Pacific Energy Group - Executive Summary |
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1. Accidental release Prevention And Emergency Response Policies The primary function of Pacific Energy 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 commited to employee, public and enviromental 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 progam is based upon the (NPGA's LP-Gas Safety Handbook/ Guidelines for Development Plant Emergency Procedures/ How to control LP- Gas Leaks and Fires ). In addition to the pressence of appropriate controls to prevent possible releases of propane, if a release does occur, we are completely coordinated with Barstow City 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 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/ truck and is stored in 2 storage tanks. This facility has equipment for unloading rail cars and transports and equipment to load transports and containers. Access to this site is restricted to authorized contractors. The regulated substances handled at this facility is propane. The maximum amount of propane that can be stored at this plant is 232,640 lbs. 3.The worst Case Release Scenario(s) and the Alternative Release Scenario(s), Including Administ rative controls and mitigation measures to limit the distance for each reported scenario. We have calculated worst case release scenarios based on the the RMP offsite consequence guidance. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for propane involves a catastrophic release of propane. The scenario involves the release of 116,589 lbs. of propane. 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 .40 miles was obtained corresponding to a flammable endpoint of 1 psi overpressure. The alternative release scenario submitted for program 2 flammable substance involves a release of propane resulting in a vapor cloud fire. In this scenario 1400 lbs of propane is released in 10 minutes. The release is also controlled by active mitigation measures that inclu de excess flows valves. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is .10 miles. 4.The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps. Our facility has taken all 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, 1998 Edition/ California title 8. The following sections briefly describe the release prevention program that is in place at our stationary source. SAFETY INFORMATION Pacific Energy 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 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 1 year. Any findings related to the hazard reviews are addressed in a safe and timely manner. OPERATING PROCEDURES For the purpose of safely conducting activities within our covered processes, Pacific Energy maintains written operating procedures. These procedures address various modes of operations 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. TRAINING Pacific Energy 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 rec ieve basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently. Refresher training is provided every year and more frequently as needed. MAINTENANCE Pacific Energy 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. Any equipment deficiences identified by the maintenance checks are corrected in a safe and timely manner. COMPLIANCE AUDITS Pacific Energy 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 Pacific Energy 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 Pacific Energy 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 Pacific Energy caries 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 responsse plan is based upon the NPGA's LP-gas Handbook / Guidelines for Developing Plant Emergency Response Procedures/ How to Control LP-G as 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 from the implementation of the various elements of our accidental release prevention program. we are currently in compliance with all local and federal regulations. Certification Letter Certification Statement for Program Level 2 Processes To the best of the undersigned's knowledge, information, and belief formed after reasonable inquiry, the information submitted is true, accurate, and complete. __________________ James Weaver Signature Print Name Vice President June 6, 2000 Title Date Certification Letter Certification Statement for Program Level 2 Processes To the best of the undersigned's knowledge, information, and belief formed after reasonable inquiry, the information submitted is true, accurate, and complete. _________________________________ _________________________ Signature Print Name _________________________________ _____________ Title Date |