East Syracuse Propane - Executive Summary |
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Executive Summary Agway Energy Products East Syracuse Propane 1. Accidental Release Prevention and Emergency Response Policies The primary function of Agway Energy Products East Syracuse Propane 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 inherent safety of our distribution facility. This facility complies with NFPA-58 requirements for LP-Gas storage, a nd it is our policy to adhere to all applicable federal, state, and local laws. In addition to the presence of appropriate controls to prevent possible releases of propane, if a release does occur, we are coordinated with East Syracuse 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 transport and is stored in one 18,000-gallon storage tank. This facility has equipment for transports and equipment to load bobtails. Access to this site is restricted to authorized facility employees, authorized management personnel, and authorized contractors. Agway Energy Products - East Syracuse Propane is an unmanned facility with no employees stationed at this site. The regulated substan ce handled at this facility is propane. The maximum amount of propane that can be stored at this plant is 67,000 lb. 3. The Worst Case and Alternative Release Scenarios, Including Administrative Controls and Mitigation Measures to Limit the Distances for Each Reported Scenario We have calculated worst case release scenarios using the EPAs RMP Comp software program. For alternative release scenario analyses, we have employed the equations provided by the EPA in the RMP Guidance For Propane Storage Facilities and used RMP Comp. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for propane involves a catastrophic release from propane storage. The scenario involves the release of 67,000 lb. of propane. The release quantity has been limited by 88 percent resulting from written procedural mechanisms. It is assumed that the entire quantity of our largest propane storage tank is released as a vapor that finds an ignition s ource, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather, the maximum distance of 0.3 miles was obtained corresponding to an endpoint of 1 psi overpressure. The alternative release scenario involves a hose rupture and failure of safety devices that allows a release from propane storage resulting in a vapor cloud explosion. In this scenario, 17,056 lb. of propane is released from a 3-inch diameter hose for 1 minute. Under neutral weather conditions, the maximum distance to the 1 psi overpressure endpoint is 0.1 miles. 4. The General Accidental Release Prevention Program and 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, 1967 Edition, and state law. The following sections briefly describe the release preve ntion program that is in place at our stationary source. Safety Information Agway Energy Products East Syracuse Propane 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, and 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 regular intervals, at least every 5 years. Any findings related to the hazard reviews are addressed in a safe and timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, Agway Energy Products East Syracuse Propane maintains written operating procedures. These procedures address various modes of operation 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 Agway Energy Products East Syracuse Propane 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 receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently. Refresher training is provided at least every 3 years and more frequently as needed. Maintenance Agway Energy Products East Syracuse Propane 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 checks are corrected in a safe and timely manner. Compliance Audits Agway Energy Products East Syracuse Propane will conduct audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits will be 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 Agway Energy Products East Syracuse Propane promptly investigates any incident that has resulted, 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 Histor y Agway Energy Products East Syracuse Propane 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 that has caused deaths, injuries, significant property or environmental damage, evacuations, or sheltering in place. 6. Emergency Response Plan Employees of Agway Energy Products East Syracuse Propane do not respond to accidental releases of propane. Response actions are coordinated with the East Syracuse Fire Department and appropriate mechanisms are in place to notify emergency responders when there is a need for a response. 7. Planned Changes to Improve Safety Agway Energy Products East Syracuse Propane maintains preventative safety guidelines that are adhered to by all employees. Safety devices at this facility include excess flow valves and manual and automatic shutoffs. Routine safety inspections of tanks, valves, piping, and hoses are performed to ensure that our equipment remains in good operating condition. In addition, transports and bobtails that arrive at this facility are outfitted with air brake interlock systems to prevent pull away accidents that could result in a release. |