Suburban Propane - Elk Grove, CA. - Executive Summary

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General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities 
 
1.    Accidental Release Prevention and Emergency Response Policies 
We at Suburban Propane - Elk Grove, CA. are strongly committed to employee, public and environmental safety.  This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility.  It is our policy to implement appropriate controls to prevent possible releases of regulated substances. 
 
 
2.    The Stationary Source and the Regulated Substances Handled 
Our facility's primary activities encompass LP gas Distribution - Wholesale.  We have one regulated substance present at our facility.  These substances include  and Propane.  Propane is used for LP Gas Distribution - Wholesale. 
 
3.    The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administra 
tive controls and mitigation measures to limit the distances for each reported scenario 
To evaluate the worst case scenarios, we have used the HSE (Health and Safety Executive Methodology).  For alternative release scenario analyses we have employed the EPA's OCA Guidance Reference Tables or Equations.  The following paragraphs provide details of the chosen scenarios. 
 
The worst case release scenario submitted for Program 2 and 3 flammable substances as a class involves a catastrophic release from LP Gas Storage.  In this scenario 48112075 lbs. of Propane is released into its diked area.  The release quantity has been limited to 100% of the maximum capacity of the source by a system of administrative controls. The released quanitity is liquid. Eventually the liquid will vaporize and presumably find an ignition source. It is assumed that 3 percent of the released quantity will be involved in a vapor cloud explosion.  Under worst case weather conditions, the calculated distance of 0.50 m 
iles is obtained corresponding to an endpoint of 1 psi overpressure. 
 
One alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from LP Gas Storage.  The release is assumed to result in a Vapor Cloud Explosion.  The scenario involves the release of 21,000.00 lb. of Propane in 10  minutes.  Passive mitigation controls such as sprinkler system(s) and Water Monitors are taken into account to calculate the scenario.  The release is also controlled by active mitigation measures that include sprinkler system(s) and Water Monitors.  Under neutral weather conditions, the maximum distance to the endpoint of 1 psi overpressure is 0.15 miles. 
 
Another alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from LP Gas Storage.  The release is assumed to result in a Vapor Cloud Explosion.  The scenario involves the release of 1297.56 lb. of Propane in 10  minutes.  Passive mitigation controls such as sprinkler  
system(s) and Water Monitors are taken into account to calculate the scenario.  The release is also controlled by active mitigation measures that include sprinkler system(s) and Water Monitors.  Under neutral weather conditions, the maximum distance to the endpoint of 1 psi overpressure is 0.06 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 requirement set out under 40 CFR part 68 of the EPA.  This facility was designed and constructed in accordance with API Standards, NFPA 58, and building codes in effect at time of constricution..    The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. 
 
Process Safety Information 
Suburban Propane - Elk Grove, CA. maintains a detailed record of safety information that describes the chemical hazards, operating parameters and e 
quipment designs associated with all processes. 
 
Process Hazard Analysis 
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently.  The methodology used to carry out these analyses is HAZOP.  The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of 5 years. Any findings related to the hazard analysis are addressed in a timely manner.  The most recent PHA/update was performed on 06/14/1996. 
 
Operating Procedures 
For the purposes of safely conducting activities within our covered processes, Suburban Propane - Elk Grove, CA. 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 an 
d is readily accessible to operators involved in the processes. 
 
Training 
Suburban Propane - Elk Grove, CA. has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes.  Refresher training is provided at least every 3 years and more frequently as needed. 
 
Mechanical Integrity 
Suburban Propane - Elk Grove, CA. carries out highly documented maintenance checks on process equipment to ensure proper operations.  Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps.  Maintenance operations are carried out by qualified personnel with previous training in maintenance practices.  Furthermore, these personnel are offered specialized training as needed.  Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely ma 
nner. 
 
Management of Change 
Written procedures are in place at Suburban Propane - Elk Grove, CA. to manage changes in process chemicals, technology, equipment and procedures.  The most recent review/revision of maintenance procedures was performed on 06/15/1998.  Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. 
 
Pre-startup Reviews 
Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Suburban Propane - Elk Grove, CA..  The most recent review was performed on 06/06/1997.  These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. 
 
Compliance Audits 
Suburban Propane - Elk Grove, CA. conducts audits on a regular basis to determi 
ne whether the provisions set out under the RMP rule are being implemented.  The most recent comliance audit was conducted on 06/15/1998.  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 
Suburban Propane - Elk Grove, CA. promptly investigates any incident that has resulted in, or could reasonably result in, a catastrophic release of a regulated substance.  These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring.  All reports are retained for a minimum of 5 years. 
 
Employee Participation 
Suburban Propane - Elk Grove, CA. truly believes that process safety management and accident prevention is a team effort.  Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements.  In addition, 
our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. 
 
Contractors 
On occasion, our company hires contractors to conduct specialized maintenance and construction activities.  Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out.  Suburban Propane - Elk Grove, CA. has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes.  Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 
 
 
5.    Five-year Accident History 
Suburban Propane - Elk Grove, CA. 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. 
 
6.    Emergency Response P 
lan 
Suburban Propane - Elk Grove, CA. carries a written emergency response plan to deal with accidental releases of hazardous materials.  The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. 
 
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. 
 
Elk Grove Fire Department is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 
 
7.    Planned Changes to Improve Safety 
Any time developments and findings result from the implementation of the various elements of our accidental release prevention program; improvements to the Elk Grove process will  
be performed. These changes will be implemented immediately upon identification during audits, routine maintenance, and normal plant obersavation.
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