Ferrell North America Aberdeen, NC - Executive Summary |
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General Executive Summary for Chemical, Manufacturing, and Oil Refining Facilities The Employees at Ferrell North America (FNA) Aberdeen, N.C. 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 108 Van Place. 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 tru ck, railcar, or pipeline and offloaded into storage tanks. Propane is distributed from our storage by transports to wholesale customers. No other RMP regulated substances are handled at this facility. To evaluate the worst case scenarios, we have used the EPA's Offsite Consequence Analysis Guidance Reference Tables or Equations. For alternative release scenario analyses we have employed the EPA's RMP Guidance for Propane Storage Facilities Reference Tables or Equations. The following paragraphs provide details of the chosen scenarios. In accordance with RMP guidelines, the Worst Case Scenario for this facility is a vapor cloud explosion of our largest propane storage tank. In this scenario, 108,000 pounds of propane is released. The release quantity has been limited to 80 percent of the maximum capacity of the source by a system of administrative controls. This is estimated to cause a 1psi overpressure that would be felt up to .40 miles away. No credit for mitigation systems was considered in this case. This system is equipped with safety devices to prevent accidental releases, including automatic shutoff valves that respond to excess flow and fire exposure. The alternative release scenario is based on a "pull-away" incident caused by a propane transport truck driving away while still connected to the loading or unloading system by a 2-inch hose. This system is equipped with manual shutoff systems to allow safe remote shutoff. The quantity of propane released in this incident was calculated by assuming a liquid full hose and that shutoff would not occur instantly. This incident was used in an attempt to obtain a release quantity sufficient to predict an offsite impact in a vapor cloud explosion. No credit for mitigation systems was considered in this case. The predicted impact distance for a 1psi overpressure is .2 miles for a 15,900 pound propane release resulting in a vapor cloud explosion. 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, 1998 Edition. The elements of the release prevention program that are in place at our facility include Process Safety Information, Process Hazard Analysis, Operating Procedures, Training, Mechanical Integrity, Management of Change, Compliance Audits, Incident Investigation, Employee Participation, and Contractor selection. Ferrell North America,Aberdeen, N.C 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. Due to our limited staff, FNA does not perform emergency response as defined by EPA RMP rules. Our Employees perform incidental response, which is limited to actions that can be safely taken to stop or prevent a minor release of propane. In the event of a major r elease 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 and rail operations. There are no current plans to change our plant configuration. |