Silgas Terminal - Executive Summary

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General Executive Summary for Propane Storage and Distribution Facilities of Silgas Terminal, Seymour, Indiana 
1.    Accidental Release Prevention and Emergency Response Policies 
The primary function of Silgas Terminal is to act as a propane distribution facility.  By virtue of the flammable effects associated with propane, it is necessary to observe certain safety precautions in handling propane to prevent unnecessary human exposure, to reduce the threat to our own personal health as well as the health of our co-workers, and to reduce the threat to nearby members of the community.  We are strongly committed to employee, public and environmental safety.  Safety at our facility depends upon the manner in which we handle propane as well as on the various safety devices incorporated into the design of our equipment.  Furthermore, comprehensive training received by our employees adds to the inherent safety of our distribution facility. 
Our emergency response program is based upon the NPGA's 
LP-Gas Safety Handbook, Guidelines for Developing Plant Emergency Procedures, How to Control LP-Gas Leaks and Fires, State and Local Regulations, and Company Policy.  In addition to the presence of appropriate controls to prevent possible releases of propane, if a release does occur, our highly trained local emergency response personnel are at hand to control and contain the effects of the release.  We are also completely coordinated with Jackson County LEPC which provides additional emergency response expertise. 
2.    The Stationary Source and the Regulated Substances Handled 
The primary purpose of this facility is to repackage and distribute propane to both retail and wholesale customers for use as a fuel.  Propane arrives at our facility via pipeline and transport and is stored in       21,000,000 gallon underground cavern and in 40-34,500 gallon aboveground storage tanks.  This facility has equipment for unloading transports, receiving propane from pipeline facilities and equipment 
to load  
transports and containers.  Access to this site is restricted to authorized facility employees, authorized management personnel and authorized contractors.  
The regulated substance handled at this facility is propane.  The maximum amount of propane that can be stored at this plant is 83,504,256 lb., comprised of 78,355,200 lb. in underground cavern and 5,149,056 lb. in aboveground storage tanks. 
3.    The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), Including Administrative Controls and Mitigation Measures to Limit the Distances for Each Reported Scenario. 
We have calculated worst case release scenarios based on the EPA's Guidance for Propane Storage Facilities Reference Tables or Equations energy method.  For alternative release scenario analyses, we have employed the equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance.  The following paragraphs provide details of the chosen scenarios. 
The worst case release scenario subm 
itted for propane involves a catastrophic release from Propane Storage.  The scenario involves the release of 128,726 lb. of propane. The release quantity has been limited by 10 percent resulting from written procedural mechanisms.  It is assumed that the entire quantity is released as a vapor that finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion.  Under worst case weather, the maximum distance of 0.04 miles was obtained corresponding to a flammable endpoint of 1 psi overpressure.   
The alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from Propane Storage resulting in a Vapor Cloud Fire.  In this scenario 200 lbs. of propane liquid is released in 5 minutes.  Passive mitigation controls such as fusible links are taken into account to calculate the scenario.  The release is also controlled by active mitigation measures that include excess flow valve(s).  Under neutral weather con 
ditions, the maximum distance to the flammable endpoint of the lower flammability limit of 2.1% volume is,  <0.1 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 EPA.  This facility was designed and constructed in accordance with NFPA-58 Standards and  State and Local Codes.  
The following sections briefly describe the release prevention program that is in place at our stationary source. 
Safety Information 
Silgas Terminal maintains a detailed record of written safety information, which describes the chemical hazards, operating parameters and equipment designs associated with all aspects of our distribution facility.   
Hazard Review 
Our Safety Audit Checklist methodology is used to carry out hazard reviews at our facility. The reviews focus on operating procedures, equipment functions a 
nd handling practices to identify possible hazards.  The studies are undertaken by a team of qualified personnel with extensive knowledge of facility operations and are revalidated at a regular interval of 2 years.  Any findings related to the hazard reviews are addressed in a safe and timely manner. 
Operating Procedures 
For the purposes of safely conducting activities within our covered processes, Silgas Terminal 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 with the processes. 
Silgas Terminal has a comprehensive training program in place to ensure that employees that are operating processes are completely competent in the operating procedures associated with these processes.  New employee 
s receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently.  Refresher training is provided at least every 3 years and more frequently as needed.   
Silgas Terminal carries out highly documented maintenance checks on process equipment to ensure proper functioning.  Maintenance activities are carried out by qualified personnel with previous training in these practices.  Furthermore, personnel are offered specialized training as needed.  Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. 
Compliance Audits 
Star Gas Propane, L.P. conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented.  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 
Silgas Terminal  
promptly investigates any incident that has resulted in, or could reasonably result in, a catastrophic release of propane. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from recurring.  All reports are retained for a minimum of 5 years. 
5.    Five-year Accident History 
Silgas Terminal 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 
Silgas Terminal carries a written emergency response plan to deal with accidental releases of propane.  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. 
Our facility's emergency response plan is base 
d upon the NPGA's LP-Gas Handbook, Guidelines for Developing Plant Emergency Response Procedures, How to Control LP-Gas Leaks and Fires, State and Local Codes, and Star Gas Propane, L.P. Safety & Operating Procedures. 
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.          
Jackson County is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 
7.    Planned Changes to Improve Safety 
Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program.    The replacement of storage tank relief valves are some of the major steps we want to take to improve safety at our facility.  These changes shall be implemented by August 31, 2000. 
8.    Certificatio 
n Statement 
The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. 
Name:        John Ponder 
Title:        Silgas Terminal Manager 
Date signed:    12/14/99
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