Morgan Oil & Propane, Cashiers - Executive Summary |
Executive Summary I) Accidental release prevention and emergency response policies: In this distribution facility, we handle propane which is considered a regulated flammable substance by the EPA. The same properties that make propane valuable as a fuel also make it 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 our co-workers, and to reduce the threat to nearby members of the community. It is our policy to adhere to all applicable federal, state and local rules and regulations. Safety depends upon the manner in which we handle propane combined with the safe handling procedures that we use and the training of our personnel. Our emergency response program is based upon the NPGA's LP-Gas Safety Handbook, "Guidelines for Developing Plant Emergency Procedures" and "How to Control LP-Gas Leaks and Fires". The emergency response plan, if required, includes procedures for notification of the local fire authority and notification of any potentially affected neighbors. II) The stationary source and regulated substances handled: The primary purpose of this facility is to repackage and distribute propane to both retail and wholesale customers. Propane is used by retail customers as a fuel. Propane can be received by truck transports and stored in one aboveground tank. Propane is distributed to retail customers by delivery trucks (bobtails) and to wholesale customers by bobtails and truck transports. The facility pipes propane gas to an industrial facility on the same property. Vaporizing equipment provides low pressure propane to the industrial facility. The industrial facilities fork trucks also use propane as a motor fuel. The industrial facility in not considered under this specific RMP. We also fill Department of Transportation (DOT) containers for retail customers, as needed. This facility has equipment for unloading transports and equ ipment to load bobtails, transports and DOT containers. Access to the site is restricted to authorized facility employees, authorized management personnel and authorized contractors. The regulated substance handled at this distribution facility is propane. The maximum amount of propane that can be stored at this plant is 66,528 pounds. III) The worst-case release scenario(s) and the alternative release scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario. Worst-Case Scenario: - Failure of largest tank when filled to the greatest amount allowed would release 66,528 pounds of propane. Company policy limits the maximum filling capacity of this tank to 88% at 60: F. It is assumed that the entire contents are released as a vapor which finds an ignition source, 10% of the released quantity is assumed to participate in the resulting explosion. The distance to the endpoint of a 1 psi overpressure for the worst case s cenario is 0.30 miles. This distance extends beyond the facility boundary, encompasses several residences and industrial commercial business. Alternative Scenario: - A pull-away causing failure of a 25 foot length of 3 inch hose. The excess flow valves function to stop the flow. The contents of the hose are released. The vapor expands and upon finding an ignition source, it explodes. The 1 psi overpressure is expected to extend 106 feet. The distance to the endpoint of 1 psi for the alternative scenario is 106 feet. This distance extends beyond the facility boundary and encompasses an adjacent public road, and a industrial facility. IV) The general accidental release prevention program and the specific prevention steps. This distribution facility complies with EPA's Accidental Release Prevention Rule and with all applicable federal, state and local codes and regulations. This facility was designed and constructed in accordance with NFPA-58. All drivers have been thoroughly trained using NPGA's Certified Employee Training Program (CETP). V) Five-year accident history. There has been no accidental release or ignition of propane in the last five years. VI) The emergency response program. We have agreed to evacuate the facility employees in the event of a propane gas emergency. Therefore, no emergency response plan is required. However, for facilities with 11 or more employees, a written Emergency Action Plan and a Fire Prevention Plan must be implemented in accordance with OHSA 1910.38. For facilities with 10 or fewer employees the plans may be communicated orally and the employer need not maintain a written plan on site. VII) Planned changes to improve safety. This tank has the year 1978 stamped on the ASME Nameplate. No one is sure when this facility became operational. The present propane company took over operations in 1997. At our next available opportunity to do maintenance work, we will inspect and update to NFPA 1998 standards on a as needed basis. |