Gas Supply Resources, Inc. - Auburn Terminal - Executive Summary |
|
GENERAL EXECUTIVE SUMMARY FOR PROPANE STORAGE DISTRIBUTION FACILITY Gas Supply Resources, Inc. - Auburn Terminal 1. Accidental Release Prevention and Emergency Response Policies: The primary function of Gas Supply Resources, Inc. - Auburn Terminal is to act as a propane distribution facility. By virtue of the flammable effect 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 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. In addition to the presence of appropriate controls to prevent possible releases of propane, if a release does occur, we are completely coordinated with the Auburn Fire Department, which provides highly trained emergency response personnel to control and mitigate the effects of the release. 2. The Stationary Source and The Regulated Substance Handled: The primary purpose of this facility is to repackage and distribute propane to wholesale customers for use as a fuel. Propane arrives at our facility via rail car and is stored in two (2) storage tanks. This facility has equipment for unloading rail cars and transports and for loading transports. Access to this site is restricted to authorized facility employees, authorized management personnel, and authorized contractors. The regulated substance handled at this facility is prop ane. The maximum amount of propane that can be stored at this facility is 443,520 lbs. 3. The Flammable Worst Case Release Scenario and the Alternative Release Scenario, Including Administrative Controls and Mitigation Measures to Limit the Distance for Each Reported Scenario: We have calculated the worst case release scenario based on EPA's RMP Com (TM) method. The alternative release scenario analysis is based on EPA's RMP Com (TM) method. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for propane involves a catastrophic release from the storage tanks. The scenario involves the release of 443,520 lbs. of propane. The release quantity has been calculated with a wind speed of 1.5 meters/second, stability class: F and an air temperature of 25 degrees C., The estimated distance to 1 psi overpressure is .60 miles. The alternative release scenario involves a release from the rail tower header piping resulting in a vapor cloud fire. In this scenario 1,995 lbs. of propane is released in one minute. This release is also controlled by active mitigation measures that include monitor fire nozzles, emergency shutdown valves, and manual valves. With a wind speed of 3 meters/second, stability Class: D and an air temperature of 25 degrees C. the estimated distance to lower flammability limit is .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 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NFPA-58 Standard, 1995 Edition and NFPA-70, 1993 Edition. The following sections briefly describe the release prevention program that is in place at our stationary sources. Safety Information: Gas Supply Resources, Inc. - Auburn 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: A visual inspection 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. Any finding related to the hazard reviews are addressed in a safe and timely manner. Operating Procedures: For the purposes of conducting safety activities within our covered processes, Gas Supply Resources, Inc. - Auburn Terminal maintains written operating procedures. These procedures address various modes of operation such as emergency shutdown system/ startup procedures, pre-operational visual inspection procedures, rail car unloading procedures, transport loading procedures, transport unloading procedures, and emergency shutdown system/ shutdown procedures. The information is regularly reviewed and readily accessible to operators involved with the processes. Training: Gas Supply Resources, Inc. - Auburn Terminal has a comprehensive training program in place to ensure that employees 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 and have passed a written proficiency test. Refresher training is provided yearly. Maintenance: Gas Supply Resources, Inc. - Auburn Terminal carries out 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: Gas Supply Resources, Inc. - Auburn Terminal 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 action required as a result of the audits is undertaken in a safe and prompt manner. Incident Investigation: Gas Supply Resources, Inc. - Auburn 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: Gas Supply Resources, Inc. - Auburn Terminal has had an excellent record of preventing accidental releases over the last four years (the facility was constructed in 1996). Due to our stringent release prevention policies, there has been no accidental relea se during this period. 6. Emergency Response Plan: Gas Supply Resources, Inc. - Auburn Terminal has a written emergency response plan to deal with accidental release of propane. The plan includes all aspects of emergency response including evacuations and notification of local emergency response agencies. Our facility's emergency response plan is based upon the MPGA's LP-Gas Handbook/Guidelines for Developing Plant Emergency Response Procedures/How to Control LP-Gas Leaks and Fires. 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. 7. Planned Changes to Improve Safety: Several developments and findings have resulted in the implementation of the various elements of our accidental release prevention program. Continued operator training, employee CTEP certification, an d operational reviews are some of the major steps we want to take to improve safety at our facility. These changes shall be implemented on an ongoing basis. 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: James L. Peschong Signature: Title: Director of Engineering Services Date Signed: June 9, 2000 |