Keystone Propane Service, Inc. - Executive Summary |
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General Executive Summary for Propane Storage and Transfer Facility Keystone Propane Service, Inc. Tobyhanna, PA 1. Accidental Release Prevention and Emergency Response Policies The primary function of Keystone Propane Service is to act as a propane terminal 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 in formation contained in federal regulations (29 CFR 1910.38), as well as National Propane Gas Association technical bulletins (Developing Plant Emergency Procedures). In addition to the presence of appropriate controls to prevent possible releases of propane, if a release does occur, we are completely coordinated with Union Township Fire Department and the Coolbaugh Fire Department, which provide trained emergency response personnel to control and mitigate the effects of the release. 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 rail car and is stored in two 60,000 storage tanks. This facility has equipment for unloading rail cars and equipment to load transport trucks. Access to this site is restricted to authorized facility employees, authorized management personnel and authorized contractors. T he regulated substance handled at this facility is propane. The maximum amount of propane that can be stored at this plant is 443,520.00 lb. 3. The Worst Case Release Scenario and two Alternative Release Scenarios, Including Administrative Controls and Mitigation Measures to Limit the Distances for Each Reported Scenario We have calculated worst case release scenarios based on the NPGA-EPA approved TNO-Multi energy method. For alternative release scenario analyses, we have employed the look-up tables and 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 submitted for propane involves a catastrophic release from Propane Storage involving the largest single container which results in a Boiling Liquid Expanding Vapor Explosion, or BLEVE. The scenario involves the release of 221,760 lb. of propane. It is assumed that the entire quantity is released as a vap or 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 0.50 miles was obtained corresponding to a flammable endpoint of 1 psi overpressure. Two alternative release scenarios have been submitted for this Program 2 flammable substance. Alternative Release Scenario #1 involves a release from propane piping system at the rail tower as a result of a rail car pull away resulting in a vapor ignition. In this scenario 93 lb. of propane is released in 10 minutes. The release is also controlled by active mitigation measures that include excess flow valves, emergency shutoff valves, and back flow check valves. Under neutral weather conditions, the maximum distance to the flammable endpoint of 5 kw/m2 for 40 seconds is <0.10 miles. Alternative Release Scenario #2 involves a release from the propane piping system at the transport stanchion as a result of a pull away by the trans port resulting in a vapor cloud ignition. In this scenario 28 lb. of propane is released in 10 minutes. The release is also controlled by active mitigation measures that include excess flow valves, emergency shutoff valves, and back flow check valves. Under neutral weather conditions, the maximum distance to the flammable endpoint of Lower flammability limit is <0.10 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 Title 40 Code of Federal Regulations, Part 68 (EPA). This facility was designed and constructed in accordance with NFPA-58 Standard and all other codes and regulations in effect at the time of installation. The following sections briefly describe the release prevention program that is in place at our stationary source. Safety Information Keystone Propane Service maintains a detailed record o f written safety information, which describes the chemical hazards, operating parameters and equipment designs associated with all aspects of our distribution facility. Hazard Review A checklist methodology is used to carry out hazard reviews at our facility. The reviews focus on operating procedures, equipment functions and 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 intervals. 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, Keystone Propane maintains written operating procedures. These procedures address various modes of operation such as rail car unloading, transport loading, and emergency procedures. The information is regularly reviewed and is readily accessible to operators involved with the p rocesses. Training Keystone Propane 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 employees receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently. Refresher training is provided as needed. Maintenance Keystone Propane carries out regularly scheduled 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 Keystone Propane conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audi ts will be 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 Keystone Propane 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 Keystone Propane has had an excellent record of preventing accidental releases since it's installation in 1997. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan Keystone Propane maintains a written emergency response plan to deal with accidental releases of propane. The plan includes all aspects of emergency response including adequate first aid an d 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. The Coolbaugh Fire Department, the Union Township Fire Department, and the Tobyhanna Army Depot Fire Department are the agencies 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. Continued inspection and increased training are some of the major steps we want to take to improve safety at our facility. These changes shall be implemented by June 1, 2000. 8. Certification 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: Bob Wehrmann Signature: Title: Terminal Manager Date signed: |