within body of report.
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 address each of the key features of successful prevention programs including:
* Process safety information
* Process hazard analysis
* Operating procedures
* Mechanical integrity
* Management of change
* Pre-startup review
* Compliance audits
* Incident investigation
* Employee participation
* Hot work permit
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.
DOME PIPELINE 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 contributing 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 requir
ed 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 regard
ing emergency preparedness.
Dome Pipeline Corporation'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 system .
Reduce number of fittings and eliminate unused equipment in ethyl mercaptan system.
Install relief check valve around loading pump discharge check valve
The undersigned certifies that, to the best of my knowledge, information, an
d belief, formed after reasonable inquiry, the information submitted in this RMPlan is true, accurate, and complete.
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:
Offsite consequence analysis
Five-year accident history
Program 3 prevention program
Emergency response program