Gas Supply Resources, Inc. - York Terminal - Executive Summary

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GENERAL EXECUTIVE SUMMARY FOR PROPANE STORAGE AND DISTRIBUTION FACILITY 
Gas Supply Resources, Inc. - York Terminal 
 
1.  Accidental Release Prevention and Emergency Response Policies: 
 
The primary function of Gas Supply Resources, Inc. - York 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 safety of our distribution facility. 
Our emergency response 
program is based upon the NPGA's LP-Gas Safety Handbook/ Guidlines 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 Spring Garden Township 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 distrute propane to wholesale customer for use as  
a fuel.  Propane arrives at our facility via rail car and transport and is stored in five (5) storage tanks.  This  
facility has equipment for unloading rail cars and transport and equipment to load transport trucks.  This  
facility does not load bobtails or containers.  Access to this site is restricted to authorized facility  
empolyees, authorized management p 
ersonnel 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 544,400 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 Comp (TM) method.  The  
alternative release scenario analysis, we have also utilized the EPA's RMP Comp (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 544,400 lbs. of propane.  The release quantity has been calculated with a wind speed of 1.5 meters/sec, stability class: F, and an air temperature of 25 degrees C.  The estimated distance to 1 psi overpressure is .70 miles. 
 
The alternative release scenario involves a release from the rail tower header piping resulting in a vapor  
cloud fire.  In this scenario 3,150 lbs. of propane is released in one minute.  This release is also controlled  
by active mitagation measures that include a monitor fire nozzle, emergency shutdown valves and manual  
valves.  With a wind speed of 3 meters/second, stability Class: D, and an air temperature of 25 degress 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/ NFPA-70 Standard, 1993 Edition. 
The following sections briefly describe the release prevention program that is in place at our stationary  
source. 
 
Safety  
Information: 
 
Gas Supply Resources, Inc. - York 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. - York 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 is readily accessible to operators involved with the processes. 
 
Training: 
 
Gas Supply Resources, Inc. - York Terminal has a comprehensive training program in place to ensure that  
employees are completely competent in the operating procedures associated with these processess.  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. - York 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 check 
s are corrected in a safe and timely  
manner. 
 
Compliance Audits: 
 
Gas Supply Resource, Inc. - York Terminal conducts audits on a regular basis to determine whether the  
provisions set out under the RMP rules 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: 
 
Gas Supply Resources, Inc. - York 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. - York Terminal has had an excellent record of preventing accidental releases  
over the last 5 years.  Due to our stringent release preventi 
on policies, there has been no accidental  
release during this period. 
 
6.  Emergency Response Plan: 
 
Gas Supply Resources, Inc. - York Terminal has a written emergency response plan to deal with  
accidental releases of propane.  The plan includes all aspects of emergency response including  
evacuation, and notification of local emergency response agencies. 
Our facility's emergency response plan is based upon the NPGA's LP-Gas Handbook/ Guidelines for  
Developing Plant Emergency Response Procedures/How to Control LP-Gas Leaks and Fire. 
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 various elements of our  
accidental release prevention program.  Continued opera 
tor training, employee CTEP certification training  
and 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
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