Ferrell North America - Adamana, Arizona - Executive Summary

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The Employees at Ferrell North America (FNA), Adamana, Arizona are strongly committed to employee, public, and environmental safety.  This facility is operated to comply with all applicable federal, state, and local laws and is designed and operated in accordance with NFPA 58 Liquefied Petroleum Gas Code requirements.  In addition, FNA operates this facility in accordance with our internal standards that employs good engineering practice and industry accepted principles and codes.  FNA has instituted operating and training procedures that are designed to provide a safe work environment and protect our neighbors. 
FNA operates a propane storage facility located at 113 County Road 7156.  It is comprised of one Risk Management Plan (RMP)-covered process involving propane.  The primary purpose of this facility is to store and distribute propane to wholesale Customers.  All propane is delivered to the facility by truck, railcar, or pipeline and offloaded into underground storage caverns and 
storage tanks.  Propane is distributed from our storage by transports and railcars to wholesale customers.  No other RMP regulated substances are handled at this facility. 
To evaluate the worst-case release scenario and alternative release scenario, we used the EPA's RMP*COMP TM software.  The following paragraphs provide details of the chosen scenarios. 
In accordance with RMP guidelines, the worst-case scenario for a flammable substance release from this   Storage Caverns and Tanks.  In this scenario 298,856 lb. of Propane is released.  The release quantity has been limited to 85% of the maximum capacity of the source by a system of administrative controls.  It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion.  Under worst case weather conditions, the calculated distance of 0.38 miles is obtained corresponding to an endpoint of 1 psi overpressure. 
The altern 
ative release scenario submitted for Program 2 and 3 flammable substances involves a release from Storage Caverns and Tanks.  The alternative release scenario involves the loss of LPG due to a failure of the flexible hosing used to unload transport trucks.  The unloading hose has a nominal diameter of two inches and is 18 feet in length.  There is an excess flow valve located at the connection between the flexible hose and the hard pipe.  A vapor cloud explosion follows the release.  The release was calculated by the following assumptions: when the hose fails, its entire diameter is available for LPG to escape; and, the ruptured hose does not freeze closed and stop or decrease the amount of LPG released.  Because there are safeguards (excess flow valves) in place that will stop the flow of LPG from the holding tanks and from the truck, only the amount of LPG in the hose itself will be available for release.  The hose will release 0.7 pounds of LPG.  This incident was used in an attempt 
to obtain a release quantity sufficient to predict an offsite impact in a vapor cloud explosion.  Active mitigation systems, excess flow valves, were considered in this case.  The distance to the point of 1psig overpressure is 0.004 mile (21ft).  There are no off-site receptors located within this area. The cavern, by virtue of geological and pressure constraints, is considered passively mitigated by the EPA.  There are seven off-site receptors located within this area. This system is equipped with safety devices to prevent accidental releases, including automatic shutoff valves that respond to excess flow and fire exposure. 
Our facility has taken all the necessary steps to comply with the accidental release prevention requirement set out under 40 CFR part 68 of the EPA.  This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition.  The elements of the release prevention program that are in place at our facility include Process Safety Information, Pro 
cess Hazard Analysis, Operating Procedures, Training, Mechanical Integrity, Management of Change, Compliance Audits, Incident Investigation, Employee Participation, and Contractor selection. 
Ferrell North America(FNA), Adamana, Arizona has had an excellent record of preventing accidental releases over the last five years.  Due to our stringent release prevention policies, there has been no accidental release during this period. 
FNA maintains a written emergency response plan based upon OSHA's Emergency Action Plan to deal with accidental releases of propane.  The plan includes evacuating the area, notification of local emergency response agencies, and providing technical assistance when needed.  The Facility's plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response.  FNA does not perform emergency response as defined by EPA RMP rules.  Our Employees perform incidental response, which is limited to ac 
tions that can be safely taken to stop or prevent a minor release of propane.  In the event of a major release or incident such as a fire, our policy is to depend on the Fire Department to respond with the appropriate trained personnel.  We have coordinated emergency response with the Fire Department and have written procedures in place in the event of an emergency. 
We constantly review our propane operations and procedures to improve safety.  Although not finalized, we are researching new monitoring and surveillance equipment to upgrade safety systems for pipeline operations.  There are no current plans to change our plant configuration.
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