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mergency Response
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October 1998
RISK MANAGEMENT
RAM
IDA
40 CFR PART 68)
SMliKKffJWmiM^^
reparedness and Prevention Office
ฃ\ Printed on recycled paper
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Prepared For: Use by owners and operators of Propane Storage Facilities, Implementing Agencies,
and the United States Environmental Protection Agency. , ~
Prepared By: Robert A. Banish, Richard C. Antoff, and Joseph B. Brabson:, Jr. (State of Delaware,
Department of Natural Resources and Environmental Control1 under a cooperative agreement with the
United States Environmental Protection Agency). -
This document provides guidance to help owners and operators of propane storage facilities to
determine if their processes are subject to regulation under section 112(r) of the Clean Air Act and 40
CFR part 68 and to comply with regulations. This document does not substitute for EPA's regulations,
nor is it a regulation itself. Thus; it cannot impose legally binding requirements on EPA, states, or the
regulated community, and may not apply to a particular situation based upon circumstances. This
guidance does not represent final agency action, and EPA may change it in the future, as appropriate.
1 State of Delaware, Department of Natural Resources and Environmental Control, 715 Grantham Lane, New Castle,
Delaware 19720. Telephone (302) 323-4542.
October 22, 1998 ' '. , ,
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TABLE OF CONTENTS
INTRODUCTION .^....: l
WHY SHOULD I READ THIS GUIDANCE? ... . 1
HOW DO I USE THIS DOCUMENT? 2
WHAT SHOULD I DO FIRST? /. ,. '. ....:... 2
WHERE DO I GO FOR MORE INFORMATION? . .'. .......' 4
DEFINITIONS -...,... .- - - ' ..... 5
CHAPTER 1: APPLICABILITY AND PROGRAM LEVELS ... : 7
DOES THIS RULE APPLY TO ME? 7
PROGRAM LEVELS AND APPLICABILITY . 14
DETERMINING PROGRAM 1 ELIGIBILITY 16
PROGRAM LEVEL APPLICABILITY 19
SUMMARY OF PROGRAM REQUIREMENTS 20
CHAPTER 2: OFFSITE CONSEQUENCE ANALYSIS ......... 23
WORST-CASE ANALYSIS . : 23
ALTERNATIVE RELEASE SCENARIOS s 28
DEFINING OFFSITE IMPACTS :.. 30
REVIEW AND UPDATE. 32
APPENDIX 2A - RELEASE CALCULATIONS 34
CHAPTERS; FIVE-YEAR ACCIDENT HISTORY ; 39
WHAT ACCIDENTS MUST BE REPORTED? ... 1 39
WHAT DATA MUST BE PROVIDED? ............ ........ 39
PART 68 INCIDENT INVESTIGATION ..:.....,....... 47
CHAPTER 4: MANAGEMENT ......^...................... .. 49
CHAPTERS: PROGRAM 2 PREVENTION PROGRAM 51
68.48 SAFETY INFORMATION , \ , , .;.... 52
68.50 HAZARD REVIEW 59
68.52 OPERATING PROCEDURES: 66
68.54 TRAINING. ...'.' !...... ....../. 69
68.56 MAINTENANCE ...:.... ; :. 71
68.58 COMPLIANCE AUDITS 81
68.60 INCIDENT INVESTIGATION. .'.. 83
CHAPTER 6: EMERGENCY RESPONSE .. ; 87
,WHATIS RESPONSE?. i........ 88
ELEMENTS OF AN EMERGENCY RESPONSE PROGRAM 89
CHAPTER?: RISK MANAGEMENT PLAN 95
ACRONYMS .'. -..- 97
, October 22,1998
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II I III I I 11
LIST OF TABLES
TABLE 1: TYPICAL WATER CAPACITY OF PROPANE TANKS, TRANSPORTS, AND
RAILROAD TANK CARS 9
TABLE 2: NOMINAL TANK CAPACITY TO POUNDS '. 10
TABLE 3: NOMINAL TANK CAPACITY VS DISTANCE TO ENDPOINT 25
TABLE 4: POTENTIAL DISTANCES TO ENDPOINT FOR PIPE RELEASES ..35
TABLE 5: DISCHARGE LINE BREAKS WHILE PUMPING 36
TABLE 6: RELIEF; VALVE DISCHARGES 37
-:"TABLE 7: PROCESS SAFETY INPORMAflON '."...'.'..".'.'..!.''. '.".'..'.'..."..... .....' 54
,'ง: OPlR^ING PROCEDURE REQUIREMENTS 67
"$'Hijif^^ ' '- 74
,, 5, r,,,v,, , JPJ x^ it): MlKEOT'MVMlllGATION REQUIREMENTS '.' '..........'. 84
JJM'IJV'!?, :"V llitABLl ^]gg^4|NC^.K^ONSE PLAN NPGA REFERENCES -...... 91
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"" '"" "'"' """''" ' ^OSTQFEX^yvlPLES
EXAMPLE 1: USING WORKSHEET 1 FOR USE WITH TABLE 2 12
EXAMPLE 2: USING WORKSHEET 2 TO FIND WORST-CASE DISTANCE TO ENDPOINT . 26
LIST OF WORKSHEETS
WORKSHEET 1 TANK CAPACITY/INVENTORY 13
WORKSHEET 2WORST-CASE DISTANCE TO ENDPOINT 27
WORKSHEETS POTENTIAL ALTERNATiVE RELEASE SCENARIOS 29
WO^H^4 M^AGmS^tSYSTeiA.. 50
WoiSsiEffiEf's 'PROCESSisAFCTYMFbmATiQN J.."...':"."!..".....'..:." 56
WORKSHEET6 MAJORCHANGES . T......... ^........ 58
WORKSHEET 7 EMPLOYEES WORKING PRIOR TO 6/21/99 69
WORKSHEET 8 SAMPLE INCIDENT INVESTIGATION REPORT . 85
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LIST OF CHECKLISTS, BOXES, AND EXHIBITS
EXHIBIT 1 COMPARISON OF PROGRAM REQUIREMENTS 22
HOW TO OBTAIN CENSUS DATA AND LAND VIEW 31
HOW TO OBTAIN USGS MAPS 32
EXHIBIT 2 ^^^PH^^^j^tjy^l: CLASSES .'.... .'i'. 42
Q & A PROPERTY DAMAGE'".'.'".'.7. :.'17.'.'..'..:'.'.".."!:.."."'"..... J................. 43
EXHffirf 3 งMMARฅOF PROGRAM 2 PREVENTIPN PROGRAM '.... 51
HAZARD REVIEW CHECKLIST ..'". 7'.'.."!'.:,.'..'".'....'.. i'T 60
MABSTTENAKCE INSPECTION CHECKLIST AND TESTS 77
WHAT IS^ A LOCAL EMERGENCY PLANNING COMMITTEE? ...'.. 90
October 22,1998
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INTRODUCTION
WHY SHOULD I READ THIS GUIDANCE?
If you handle, store, use, or produce propane in quantities above threshold quantity (10,000 pounds or
2380 gallons) in a single process, you are required to develop and implement a risk management
program as a result of a new rule issued by the U.S. Environmental Protection Agency (EPA). This .
rule, "Chemical Accident Prevention Provisions" (part 68 of Title 40 of the Code of Federal
Regulations (CFR)), applies to a wide variety of facilities that manufacture, store, or use toxic and
flammable substances, including propane. This document provides guidance on how to determine if
you are subject to part 68 and how to comply with part 68. If you are subject to part-68, you must be
in compliance no later than June 21,1999, or the date on.which you first have more than a threshold
quantity of a regulated substance in a process, whichever is later.
The goal of a risk management program is to prevent accidental releases of toxic and flammable
substances that can cause serious harm to the public and the environment and to mitigate the effects of
releases that do occur. The 1990 Amendments to the Clean Air Act (CAA) outline the actions to be
taken by facilities (referred to in the law as stationary sources) to prevent and mitigate accidental
releases of such chemicals into the atmosphere and reduce their potential impact on the public and the
environment.
This guidance is intended to assist facilities that handle or store propane. If you handle or store other
substances (e.g., chlorine, ammonia), you will need to use EPA's General Guidance for Risk
Management Programs, or another industry-specific guidance. If you only store propane for use as a
fuel or you are a retailer who sells a limited quantity of propane stored in a small tanks, you may be ,
able to use EPA's abbreviated Risk Management Program Guidance for Propane Users and Small
Retailers. .
In general, the rule requires the following:
Certain facilities must develop and implement a risk management prpgram and maintain
documentation of the program at the site.
The risk management program must include an analysis of the potential off site consequences
of an accidental release, a five-year accident history, a release prevention program, and an
emergency response program.
; These facilities must develop and submit a risk management plan (RMP) to EPA no later than
June 21, 1999.
The RMP provides a summary of the risk management program implemented at the facility.
The RMP will be available to government agencies and the public.
These facilities are required to update the RMP at least every five years after the initial
submission. ,
October 22,"l 998 '
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Risk Management Program Guidance
HOW DO I USE THIS DOCUMENT?
This document is designed to give owners and operators of propane storage facilities who are subject
to EPA's 40 CFR Part 68 "Accidental Release Prevention Requirements" specific guidance on how
their risk management program can be designed to comply with the EPA rule and on what information
will be required to complete the risk management plan (RMP). The guidance assumes that a propane
distribution facility2 is exempt from OSHA's 29 CFR 1910.119 "Process Safety Management
Standard" (PSM). The format for this model compliance manual is similar to the font type and size
used in the LP-Gases Handbook.;'
The guidance, examples, and commentary are all printed in the same font type and text size that this
particular sentence is printed.
The specific text of the EPA Rule is printed in this font type and size.
Boxes similar to the one on the right indicate that the information you are
developing is used in another section of the guidance.
Used in Chapter 5
Boxes similar to the one on the right indicate that information was
previously developed in another section of the guidance.
WHAT SHOULD 166 FIRST?
j From Chapter 5
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Before plunging into the development of a risk management program, you should go through the eight
steps listed below. This guidance will step you through this process sequentially.
(1) Collect any forms that you may have submitted under Sections 311 and 312 of the
Emergency Planning and Community Right-to-Know Act (e.g., Tier I or Tier If information).
(2) Determine, by noting the water capacity of your individual storage tanks, the total
propane storage capacity of your facility. (See Chapter 1)
(3) Determine if you are covered by this rule, and if you are, how many of your processes are
covered. (See Chapter 1)
, , ,, , , ,. ' , . f ' , ,
Only sources with a threshold quantity of a regulated substance in a process need to comply
with this rule. If you handle other substances in excess of their threshold quantities (such as
acetylene, butane, or ethyl mercaptan), you must develop a risk management program for those
2 An industrial user of propane may be subject to OSHA PSM. Program 3 prevention program is not part of this
guidance. An industrial user subject to OSHA PSM must use EPA's General Guidance for recommendations on 1;he prevention
program. ,
3 National Fire Protection Association (NFPA), L P-Gases Handbook, Fourth Edition 1995.
October 22,1998
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. Risk Management Program Guidance
substances as well as for propane. The EPA rule states that you are to file only, one risk
management plan (RMP) for your facility, so if you have multiple regulated substances in
excess of their threshold quantities, you can use the parts of this guidance that apply to
propane and supplement your RMP with additional information for the other regulated
substances, as described in EPA's General Guidance for Risk Management Programs (40
CFRPart68). Thus, a facility with multiple regulated substances will submit only one RMP,
but will have an individual risk management program appropriate for each regulated substance
and covered process. .'.'' "
(4) Perform the "Offsite Consequence Analysis" to determine your"worst-case" scenario.
(See Chapter 2) .
(5) Determine the appropriate program level for each covered process.
Depending on specific characteristics of your operations, the results of the offsite consequence
analysis, and your accident history, your covered process may be subject to one of three
different sets of requirements (i.e., Programs 1,2, or 3). (See Chapters 1 and 2)
(6) Determine EPA's requirements for your facility and each covered process.
Certain requirements apply to the facility (source) as a whole, while others are process-
specific. '
(7) Assess your operation to identify current risk management activities.
> Because you probably conduct some risk management activities (e.g., employee training,
equipment maintenance, and emergency planning), you should review your current operations
to determine if you are already in compliance with certain provisions of this rule. EPA does
not expect you to "redo" these activities if they already meet the rule's requirements. Note: for
owners and operators of propane storage facilities, this guidance references the NFPA 58,
1998 Edition4 for the mechanical design of the facility.
(8) Review the regulations and this guidance to develop a strategy for conducting the
additional actions you need to take for each covered process. . ,
' This guidance presents a step-by-step approach for propane distributors to follow. It will help
you determine if you are regulated and what actions you need to take to come into compliance
with this rule. , ,
Finally, keep in mind that many of these requirements are performance-based; for EXAMPLE, EPA
does not specify what maintenance must be performed, but allows you to design a maintenance .
program that fits your facility. Your program will be different from everyone else's program because it
will be designed for your specific situation and hazards. It will reflect whether your facility is near the
public and sensitive environmental areas, the specific equipment you have installed, and the
managerial,decisions that you have made. , . '
4 National Fire Protection Association, NFPA 58, "Liquefied Petroleum Gas Code, 1998 Edition.
October22, 1998 ' '
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Risk Management Program Guidance
WHERE DO I GO FOR MORE INFORMATION?
EPA's risk management program requirements may be found in Part 68 of Volume 40 of the Code of
Federal Regulations. A consolidated copy of these regulations is available in Appendix A. EPA is
working with industry and local, state, and federal government agencies to assist sources in complying
with these requirements^ For more information, refer to Appendix E (Technical Assistance).
Appendices C and D also provide points of contact for EPA and OSHA at the state and federal levels
for your questions. Your local emergency planning committee (LEPC) also can be a valuable resource
and can help you discuss issues with the public.
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Fjnally, if you have access to the Internet, EPA has made copies of the rules, fact sheets, and other
related materials available at the home page of EPA's Chemical Emergency Preparedness and
Prevention Office (http://www.epa.gov/cepp6/). Please check the site regularly as additional materials
In are posted. ' *' " ' - '
For more information, call the RCRA, Superfund, &. EPCRA Hotline. The Hotline is a publicly
accessible service that provides up-to-date information on several EPA programs. The Hotline
responds to factual questions on EPA regulations developed under section 112(r) of the Clean Air Act.
The Hotline responds to requests for relevant documents. Anyone can call the Hotline; it offers
information to a broad audience of callers with diverse backgrounds and varying degrees of regulatory
knowledge. To speak with Information Specialists about regulatory questions or to order documents,
call: (800) 424-9346 or DC area local (703) 412-9810 or TDD (800) 553-7672 or TDD DC area local
(703) 412^3325" Monday through Friday 9:00 a.rhl until 6:56 p.mu EST (closed on federal holidays).
October 22,1998
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Risk Management Program Guidance
DEFINITIONS
Propane, in the context of this guidance, means liquefied petroleum gas or LP-Gas. This is a mixture.
It is not a pure substance, but contains propane as its largest single component. For the purppses of the
engineering calculations included in this guidance, the other components of the mixture are assumed to
have a negligible affect.
Propane distribution facilities use a grade of LP-Gas that complies (as a minimum) with the
commercial propane specification issued by the Gas Processors Association (GPA) in Standard 2140-
96. LP->Gas must contain an odorant unless further processing makes addition of the odorant harmful.
Thus, certain industrial users of propane do not use LP-Gas which contains an odorant.
Butane is also sometimes distributed as a fuel and it can be a minor component of LP-Gas. Propane
distribution facilities and industrial users that have butane may adapt this guidance to comply with
EPA's accidental release prevention rules.
NFPA-58 defines Liquefied Petroleum Gas (LP-Gas) as any material having a vapor pressure not
exceeding that allowed for commercial propane composed predominantly of the following
hydrocarbons, either by themselves or as mixtures: propane, propylene, butane (normal butane or
isobutane), and butylenes. -
A process means any activity involving a regulated substance including any use, storage,
manufacturing, handling, or on-site movement of such substances, or combination of these activities.
For the purposes of this definition, any group of vessels that are interconnected, or separate vessels
that are located such that a regulated substance could be involved in a potential release, shall be
considered a single process.
This guidance is meant to assist propane storage facilities with complying with EPA's risk
management rule. One of the most common types of storage facilities potentially subject to EPA's risk
management rule is a propane distribution facility.
A^propane distribution facility as defined by NFPA-58 "[a] facility, the primary purpose of which is
the distribution of gas, that receives LP-Gas by tank car, tank truck, or piping, distributing this gas to
the end user by portable container (package) delivery, by tank truck, or through gas piping. Such
plants have bulk storage tank(s) greater than 2,000 gallons (7.6 m3) water capacity and usually have
container-filling facilities on the premises. Normally, no persons other than the plant management or
plant employees have Access to these facilities. A facility that transfers LP-Gas from tank cars on a
private track directly into cargo tanks is also in this category." This guidance is also applicable to
industrial users of propane who handle or store propane in quantities greater than the threshold
quantity of 10,000 pounds.
Under the above definitions, a propane storage facility having several interconnected LP-Gas storage
tanks (a storage tank is used here to describe LP-Gas storage tanks larger than 2800 gallons of
combined water capacity) would be considered "one" process. Similarly, a propane storage facility .
having several LP-Gas storage tanks or other vessels containing propane, that are not interconnected,
October 22,1998 , . .
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Rigk Management Program Guidance
but are sufficiently close together that they could be involved in a single accident (e.g., if a fire could
involves a number of storage vessels), would also be considered "one" process. Multiple, widely
separated, not interconnected, LP-Gas storage vessels would be considered more than "one" process if
they could not be involved in a single accident. Therefore, propane storage facilities are most likely
going to have only "one" process unless the physical arrangement of the storage tanks precludes
beyond a reasonable doubt the possible mutual involvement of the tanks in any conceivable release
scenario.
Propane storage facility can be any of the following types of facility that stores or handles propane in
quantities greater than the threshold quantity:
A propane distribution facility,
An industrial user of propane
> Those using propane for fuel for building or process heat.
> Those using propane for refrigeration.
> Those using propane as a carrier gas (e.g., an aerosol propellant).
> Those using propane as a chemical feed stock.
An institution (e.g., a hospital or government installation) that uses propane for fuel.
LP-Gas processors conforming to American Petroleum Institute (API) standards rather than NFPA
standards may not rely on this guidance. The checklists are not appropriate for these facilities, because
the checklists are based on NFPA standards. .
October 22.1998
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Risk Management Program Guidance
CHAPTER 1: APPLICABILITY AND PROGRAM LEVELS
DOES THIS RULE APPLY TO ME?
68.10 Applicability
(a) An owner or operator of a stationary source that has more than a threshold quantity of a
regulated substance,in a process, as determined under ง 68.115, shall comply with the requirements
of this part no later than the latest of the following dates:
: (1) June 21, 1999; /
(2) Three years after the date on whiqh a regulated substance is first listed under ง 68.130;
or . ^
(3) The date on which a regulated substance is first present above a threshold quantity in a
process.
You must first determine if your propane storage facility is subject to EPA's Rule "Accident Release
Prevention Requirements: Risk'Manasement Programs Under Clean Air Act Section 112(r)(7T. If _
you store more than 10,000 pounds (2381 gallons @. 60 ฐF) of propane in a process at your facility,
you are subject to the rule. -
How Do I DETERMINE THE AMOUNT OF PROPANE STORED IN A PROCESS AT MY
FACILITY?
To answer the question of whether you are regulated, you need to calculate the total quantity (in
pounds) of propane stored in all your facility's storage tanks that are interconnected or co-located (i.e.,
close enough to be involved in a single accident). If this total quantity exceeds the threshold of 10,000
pounds, you are regulated.
First determine the water capacity of each tank. The nominal nameplate capacity (in gallons of water)
can be found on the "U1A" certificate for the vessel. The VIA certificate is issued to the owner by the
manufacturer of a boiler or a pressure vessel and contains important information relating to the design
and construction of the vessel. Manufacturers may file a copy of this document with the National
Board of Boiler and Pressure Vessel Inspectors5, for future reference by the original or subsequent
owners of the vessel. The nominal nameplate capacity can also be found on the permanently attached
nameplate on your storage tank. The nameplate will also have the National Board Number for your
vessel. This number is key to retrieving your U1A form from National Board. These nameplates are
usually located on one of the hemispherical heads of the vessel, the manway or on the manway cover.
Obtain the nominal capacity for all your tanks from the nameplate or from the U1A form and record
these nominal water capacities in Column 1 of Worksheet 1.
National Board of Boiler and Pressure Vessel Inspectors, 1055 Crupper Avenue, Columbus, OH 43229. Telephone
(614)888-8320. ...'-. - ,
October 22, 1998 ' ,
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Risk Management Program Guidance
secomi step is to calculate the amount of propane you store. The following method can be used to
determine the total amount of propane stored at your facility (the maximum intended inventory).
How TO USE TABLE 2 TO FIND THE MAXIMUM INTENDED INVENTORY
Table 2 summarizes the conversion of nominal water capacity in gallons to pounds of "commercial"
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prbpane @ 60 ฐF so that you may determine the maximum intended capacity of each of your propane
storage tanlc(s)m a process. The multiplier 3.696 (used in Table 2 to convert gallons to pounds) was
developed based on the density of "commercial" propane (4.20 pounds per. gallonฎ) multiplied by the
maximum permitted liquid volume (88% @ 60ฐF7). The inventory in pounds is rounded to the nearest
J^ thousand., If you have written administrative controls that limit the quantity in your vessels to some
other percentage, you should adjust these figures to account for your controls. Base your decision on
the actual maximum quantity that you may have in the vessel, not the maximum capacity of the vessel.
This rule applies to regulated substances that are handled at "stationary sources." Transportation
containers used for storage not incident to transportation and transportation containers connected to
equipment at a stationary source are considered part of the stationary source. Transportation containers
that have been unhooked from/the motive power that deliverecT them to the site (e.g., truck or
locomotive) and left on your site for short-term or long-term storage are part of your stationary source.
For example, if you have railcars on a private siding that you use as storage tanks until you are ready to
hook them to your process, these railcars should be considered to be part of your source. If a tank
truck is being loaded and the motive power is still attached, the truck and its contents are considered to
be in transportation and not covered by the rule. You should count only the substances in the piping or
hosing as well as the quantity in the storage tank.
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Record the amount of propane in pounds from the right column across from the water capacity of your
tank on Worksheet 1. Do this for each of your vessels in the process. Total the amount of propane in
pounds and record this in the box at the bottom of Worksheet 1. You must complete Worksheet 1 for
each propane process at your propane storage facility. The total in the box at the bottom of Worksheet
1 rounded to two significant figures is the maximum inventory for that process and will be the quantity
you list in the registration section of your risk management plan. If you have multiple processes at the
same facility, you are only required to submit one risk management plan, but you are required to list
each process and its quantity separately. If you have multiple facilities, you will have to submit a risk
management plan for each facility that lists all the processes at each facility.
8 NFPA 58,1998 Edition, Liquefied Petroleum Gas Code, Table B-1.2, pg 81.
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:";: ' * NFPA58,1998 Edition, Liquefied Petroleum Gas Code, Table 4-4.2.2(b), pg 52.
Oซober22.1998 ' ' '
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Risk Management Program Guidance
TABLE 1
TYPICAL WATER CAPACITY OF PROPANE TANKS,
TRANSPORTS AND RAILROAD TANK CARS
Storage Tank
Storage Tank
Storage Tank
Storage Tank
Storage Tank '
Storage Tank
Storage Tank , ...
Transport (Cargo Tank)
Rail Car DOT Class 105J300W & 105A300W
Rail Car DOT Class 1 12J340W & 1 12T340W
Rail.Car DOT Class 1 14J340W & 1 14T340W .
Rail Car DOT-Class 1 14J400W & 1 14T400W
Bobtails (Delivery Cargo Tank)
,12,000 Gallons
18,000 Gallons
30,000 Gallons
40,000 Gallons
_60,000 Gallons
100,000 Gallons
120,000 Gallons
8,000 -11, 000 Gallons
11, 000 -34,500 Gallons
26,000 - 34,500 Gallons
26,000 - 34,500 Gallons
26,000 - 34,500 Gallons
750 - 3200 Gallons
October 22, 1998
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Risk Management Program Guidance
10
TABLE 2
NOMINAL TANK CAPACITY TO POUNDS8
(Filled to 88% capacity)
ffl
Tank Capacity (gallons of
water)
500
1000
1500
2000
2500
2700
2701-5000
5001-7000
7001-9000
9001-11,000
11,001-13,000
13,001 - 15,000
15,001 - 17,000
17,001 - 19,000
19,001-21,000
21,001-23,000
23,001-25,000
25,001 - 27,000
27,001-29,000
29,001 - 31,000
31,001-33,000
33,001-35,000
Propane (pounds)
1800
3700
5500
7400
9200
10,000
14,000
22,000
30,000
37,000
44,000
52,000
59,000
67,000
74,000
81,000
89,000
96,000
100,000
110,000
120,000
130,000
Butane (pounds)
2000
4100
6100
8200
10,000
11,000
16,000
25,000
33,000
41,000
49,000
57,000
65,000
74,000
82,000
90,000
98,000
110,000 .
. 110,000
120,000'
130,000
140,000
r - * Note Table 1 is/zg/to be used as a replacement for the "Maximum Permitted Liquid Volume"given in Table 4.2.2(b)
of NFPA 58,1998 Edition. ,
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Risk Management Program Guidance
Tank Capacity (gallons of
water)
35,001-37,000
37,001 - 39,000
39,001'- 41,000
41,001 -43,000
43,001-45,000 '-
45,001-47,000
47,001 -49,000
49,001- -51,000 , .
51,001-53,000
53,001 - 55,000
55,001 > 57,000
57,001-59,000
59,001 - 61,000
61,001-63,000
63,001-65,000.
65,001-70,000
70,001-80,000 -.
80,001-90,000 .
90,001-100,000
100,001-110,000
110,001 -,120,000?
Propane (pounds)
130,000
140,000
150,000
' 160,000 ;
160,000
170,000
180,000
190,000
190,000 ' , -
200,000
210,000
210,000
220,000
230,000 '
240,000
.250,000 ,
280,000
310,000
350,000.
390,000
. 430,000
Butane (pounds)
. 150,000
160,000'
160,000
, 170,000
180,000
190,000 : '
200,000
200,000
210,000
220,000
230,000
240,000
250,000
'. .250,000
260,000
280,000
310,000
350,000
390,000
430,000
470,000'
For tanks laiger than 120,000 gallons use the following calculation to determine the pounds of propane at 88 percent
capacity.' (Tank size, in gallons of water) x 3.696 = (propane capacity in pounds). Round to two significant figures. Example:
160,000 x 3.696 = 590,000 pounds. For butane the multiplier is 4.08.
October 22, 1998
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Risk Management Program Guidance
12
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USING WORKSHEET 1 'TANK CAPAClTYflNVENTORY
; V V''^ .'. '.
(Complete one for each process)
' ill
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fill
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ill ......... ,i i
"
Tanks in the
Process
Tankl
Tank 2
TankS
Tank 4
TankS
Tank 6
Tank?
TankS
Tank 9
Tank 10
Total
Column 1
Tank Water Capacity (gallons)
18,678
30,927
60,899
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Column 2
Max. Inventory of Propane
(pounds)
67,000
110,000
220,000
N/A
N/A
N/A
" . :N/A '
N/A
N/A
Unless you always store less than these quantities in these tanks (i.e., you fill your tanks to
less than 88 percent capacity), 400,000 pounds is the maximum quantity in this process.
Largest Tank Number (from Table above) 3
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Largest Tank water capacity 60,899 gallons
Largest Tank maximum inventory 220,000 pounds.
October 22,1998
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13
Risk Management Program Guidance
WORKSHEET 1 TANK CAPACITY/INVENTORY
FOR USE WITH TABLE 2
(Complete one for each process)
Tanks in the
Process
Tank 1
Tank 2
Tank 3
Tank 4
Tank 5
Tank 6
Tank?
Tank 8
Tank9
Tank 10
Total10
Column 1
Tank Water Capacity (gallons)
- .
' '
Column 2
Max. Inventory of Propane (pounds)
i
This is your maximum inventory
Largest Tank Number (from Table above)
Largest Tank water capacity
Used in Chapter 2
gallons.
Largest Tank water capacity converted to pounds of propane.
. pounds.
Do not forget to round to two significant figures.
October 22,1998
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Risk Management Program Guidance
14
PROGRAM LEVELS AND APPLICABILITY
68.10 Applicability.
Once you have determined that this rule is applicable (i.e., that you store more than 10,000 pounds of
propane in a process), you must determine what Program level applies to each process. The rule
imposes different requirements on processes based on the relative potential risks to the public and level
of effort needed to prevent accidents. Three levels of requirements are as follows:
(b) Program 1 eligibility requirements. A covered process is eligible for Program 1 requirements as
provided in ง 68J2(b) if it meets all of the following requirements:
(1) For five years prior to the submission of an RMP, the process has not had an accidental release of
a regulated substance where exposure to substance, its reaction products, overpressure generated by
an explosion involving the substance, or radiant heat generated by afire involving the substance led
to any of the following qffsite:
(I) Death;
(ii) Injury; or
(Hi) Response or restoration activities for an exposure of an environmental receptor;
(2) The distance to a toxic or flammable endpointfor a worst-case release assessment conducted
under Subpart B and ง 68.25 is less than the distance to any public receptor, as defined in ง 68.30;
and
(3) Emergency response procedures have been coordinated between the stationary source and local
emergency planning and response organizations.
Program 1: A process with no public receptors within the distance to the endpoint
from a worst-case release and with no accidents with specific offsite consequences
within the past five years is eligible for Program 1, which imposes minimal
requirements on the process. Some propane storage facilities will be eligible for
Program 1.
(c) Program 2 eligibility requirements. A covered process is subject to Program 2 requirements if it
does not meet the eligibility requirements of either paragraph (b) or paragraph (d) of this section.
Program 2: A process which is not eligible for Program 1 nor subject to Program 3 is
placed in Program 2, which imposes a streamlined prevention program. Most propane
storage facilities not eligible for Program 1 will be eligible for Program 2.
(d) Program 3 eligibility requirements. A covered process is subject to Program 3 if
the process does not meet the requirements of paragraph (b) of this section, and if either of the
following conditions is met:
(1) The process is in SIC code 2611, 2812, 2819, 2821, 2865, 2869, 2873, 2879, or 2911; or
(2) The process is subject to the OSHA process safety management standard, 29 CFR
1910.119.
October 22.1998
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.15 ., ' . . Risk Management Program Guidance
Program 3: A process not eligible for Program 1 and that is either subject to OSHA's
PSM standard or in one of the nine specified Standard Industrial Classification (SIG) ,
codes is placed in Program 3, which imposes the OSHA PSM program as the
prevention program. OSHA exempts retailers, who are defined as facilities whose
sales to end users account for more than half of the total sales from the facility. Thus a
propane distribution facility with a large wholesale business may be subject to OSHA
PSM. OSHA also exempts propane when used solely as a fuel if such fuels are not part of a process
containing another highly hazardous chemical covered by the OSHA PSM standard. If you use
propane (above 10,000. pounds) either in a chemical process as a feedstock, as a refrigerant, as the
carrier gas for aerosol propellants containers, or as a fuel for heating a process or process equipment
that contains another OSHA PSM substance, you will be subject to OSHA PSM and Program 3.
OSHA PSM would also apply to a propane storage vessels that are close enough to vessels containing
another OSHA PSM-regulated substance to be considered co-located with them.
It is unlikely that a propane distribution facility will be subject to Program 3. Industrial users of
propane, however, will need to consider carefully whether they are required to implement Program 3
requirements and prepare the appropriate justification that supports the level selection.
This guidance is mainly geared to help those propane storage facilities .that qualify for Programs 1 or 2.
If you are subject to Program 3, you should consult OSHA and EPA's General Guidance. At your
discretion, you may use sections of this guidance to supplement your Program 3 risk management
program and risk management plan.
If you can qualify a process for Program 1, it is in your best interests to do so from an enforcement
standpoint, even if the process is already subject to OSHA PSM. For Program 1 processes, the agency
implementing part 68 will inspect and enforce only for compliance with the minimal Program 1
requirements. If you assign a process to Program 2 or 3, when it might qualify for Program 1, the
implementing agency will inspect or enforce for compliance with all thte requirements of the higher
program levels. Oh me other side, you have from now until June 21, 1999, to implement whichever
program level that you decide is appropriate. If an accident should make you change from a lower
program level to a higher program level, you will only have six months to implement the higher
program level requirements. This guidance will help you make your Program level determination as
you complete the various sections of the program.
KEY POINTS TO REMEMBER
In determining program level(s) for your process(es), keep in mind the following:
(1) Each process is assigned to a program level, which indicates the risk management measures
necessary to comply with this regulation for that process, not the facility as a whole. The
eligibility of one process for a program level does not influence the eligibility of other covered
processes for other program levels. .
(2) Any process that meets the criteria for Program 1 can be assigned to Program 1, even if
it is subject to OSHA PSM or is in one of the SIC codes listed for Program 3.
October 22,1998 , ' . ' '
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Risk Management Program Guidance
16
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(3) Program 2 is the default program level. There are no "standard criteria" for Program 2.
Any process that does not meet the criteria for either Programs 1 or 3 is subject to the
requirements for Program 2.
(4) Only one Program level can apply to a process. If a process consists of multiple vessels,
the highest Program level that applies to any segment of the process applies to all parts.
CIllll'H, ',. i II '
DETERMINING PROGRAM 1 ELidlBlLlTY
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For a process to be eligible for Program 1, it must meet two basic criteria (the third criteria,
coordinatipn wi|h public responders applies to all three Program levels):
There must be no public receptors within the distance to an endpoint from the worst-case
release scenario for the process; and
No accidental release of propane from the process can have caused offsite deaths, injuries, or
response or restoration activities for an environmental receptor.
The following sections of this chapter discuss the meaning of "public receptor," "environmental
receptor," and "injury." Chapter 2 describes how to determine your distance to an endpoint. A
process may have had accidental releases that you will need to report in the five-year accident history,
and yet the process may still be eligible for Program 1 because the criteria for Program 1 and the five-
year accident history are not the same.
WHAT Is A PUBLIC RECEPTOR?
The rule (ง 68 J) defines public as "any person except an employee or contractor of the stationary
Source." Consequently, employees of other facilities that may share your site are considered members
of the public even if they share the same physical location. Being "the public," however, is not the
salri^ as being "a public receptor.
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^'jPubfic receptors include "offsite residences, institutions (e.g.", schools and hospitals), industrial,
commercial, and office buildings, parks, or recreational areas inhabited or occupied by the public at
ariy time without restriction by the stationary source wnere members of the public could be exposed to
:;!;! J "tpxic lconcpntration|,'"radiant heatj or overpressure,' as a" result of'an" accidental release." Offsite means
areas beyond your property boundary and "areas within the property boundary to which the public has
routine and unrestricted access during or outside business hours.*'
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The first step in identifying public receptors is determining what is "offsite." For most facilities, that
determination will be straightforward. If you restrict access to all of your property all of the time,
"offsite" is anything beyond your property boundaries. Ways of restricting access include fully fencing
the property, placing security guards at a reception area or using ID badges to permit entry.
If you do not restrict access to a section of your property and the public has routine and unrestricted
access to it during or after business hours, that section would be "offsite." For example, if your
October22,1998 ' '" " " " '" '" "''" ' "
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17 . . Risk Management Program Guidance
operations are fenced but the public has unrestricted access to your parking lot during or after business
hours, the parking lot is "offsite." In the case of facilities such as hospitals, schools, and hotels that
shelter members of the public as part of their function or business, the parts of the facility _that are used
to shelter the public would be "offsite." , - ' .
, ' Not all areas offsite are potential public receptors. The point of identifying public receptors is to locate
those places where there are likely to be, at least some of the time, members of the public whose health
could be .harmed by short-term exposure to an accidental release at your site. The basic test for
identifying a public receptor is thus whether an area is a place where it is reasonable to expect that
members of the public will routinely gather at least some of the time.
The definition of "public receptor" itself specifies the types of areas where members of the public may
routinely gather at least some of the time: residences, institutions such as hospitals and schools,
buildings in general, parks and recreational areas. There should be little difficulty in identifying
residences, institutions and businesses as such, and virtually any residence, institution and business
will qualify as a public receptor, even when the property is used only seasonally (as in a vacation
home). Notably, a residence includes'its yard, if any, arid an institution or business includes its
grounds to the extent that employees or other members of the public are likely to routinely gather there
at least some of the time for business or other purposes (see discussion of recreational areas below).
The only circumstances that would justify not considering such a property a public receptor would be
where your facility owns or controls the property and restricts access to it, or no member of the public
inhabits or occupies it at any time. Where a hospital, school, hotel or other entity that provides public
shelter is itself subject to the part 68 rule (e.g., because of on-site propane storage tanks), it will be its
own public receptor except for those areas where members of the public are not allowed to go at any
time. _. . ,
Buildings other than residences, institutions or businesses are also highly likely to qualify as public
receptors since the function of most buildings is at least in part to shelter people. Accordingly, toll
booth plazas, transit stations, and airport terminals would qualify as public receptors. For a building
not to qualify as a public receptor, one of the circumstances mentioned above would have to 'apply.
Every designated park or recreational area, or at least some portion thereof, is apt to be a public
gathering place by virtue of facilities made available to the public (e.g., visitors' center, playground,
golf course, camping or picnic area, marina or ball field) or attributes that members of the public
routinely seek to use-(e.g., beach). It does not matter whether use of such facilities is seasonal; routine
use for at least part of the year would qualify the area as a public receptor.
At the same time, some portion of a designated park or recreational area may not be a public receptor.
For instance, a large state or national park may include relatively inaccessible tracts of land that do not
contain public facilities or receive routine use. Occasional hiking, camping or hunting in such areas
would not qualify the areas as public receptors.
An area need not be designated a recreational area to be one in fact. If an area is routinely used for
recreational purposes, even if only seasonally, it is a recreational area for purposes of the part 68 rule.
For example, a marina may not bill itself as a "recreational area," but if a marina houses recreational
boats, it qualifies as a public receptor. Further, if your facility or a neighboring property owner allows
October 22,'1998 ' '
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Risk Management Program Guidance 18
the public to make routine recreational use of some portion of land (e.g., a ball field or fishing pond), .
that portion of land would qualify as a public receptor.
Roads and parking lots are not included as such in the definition of "public receptor." Neither are
places where people typically gather; instead they are used to travel from one place to another or to
park a vehicle while attending an activity elsewhere. However, if a parking lot is predictably and
routinely used as a place of business (e.g., a farmer's market) or for a recreational purpose (e.g., a
county fair), it would qualify as a public receptor.
In general, farm land would not be considered a public receptor. However, if farm land, or a portion
thereof, is predictably and routinely occupied by farm workers or other members ,of public, even if only
on a seasonal basis, that portion of the land would be a public receptor.
If you are in doubt about whether to consider certain areas around your facility as public receptors, you
should consult with the relevant local officials and land owners and your implementing agency for
I" guidance. ' ' ' : ' .
!? !,:'': '. , ' ; MCi .. ' ., i"> v.-i; .-.. ,;.,. ', f'-i |..;|; ;.; ,;.:; -.,:-, i.;. ';. < n> , r . : . " ; .. , \ . '
WHAT is A DISTANCE TO AN ENDPOINT FROM A WORST-CASE RELEASE?
Ill broad terms, the distance to an endpoint is the distance a toxic vapor cloud, fire, or explosion from
an accidental release will travel before dissipating to the point that serious injuries from short-term
exposures will no longer occur. For propane (and other flammables) the endpoint is an overpressure of
1 psi. Beyond that endpoint, the effects on people are not considered to be severe enough to merit the
need for additional action under this rule.
WHAT is AN INJURY?
An injury is defined as "any effect on a human that results either from direct exposure to toxic
concentrations; radiant heat; or overpressures from accidental releases or from the direct consequences
of a vapor cloud explosion (such as flying glass, debris, and other projectiles) from an accidental
release." "The effect must "require medical treatment or hospitalization." This definition is taken from
the OSHA regulations for keeping employee injury and illness logs and should be familiar to most
employers. Medical treatment is further defined as "treatment, other than first aid, administered by a
physician or registered professional personnel under standing orders from a physician." The definition
bf medical treatment will likely capture most instances of hospitalization. However, if someone goes
to the hospital following; direct exposure to a release ancf is kept overnight for observation (even if no
specific injury or illness is found), that would qualify as hospitalization and so would be considered an
injury.
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WHAT is AN ENVIRONMENTAL RECEPTOR?
The environmental receptors you need to consider are limited to natural areas such as national or state
parks, forests, or monuments; officially designated wildlife sanctuaries, preserves, refuges, or areas;
and Federal wilderness areas. All of these areas can be identified on local U.S. Geological Survey
"'maps. ''" ' ' '" '"
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October 22,1998
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19 Risk Management Program Guidance
WHAT ARE RESTORATION AND RESPONSE ACTIVITIES?
The type of restoration and response activity conducted to address the impact of an accidental release
will depend on the type of release (volatilized, spill, vapor cloud, fire, or explosion), but may include
such activities as: -'.'
- Collection and disposal of dead animals and contaminated plant life;
Collection, treatment, and disposal of soil;
.',' Shutoff of drinking water;
Replacement of damaged vegetation; or
Isolation of a natural area due to contamination associated with an accidental release.
PROGRAM LEVEL APPLICABILITY '
It is expected that most propane storage facilities will have no accidents that meet the criteria (i.e., that
have resulted in offsite deaths, injuries, or response or restoration activities for exposure"of an
environmental receptor. Have you had.an accidental release of propane that meets this definition?
(Yes or No)
Used in Chapter
From Worksheet 3, Chapter 2 record the distance to eridpoint for your
worst-case scenario - miles.
To define the area of potential impact from the worst-case release, draw a
circle on a map, using the process as the center and the distance to the
eridpoint as the radius. If there are public receptors within that area, your process is not eligible for
Program 1. '
If you answered "NO," there are no public receptors within the distance to
endpoint for your worst case, and if you have determined that you have not had an
accidental release of propane as defined in ง 68.10(b)(1) within the five years prior
to RMP submission, you are eligible for Program 1.
Unless eligible for Program 1, a propane storage process is Program 3 if it is covered by OSHA's
Process Safety Management Standard (PSM) [29 CFR 1910.119] or in one of the nine SIC codes.
Most propane storage facilities are exempt from OSHA's PSM standard, provided that they qualify for
any one of the following OSHA's exemptions:
' . > Retail facility.
> Hydrocarbon fuels used solely for workplace consumption as a fuel (e.g., propane
used for comfort heating)...if,such fuels are not part of a process containing another
highly hazardous chemical1 covered by the PSM standard.
> A normally unoccupied, remote facility.
October 22, 1998
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Risk Management Program Guidance 20
ป An oil or gas drilling or servicing operation.
* I1 ' ,
Note: Propane Distributors with a large wholesale business may be subject to OSHA PSM and
,i iiiiiiiir1.in :iu nii'ji; ', vr, ', ,,,^' , , ,i,i, ,,' ,, , ' ' in,i!p ', vซ ,-f,,r, ,i 'I/ ii, ,,,,7 ,,, , , ,, ,,, , ,, | , ,, , , , ,',,,,
thus to Program 3.
If you are subject to Program 3, you must also complete ง 68.28 "Alternative
Flammable Release Scenarios" and subpart D Program 3 Prevention Program. You
will need to consult EPA's General Guidancefor information on Program 3 Prevention
Program.
A propane storage process is Program 2, if it is neither Program 1 nor Program 3. It is expected
that most propane distributors will be Program 2.
Record your program level
,lllllll,lN!,:P!' !', I'll,, ll/ ,1,11,11
If you are subject to Program 2, it will be necessary for you to complete ง 68.28
"Alternative Flammable Release Scenarios" and all of SUBPART C Program 2
Prevention Program.
;, il
SUMMARY OF PROGRAM REQUIREMENTS
Regardless of the program levels of your processes, you must complete a five-year accident history for
each process and submit an RMP that covers all processes. Depending on the Program level of each of
your processes, you must comply with the additional requirements described below. Exhibit 1 lists
them in more detail.
Program 1. For each Program 1 process, you must conduct and document a worst-case release
analysis. You must coordinate your emergency response activities with local responders and sign the
p'rogram 1 certification as part of"yourRMP submission^
Programs 2 and 3. For all Program 2 and 3 processes, you must conduct and document at least one
, vyorstcase release analysis to cover all toxics and one to cover all flammables. You may need to
cppducj: additional worst-case release analyses if worst-case releases from different parts of your
facility would affect different public receptors. You must also conduct one alternative release scenario
analysis for all flammables. You must coordinate your emergency response activities with local
responders and, if you use your own employees to respond to releases, you must develop and
implement an emergency response program.
For each Program 2 process, you must implement all of the elements of the Program 2 prevention
program: safety information, hazard review, operating'procedures, training, maintenance, compliance
audits, and incident investigations. .
October 22,1998 .. ..
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21 : Risk Management Program Guidance
For each Program 3 process, you must'implement all of the elements of the Program 3. prevention
program: process safety information, process hazard analysis, standard operating procedures, .training,
mechanical integrity, compliance audits, incident investigations, management of change, pre-startup
reviews, contractors, employee participation, and hot work permits.
October 22, 1998
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Risk Management Program Guidance
22
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23 Risk Management Program Guidance
CHAPTER 2: OFFSITE CONSEQUENCE ANALYSIS
You are required to conduct an offsite consequence analysis to provide information to the government
and the public about the potential consequences of an accidental chemical release. The offsite
consequence analysis (OCA) consists of two elements:
A worst-case release scenario and
Alternative release scenarios (Program 2 and Program 3 processes only).
To simplify the analysis and ensure a common basis for comparisons, EPA has defined the worst-case
scenario as the release of the largest quantity of a regulated substance from a single vessel or process
line failure trial results in the greatest distance to an endpoint.
RMP*Comp
To assist those using this guidance, the National Oceanic and Atmospheric Administration
(NOAA) and EPA have developed a software program, RMP*Comp, that performs the
calculations described in this document. This software can be downloaded from the
NOAA Internet website at http://response.restoration.noaa.gOv/chemaids/rmp/rm.p.html.
The methodology and reference tables of distances presented here are optional. You are not
required to use this guidance. You may use publicly available or proprietary models to do your
offsite consequence analysis, subject to certain conditions. If you choose to use other models, you
should review the rule and Chapter 4 of the General Guidance for Risk Management Programs, which
outline required conditions for use of other models.
. WORST-CASE ANALYSIS
68.25 Worst-case release scenario.
(a) The owner or operator shall analyze and report in the RMP:
(1) For Program 1 processes, one worst-case scenario for each Program 1 process;
(2) For Program 2 and 3 processes:
[ (I) Not Applicable (pertains to toxic worst-case).]
(ii) One worst-case release scenario that is estimated to create the greatest distance in any direction
to an endpoint defined in ง 68.22(a) resulting from an accidental release of regulated flammable
substances from covered processes under worst-case conditions defined in ง 68.22; and
(Hi) Additional worst-case release scenarios for a hazard class if a worst-case release from another
covered process at the stationary source potentially affects public receptors different from those
potentially affected by the worst-case scenario developed under paragraphs (a)(2)(I) or (a)(2)(ii) of
this section. ,
October 22, 1998 '" .
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Risk Management Program Guidance
24
(b) Determination of worst-case release quantity. The worst-case release quantity shall be the
greater of the following:
(1) For substances in a vessel, the greatest amount held in a single vessel, taking into account
administrative controls that limit the maximum quantity; or
(2) For substances in pipes, the greatest amount in a pipe, taking into account administrative
controls that Hn^it the maximum quantity.
(c) Worst-case release scenariotoxic gases. [Not applicable]
(d) Worst-case release scenariotoxic liquids. [Not applicable]
(e) Worst-case release scenarioflammables. The owner or operator shall assume that the quantity
of the substance, as determined under paragraph (b) of this section, vaporizes resulting in a vapor
cloud explosion. A yield factor of 10 percent of the available energy released in the explosion shall be
used to determine the distance to the explosion endpoint if the model used is based on TNT-equivalent
methods.
(f) Parameters to be applied. The owner or operator shall use the parameters defined in ง 6822 to
determine distance to the endpoints. The owner or operator may use the methodology provided in the
-RMP Offsite Consequence Analysis Guidance or any commercially or publicly available air
dispersion modeling techniques, provided the techniques account for the modeling conditions and are
recognized by industry as applicable as part of current practices. Proprietary models that account for
the modeling conditions may be used provided the owner or operator allows the implementing agency
access to the model and describes model features and differences from publicly available models to
local emergency planners upon request.
(g) Consideration of passive mitigation. Passive mitigation systems may be considered for the
analysis of worst case provided that the mitigation system is capable of withstanding the release event
triggering the scenario and would still function as intended.
(h) Factors in selecting a worst-case scenario. Notwithstanding the provisions of paragraph (b) of
this section, the owner or operator shall select as the worst case for flammable regulated substances .
.. a scenario based on the following factors if such a scenario would result in a greater distance to an
endpoint defined in ง 68.22(a) beyond the stationary source boundary than the scenario provided
under paragraph (b) of this section:
(1) Smaller quantities handled at higher process temperature or pressure; and
(2) Proximity to the boundary of the stationary source.
Everyone subject to the rule must analyze at least one worst-case scenario. Complete the analysis for
propane and determine the greatest offsite impact distance. For trie purposes of the analysis, you must
assume that the entire contents of your largest tank is released, a vapor cloud forms (with all the mass
of the tank within the flammable range), and a detonation occurs. The analysis incorporates a 10
percent yield factor for TNT-equivalency models. The distance to endpoint is defined as the distance
over which a minimum pressure of one (1) pound per square inch (psi) occurs from the pressure wave
formed by the detonation.
To conduct this hazard assessment analysis, you may use Worksheet 2 along with Table 3 or you may
use EPA's RMP Offsite Consequence Analysis Guidance or some other recognized model. To use
Worksheet 2, complete the following steps: .
October 22,1998
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25
Risk Management Program Guidance
1. In the left hand column of Worksheet 2, record the nominal water capacity for each of your
bulk propane storage tanks. Do not include tanks used for transportation and still attached to
their motive power. You can transfer the nominal water capacity information from Worksheet
1 to Worksheet 2.
2. Find the range of nominal water capacities in Table 3 that encompasses your actual tank
inventory. If you have administrative controls that require that the tank be filled to less than
88 percent capacity at all times, you should adjust the numbers from Table 3 to reflect the
smaller inventories in your tanks. Record the distance to endpoint for your corresponding
storage tank in the right hand column of Worksheet 2.
3. Repeat these steps for each storage tank. .
See example 2. For example, a storage tank with a nominal water capacity of 30,000 gallons of water
is in the range of. 23,001 - 47,000 gallons and corresponds to 0.4 miles for distance to the endpoint.
Use Table 3 below to calculate the distance to the endpoint of 1 psi overpressure for each of your
propane storage tanks: .
TABLE 3
NOMINAL TANK CAPACITY VS DISTANCE TO ENDPOINT
Nominal Water Capacity
(Gallons)
500-1,750 /
1,751-7,000
7,001 - 21,000
21,001-23,000
23,001-47,000
47,001-51,000
51,001-90,000
90,001 - 120,000
Propane Distance to
Endpoint (Miles)
0.1
0.2
0.3
0.3
0.4
0.4
0.5
0.6
Butane Distance to
Endpoint (Miles)
0.1
-. 0.2
0.3
0.4
0.4
0.5
0.5
0.6
October 22, 1998
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gisk Management Program Guidance
26
' "::; : ' " :" EXAMPLE 2 -
USING WORKSHEET 2 TO FIND WORST-CASE DISTANCE TO ENDPOINT
.
Tankl
Tank 2
TankS
Tank 4
TankS
Tank 6
Tank?
TankS
Tank 9
Tank 10
Nominal Water Capacity
(Gallons)
18,678
30,927
60,899
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Distance to Ehdpoint (Miles)
0.3
0.4
0.5
N/A
N/A
'N/A
N/A
N/A
N/A-
N/A
Record the amount contained in your largest tank: 220.000 pounds, remembering to adjust
for administrative controls if you always fill your tanks to less than 88 percent capacity. You
have already calculated this in Chapter 1, Worksheet 1.
Record the distance to endpoint for your largest tank: 0.5 miles.
' ," ^ ' v". ,;' ' ,,-,'i :;::: '-. : ,'. ' :';'",''>'',' '' -/: ',' : '.', ' ..'.:' !' " , , ;;
This is your "worst-case scenario."
October 22.1998
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27
Risk Management Program Guidance
WORKSHEET 2
WORST-CASE DISTANCE TO ENDPOINT
Tank!
Tank 2
TankS
Tank 4
TankS
Tank 6
Tank?
TankS
Tank 9
Tank 10
Nominal Water Capacity"
(Gallons)
Distance to Endpoint12 (Miles)
-
" -
Record the amount contained in your largest tank, remembering to
adjust for administrative controls if you always fill your tanks to
less than 88 percent capacity: . pounds. You have
already calculated this in Chapter 1, Worksheet 1.
| From Chapter 1 |
Record the distance to endpoint for your largest tank:
Used Chapter 1
miles.
This is your "worst-case scenario.".
11 Note: The Nominal Water Capacity information for each of your propane storage tanks can be transferred from
Worksheet 1. '
,12 Note: The Distance to Endpoint is found in Table 2.
October 22, 1998
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Risk Management Program Guidance 28
ALTERNATIVE RELEASE SCENARIOS
Remember that alternative release scenarios are not required for Program 1 processes.
(a) The number of scenarios. The owner or operator shall identify and analyze at least one
alternative release scenario... to represent all flammable substances held in the covered processes.
(b) Scenarios to consider.
(1) For each scenario required under paragraph (a) of this section, the owner or operator shall select
a scenario:
(I) That is more likely to occur than the worst-case scenario under ง 68.25; and
(ii) That will reach an endpoint offsite, unless no such scenario exists.
These are the only two criteria for selecting an alternative release scenario. The alternative release
scenario gives you an opportunity to describe an event more likely than the worst-case scenario that
may reach an endpoint offsite. This scenario will be of interest to many emergency responders. The
alternative release scenario represents an event that an emergency responder may actually encounter as
opposed to the worst-case event that has a very low probability of occurrence. Should you decide that
no alternative scenario exists that would reach an endpoint offsite, you must document for your
implementing agency the scenarios that you examined that allowed you to draw that conclusion,
making sure you have reviewed all the possible release scenarios suggested below.
(2) Release scenarios considered should include, but are not limited to, the following, where
applicable:
(I) Transfer hose releases due to splits or sudden hose uncoupling;
(ii) Process piping releases from failures at flanges, joints, welds, valves and valve seals, drains or
bleeds; ,
(In) Process vessel or pump releases due to cracks, seal failure, or drain, bleed, or plug failure;
(iv) Vessel overfilling and spill, or overpressurization and venting through relief valves or rupture
disks; and t ' '
(v) Shipping container mishandling and breakage or puncturing leading to a spill.
(c) 'PQrametersJjQ "be applied. The owner or operator shall use the appropriate parameters defined in
ง 68.22 to< determine-thedistance to the endpoints...
(d) Consideration of mitigation. Active and passive mitigation systems may be considered provided
they are capable of withstanding the event that triggered the release and would still be functional.
(e) Factors in selecting scenarios. The owner or operator shall consider the following in selecting
alternative release scenarios; ' "r _ "_ '". \ ' \t\ '\\ ' ' _, " ''. i ^ ' '_, ( , , '
(1) The five-year accident history provided in ง 68.42; and
(2) Failure scenarios identified under งง 68.50 or 68.67.
I i " i" ;;,. f.v ;,, i;" <.";ป : " ; " ; ..,'
You should review your five-accident history as a guide to selecting an alternative scenario appropriate
to your facility. It may also be possible to obtain information concerning propane accidents from
EPA's web site, which has links to various accident databases.
i Ii iii ' '' , ,.:,.;. . "i1 ''3 'i ' '" '" -i, . ," ',:'
Select one or more alternative release scenarios from Appendix 2A that is appropriate for your propane
storage facility. Your selection should:
, ' " :-, " ', ,'i i ,.
October 22,1998
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29
Risk Management Program Guidance
ป Describe something that has occurred or could occur. Review any applicable accident.
history.
* Be more likely to occur than the worst-case scenario.
ป- , .Have a distance to the endpoint that is greater than the distance to the facility
boundary, unless no such scenario exists.
Use the following worksheet to record the scenarios that you have selected from Appendix 2A.
WORKSHEETS x
POTENTIAL ALTERNATIVE RELEASE SCENARIOS
Alternative Flammable
Release Scenario
(Possible Selections)
Pull Away
Process Piping Breaks
Process Piping Breaks While
Pumping
Overfilling Storage Tank
Relief Valve Lifts
Other: (Describe:)
Amount
Released
(pounds)
Distance
to
Endpoint
(Miles)
Check the Scenario that
You will Report as the
Alternative Scenario
' . . n
. n
n
a
n
Alternative release scenarios will help stimulate discussions between the facility, the public and
emergency planners. Emergency planners using information from the facility will decide how best to
incorporate the distance to the endpoint into.the community plan.
You can use other more sophisticated calculations and computer models to determine other scenarios
or fire events and to determine other impact distances. The owner/operator attempting to provide more
information to emergency planners should see the procedure in EPA's OCA Guidance for help in
conducting these analyzes. You also have the option of using other modeling to perform these
analyzes. '
October 22, 1998
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Risk Management Program Guidance 30
DEFINING OFFSITE IMPACTS
(a) The owner or operator shall estimate in the RMP the population within a circle with its center at
the point of release and a radius determined by the distance to the endpoint defined in ง 68.22(a).
(b) Population to be defined. Population slialt include residential population. The presence of
institutions (schools, hospitals, prisons), parks and recreational areas, and major commercial, office,
and industrial buildings shall be noted in the RMP.
(c) Data sources acceptable. The owner or operator may use the most recent Census data, or other
updated information, to estimate the population potentially affected.
(d) Level of accuracy. Population shall be estimated to two significant digits.
The rule requires that you estimate in the RMP residential populations within the circle defined by the
endpoint for your worst-case and alternative release scenarios (i.e., the center of the circle is the point
of release and the radius is the distance to the endpoint). In addition, you must report in the RMP
Whether certain types of public receptors and environmental receptors are within the circles.
RESIDENTIAL POPULATIONS
To estimate residential populations, you may use the most recent Census data or any other source of
data that you believe is more aqcurate. You are not required to update Census data or conduct any
surveys to develop your estimates. Census data are available in public libraries and in the LandView
system, which is available on CD-ROM (see box below). The rule requires that you estimate
populations to two-significant digits. For example, if there are 1,260 people within the circle, you may
report 1,300 people. If the number of people is between 10 and 100, estimate to the nearest 10. If the
number of people is less than 10, provide the actual number.
Census data are presented by Census tract. If your circle covers only a portion of the tract, you should
develop an estimate for that portion. The. easiest way to do this is to determine the population density
per square mile (total population of the Census tract divided by the number of square miles in the tract)
and apply that density figure to the number of square miles within your circle. Because there is likely
to be considerable variation in actual densities within a Census tract this number will be approximate.
The rule, however, does not require you to correct the number.
ii
OTHER PUBLIC RECEPTORS
n , ii ''',',' *'' " '
Other public receptors must be noted in the RMP (see the discussion of public receptors in Chapter 2).
If there are any schools, residences, hospitals, prisons, public recreational areas or arenas, or
commercial or industrial areas within the circle, you must report that. You are not required to develop
a list of all public receptors; you must simply check off that one or more such areas is within the circle.
Most receptors can be identified from local street maps.
ENVIRONMENTAL RECEPTORS
Environmental receptors are defined as natural areas such as national or state parks, forests, or
monuments; officially designated wildlife sanctuaries, preserves, refuges, or areas; and Federal
October 2Z 1998
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31
Risk Management Program Guidance
wilderness areas. Only environmental receptors that can be identified on local U.S. Geological Survey
(USGS) maps (see box below) need to be considered. You are not required to locate each of these
specifically. You are only required to check off in the RMP which specific types of areas are within
the circle. If any part of one of these receptors is within your circle, you must note that in the RMP.
Important: The rule does not require you to assess the likelihood, type, or severity of potential
impacts on either public or environmental receptors. Identifying them as within the circle simply
indicates that they could be adversely affected by the release.
How TO OBTAIN CENSUS DATA AND LANDVIEWฎ
Census data can be found in publications of the Bureau of the Census, available in public libraries,
including County and City Data Book.
LandView ฎHI is a desktop mapping system that includes "database extracts from EPA, the Bureau
of the Census, the U1S. Geological Survey, the Nuclear Regulatory Commission, the Department
of Transportation, and the Federal Emergency Management Agency. These databases are
presented in a geographic context on maps that show jurisdictional boundaries, detailed networks
of roads, rivers, and railroads, census block group and tract polygons, schools, hospitals, churches,
cemeteries, airports, dams, and other landmark features.
CD-ROM for IBM-compatible PCS
CD-TGR95-LV3-KIT $99 per. disc (by region) or $549 for 11 disc set
U.S. Department of Commerce /
Bureau of the Census
P.O. Box 277943
Atlanta, GA 30384-7943
Phone: 301-457-4100 (Customer Services-orders)
Fax: (888) 249-7295 (toll-free)
Fax: (301) 457-3842 (local) .
Phone: (301) 457-1128 (Geography Staff-content) , .
http://www.census.gov/ftp/pub/geo/www/tiger/
Further information on LandView and other sources of Census data is available at the Bureau of
theCensuswebsiteatwww.census.gov. >
October 22; 1998
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(I
Management Program Guidance
32
Iff'1 [ "'I
|||f" I ;!
i5iii'ซ' Li: i'1"
"i/iiiii r i'li"1!::"!
i I'll'111 "I ' !. "lid:
lii't! r1
'i1!,': I'1 n|,l I,,!,,,,! ' !i, "lj,,||
i"", r'^j1,1''' ',! ,^f
Hi Ill'HI ' I' " " Ml'
illl-ilBKii I, ',;, SI"
l
Si
ilii
IS'I
How TO OBTAIN USGS MAPS
The production of digital cartographic data and graphic maps comprises the largest component of
the USGS National Mapping Program. The USGS's most familiar product is the l:24,000-scale
Topographic Quadrangle Map. This is the primary scale of data produced, and depicts greater
detail for a smaller area than intermediate-scale (1:50,000 and 1:100,000) and small-scale
(1:250,000, 1:2,000,000 or smaller) products, which show selectively less detail for larger areas.
U.S. Geological Survey
508 National Center
12201 Sunrise Valley Drive
Reston,VA 20192
www.mapping.usgs.gov/
To order USGS maps by fax, select, print, and complete one of the online forms and fax to
303-202-4693. A list of commercial dealers also is available at
www.mapping.usgs.gov/esic/usimage/dealers.htrnl/. For more information or ordering assistance,
call 1-800-HELP-MAP, or write:
USGS Information Services
Box 25286
Denver, CO 80225
For additional information, contact any USGS Earth Science Information Center or call
1-800-USA-MAPS.
REVIEW AND UPDATE
iipin i i '; . , ' .',..
(a) The owner or operator shall review and update the offsite consequence analyses at least once
i every five years.
!'.. * * .' ,1,1 ," . ', .", ,', ,;"! ' , " ", , I '..",',, ' ' i '" ,, , "- " , , , ," '
To demonstrate that ari prlsite consequence analysis has been reviewed and updated, you must retain
the last copy and date each subsequent analysis.
(b) If changes in processes, quantities stored or handled, or any other aspect of the stationary source
might reasonaSly be expected! to increase or decrease the distance to the endpoint by a factor of two
or more, the owner or operator shall complete a revised analysis within six months of the change and
submit a revised risk management plan as provided in ง 68.190.
If you add or remove bulk storage tanks, you may have to re-do the offsite consequence analysis. If, as
the result of adding a new tank, the distance to the endpoint for your worst-case analysis is more than
twice as far as the previously reported distance, you must resubmit a revised risk management plan
within six months. Or if you remove your largest tank from service and the next largest tank has a
October 22,1998
-------
33 Risk Management Program Guidance
distance to endpoint less than half of the original analysis, you must resubmit a revised risk
management plan within six months. See Chapter 6 of this guidance for details on the risk
management plan.
Increasing tank size will not proportionately increase your distance to endpoint. As Table 3 indicates,
you would have to increase or decrease your tank size by more than a factor of five to double the
distance: For example, if you replaced your 12,000 gallon tank (distance to endpoint = 0.3 miles) with
a 100,000 gallon tank (distance to endpoint = 0.6 miles), you would be required to file an amended
risk management plan. If you added five 30,000 gallon tanks, you would not have to file an amended
plan because your distance to endpoint would only increase from 0.3 miles to 0.4 miles. Remember,
worst case is the loss of the single largest vessel; adding storage capacity by adding more tanks of the
same'size will not alter the distance to an endpoint.
October 22, 1998
-------
Ill 111
111 P
111 111 I
Iliil1' i III
Risk Management Program Guidance
34
APPENDIX 2A - RELEASE CALCULATIONS
11 ESil::
I 111 III ':ii"ii i"'!!!"
The endpoints that can be considered for the alternative release scenario are explosion damage, radiant
heat effect and Ipwer fiarnmabiiity limit vapor concentration. Review these potential alternative
scenarios and pick one or more that best describes a scenario that is more likely to occur than the
worst-case "scenario and that has an endpoint which is beyond your facility boundary. The following
are possible alternative release scenarios that use a vapor cloud explosion and an overpressure of 1 psi.
PULL-AWAY: (ACTIVE MITIGATION DEVICES PERFORM AS DESIGNED)
An alternative scenario for a propane storage facility may be a hose rupture caused by a pull-away. A
'ป,; pull-away can occur if the driver fails to remove the hoses between the storage tank and the transfer
III; vehicle (b'pbtail "or'u-ahsportybefore moving me vehicle. In this case, me analysis considers the failure
of a 25 foot length of unloading hose, 4" in diameter. The active mitigation devices are assumed to
work as designed, limiting the release to the contents of the hose.
Volume of hose = cross sectional area of hose x length of hose
Volume of hose=,TC x (4 in / 2)2 x 1 ft2 / 144 in2 x 25 ft = 2.182 ft3
Wf= 21182 ft3 x .504 x 62.37 pounds/ft3 = 68:59 pounds of propane
There are three methods described in EPA's OCA that you can use to determine the distance to the
endpoint for an alternative scenario. Two of those, methods are used here as an example.
mil' iini i ... i , i "'.i i < iiriiimmiMi ' < " !i i i< . '"'' .i< i111 n> ' ii "'' 'n i , ' " . .' ' .1.1' .1: ' I'. "..", i, 'i i' 'i
:|:
i..'*;, i :: Ii'!' ;
||IT|; ^ ; , nl , if ir> : :liM TIT f i& cut WdgJUL \Ji pltjpaii& ill AJLJLV/^JLOIIJLO Jill ui\^ vapirji wiwuu,
j w*{ ';\i: '!': ' '':';.' ',''.: ||i i, HCr is the h eat'of combustion of propane from Appendix C of-EPA's' OCA,
isi'1!' !-!i:f'. (, i:;1 ' *"!'''iiCirjn. is the heat of combustion of TNT from Appendix C of EP'X's OCA, and
t> is the distance in meters from the explosion where overpressure exceeds 1 psi.
D = 17 (.1 x Wf x 46333/4680)* = 17 (.1 x 68.6/2.2046 x 46333/4680f = 53.29 meters
D = 174.8Jfeet
'.f IJJH I "I,
II'1; '.'>.\r
13 These valves require a pressure of 100 psi to function proper^. The vapor pressure of propane at 60 ฐF is
approxJmatey 100 psi. At temperatures less than 60ฐF, there may not be enough pressure to allow the valves to function propejl.
Since the excess safety valve may not function properly under some conditions, it may be more appropriate not to consider this
mitigation device. .
" Ociober22.1998 '
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35
Risk Management Program Guidance
If you use this scenario as your alternative release scenario, the distance to endpoint is 175 feet and the
endpoint used is 1 psi overpressure. .
PROCESS PIPING BREAKS
Liquid propane pipe failures: W,\n,2", 3", 4" and 6". (Causes liquid expansion [failure of
hydrostatic valves], a pull-away [failure of breakaway devices1*], collision, corrosion). You can
estimate the amount released from a line shear using equation:
X, ' _ t - ,
QR = HA x Pt"x l/(Tt)'/2 x GF
Where: QR is the release rate in pounds per minute. ., .
HA is the area of the hole or pipe in square inches. . >
Pt is the tank initial pressure in psia( @ 77 ฐFPt = 170 psia). ; .
T, is the tank initial temperature in ฐK (Tt = 298 ฐK).
GF is the gas factor which is 22 for propane.
QR can be calculated using the values in the table below for HA. Now Q (the release quantity) and D
(the distance to the endpoint in feet) can be calculated using the equation. Note that Q cannot be larger
than the amount of propane contained in your storage tank.
TABLE 4
POTENTIAL DISTANCES TO ENDPOINT FOR PIPE RELEASES
(for 1 psi Overpressure)
Pipe Size (inches)
Q.50
1
2
3
4
. 6 .
HA (inches)2
' 0.2 ,
0.79
3.14
7.07
12.57 .'
28.27
QR
(pounds/minute)
474
1,895
7,580
17,056
30,322
68,224
Q Total Amount
Released after 10
minutes (pounds)
4,738
18,951
75,804
170,560
303,217
682,239
D (Miles)
.1
0.2 /'
, 0.3
0.4
0.5 -
0.7
PROCESS PIPING BREAKS -WHILE PUMPING
14 See NFPA 58,1998 Edition, Section 3-9.4.2. A breakaway device is used when dispensing I.PG. It is designed so
that the breakaway device fails (instead of the piping or hose) allowing other safety devices to retain the fuel and limit the spill.
Failure of the breakawa/ device means that the breakage occurs somewhere else rather than at the breakaw? device during a pull
away, thus negating the effectiveness of some or all of the other safetydevices. ,
Octobter22, 1998
-------
1 IK
Risk Management Program Guidance
36
rr;r:r'!
A pipe on the discharge of the pump ruptures while loading is in progress. For this situation assume
that the pump remains running for three minutes after the pipe breaks* and the release continues for
7 five minutes before manual valves can be closed. The resulting vapor cloud reaches an ignition source
arid explodes. Assume that the pump is a 3" x 2" pumping at 100 GPM. The normal pumping rate
'tf ; jjjjljj;!|ncreases as the head|on.the pump is reduced (discharge to atmosphere as opposed to discharge into a
. .H' ''." . f*jf 9lQS?d system). Assume the pump rate increases to 140 GPM. The discharge line is a two-inch line.
lijijjiLjiiiijjijji'lijijiM.ii |. ""'!(! I1:'' I* 'iซf ' ,' ' ijjiniiiliij'iiii, , '":' ''"' i'; "i;, I'MIN!!' '".-ii i,ji|u ' ;"iifi .ป" ' ;,! !.''ซ" 'i.iiji. is,'1*1 ,n i i n n i . ! .'' :;, ,,, . . ,'" ', ',i 'ซ ": M- "V1!;
iป W:^jj Tt'ji.; J i;|: ',, i jSi |," The first step is to calculate the amount of propane released by pumping.
iM'i^ff'^r- Si;,1^mp=i40gal"/minx4.2dlbs/galionx3m ' ' ,
*aป|;.i;'!.i "; ,'i1:* . till J.,':''.v '*;': *''; '" "li'lii "i .' ..'-': ;|l~i:i1:'; I,'1. v';::i: ' ' ,'^.v :;,;: ;v;.;,:' ;;i; .' ",'' ;'',' ฐ:':'''( ,'"'', v':1.', ' ': ', ' "'"' " ; '." ; ;*. ;t;
iiif llfl'i'f' lit ': iills^^ext use .the.^lolbs/nTjn'releaseJ^e.frorri'Ae pipeline breakage example above for a 2" line rupture..
- "f- ' " SI!, The amount released after the pump stops can be calculated as follows. . ,-
i) ft 1-: II!*.,!1-'!- i t>i ::; ;ar*< ym <( <.: i ::>">,: f'-i""" '',;''"'I1';',!" ''I'f, 'fl '!l ;" ' !':! f1; ,':i11 "' lij.i;1 "'1 l|"1." .v .lli;"| '"' ' 'l"''1''il'ii n,"1 [ ,!: ';'':': ", l>,:;: ;ii"r I' I' ^ . . '' I , ;1 '' '"''',' ;'
' ' "V"1" " '" ' "" ' : "' ' ':'
""..;..'' "".'. ', , ' ' ' ''
'astljfsjing the Method 1 equation, determine the distance to endpoint for 1 psi overpressure:
..'1!? '"' , S!S =' JT(M"*$!x H^r/HC^1* = 17 x 3.281 (0.1 x 5164 / 2.2046 x 46333 / 46'8p)%' = ' ^ " | "r
':;?: ' ""''iJss'^i^feet " " " '' ' :;" "''' ' ' "" " "' ' "
Pi''! ill1 ' !i ' ll1!:!!"!! i I1.1* '. " r- '' ii IBM: n i y-, "KI : ' ' ' '," ' ' ,;,ป ,r:w. , i-,
! ป/' -m.:\ 'i&il l>^::V::>V:r.:V ' ' i ':': ;..?" : ' '!:'>*&' ,
-j'/'f:!; 'lis! -;: W( A table summarizing similar situations is shown below:
,!!!": is;;: ป,(ซ . in -i, i. ...... . >:', ,'.i iii;1'! !ป,! >'. i,1 i i . '.,', ','''!, -'l-/ f '
'tftMlisi : 11; 'i:' ;.;'/' P'^'lli [firi'".1-.::V;::-i?--M ' i , > i i ';'', ' '": :''": - '"-.' ' ";.'.:!?Vi''
;:;;;;;;,;;;;;;;; ; ,;;,,i1;1;,,",: :,:,;;;,;;;;;" , ,'";', , , ",;;;:;;:;;, , , ,:, " , ;; ,, rp A T>T "C1 C
:;IIlOllii: ^Ji:;111!!.!1!'!111'11"111:1'11'!111! ; " . *;'!ป i ";' '.*! ...V'i ,, . .< '.^-..'.f- ^ i J.AJjl /r/ j
**" f^* '" ! :!''.:,:' ':,;: :"'"'!;''"" !;!: '::i^DISCMRGELINE BIUSAKS WHILE PUMPING' ' ""' '." "
' "' " !;'': is'(for ' " ' ' ' "
" illlln"'! ill1
iili;
Pump Size
or
Compressor
Size
3x2
2x2
4x3
490
690
Max
Discharge
Rate
(GPM)
140
100
300
200
330
Amount
Released
by
Pumping
(Ibs)
1764
1260
3780
2520
4158
Discharge
Line Size
(inches)
Amount
Discharged
After
Pump
Stops (Ibs)
3400
3400
7655
3400
7655
Total
Amount
Released
Obs)
5164
4660
11435
5920
11813
Distance
to
Endpoint
(Miles)
0.1
0.1
0.2
0.1
0.2
October 22,1998
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37
Risk Management Program Guidance
OVERFILL STORAGE TANK - RELIEF VALVE LIFTS
A safety relief valve lifts (causes: Overpressure or overfilling [failure of your level indicator and
administrative procedures]).
A four- valve multiport relief valve has a flow capacity of 27,750 SCFM/Air at 300 psi with three of
the four valves lifting. Estimate the amount of propane discharged from one port over 5 minutes and
the distance to endpoint if the vapor cloud finds a source of ignition and explodes. The density of air
is 12.39 ft3/lb and the density of propane is 8.66 fi?/lb. To convert SCFM (air) to SCFM (propane) multiply
by 0.808. .
The release rate from one port is 27,950 SCFM (air/ 3 = 9,250 SCFM (air)
= Q(aio>< 0.808 / 8.66 tf/lb = 863 Ibs/min x Smin = 4,3151bs= 1957.4 kg
D = 17 ( 0.10 x 1957.4 x 46,333/4680) Va = 21 1.9 meters x 3.281 ft/meter = 695.2ft / 5280ft/mile =
0.13 miles.
TABLE 6
RELIEF VALVE DISCHARGES (FOR 1 PSI OVERPRESSURE)
Relief Valve Size
(inches)
Multiport 21/2"
Dual Port 1ป4"
21/2"
V/2"
W4"
1 "
Capacity
SCFM of
Air
9,250
' 5,250
10,390
6,080
5,280
3,340
Release Rate
(Ibs/min)
Propane
863
490
969
567
492
312
Duration
(rriin)
5
5
5
5.
5
5,
Amount
Released
(Ibs)
4,315
2,449
4,847
2,836
2,463
1,558
Distance to
Endpoint
(Miles)
0.1
0.08
0.1
0.1
0.1
0.09
October 22, 1998
-------
".," llllllli1'1'!1! I"!'111'1!!!!1:1'!!'! I'MT:"il ! JiNFII"1
Risk Management Program Guidance
38
Oclober22,
-------
39 Risk Management Program Guidance .
CHAPTER 3: FIVE-YEAR ACCIDENT HISTORY
The five-year accident history involves an examination of the effects of any accidental releases of one
or more of the regulated substances from a covered process in the five years prior to the submission of
a Risk Management Plan (RMP). A five-year accident history must be completed for each covered
process,, including the processes in Program 1, and all accidental releases meeting specified criteria
must be reported in the RMP for the process.
Note that a Program 1 process may have had an accidental release that must be included in the five-
year accident history, even though the release does not disqualify the process from Program 1. The
accident history criteria that make a process ineligible for Program 1 (certain offsite impacts) do not
include other types of effects that require inclusion of a release in the five-year accident history (on-site
impacts and more inclusive offsite impacts). For example, an accidental release may have led to
worker injuries, but no other effects. This release would not bar the process from Program 1 (because
the injuries were not offsite), but would need to be reported in the five-year accident history.
Similarly, a release may have resulted in damage to foliage offsite (environmental damage), triggering
reporting, but because the foliage was not part of an environmental receptor (e.g., national park or
forest) it would not make the process ineligible for Program 1.
WHAT ACCIDENTS MUST BE REPORTED?
The five-year accident history covers only certain releases:
The release must be from a covered process and involve a regulated substance held above its
threshold quantity in the process. -, _
. The release must have caused at least one of the following: -
> On-site deaths, injuries, or significant property damage (ง68.42(a)); or .,
> Known offsite deaths, injuries, property damage, environmental damage, evacuations,
or sheltering in place (ง68.42(a)).
If you have had a release of a regulated substance from a process where the regulated substance is held
below its threshold quantity, you do not need to report that release even if the release caused one of the
listed impacts or if the process is covered for some other substance. You may choose to report the
release in the five-year accident history, but you are not required to do so.
WHAT DATA MUST BE PROVIDED?
The following information should be included in your accident history for every reported release. The
descriptions below are those used for the RMP*Submit system and data element instructions:
Date. Indicate the date on which the accidental release began.
October 22, 1998
-------
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* Fire. A fire is combustion producing light, flames, and heat.
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"Explosion. An explosion is a rapid chemical reaction with the production of noise, heat, and
ป ;i,'".r-i" ",'.ป " - ^ ซ < '".'Violent expansion of gases. , ' . ^
lilJILlllllili: 'I1 ii"',i!, I, ' :,',|, .,. ll!!1":" !' ป t .' J !1llli:i, H ,1 ,| '"H ' '" ,m i ,!, '! !.!!. !' 1, |.i ', ' , " ,','!' I . H ' , ' ,' ' '' " - ' 'i|i ,, ,i ' i1,1:! , 'I , ' ,' ,"''.,
nillllllli iUI'l ill, I I 1 n, lhi |H' :; " i'i / i ,, " ,i, "' ' ' I IIHIl ' ,M "1|1" ' ,' '' , 'i':'1!," 'l!|i! JiP '"' !" ' lpi "' "'i'"1'1!, i i, i.,', ! ,i, ' I,,, ',v, , , ,, jป , ji , ' ' i, i | , , ,j. , ซ
:sji:i ]R.eleaseisour^ei. Indicate all that apply.
Storage Vessel. A storage vessel is a container for storing or holding gas or liquid. Storage
flfeyi!''. ''i1'"'}"1 " ' i|i:ii !. r",' 'v'iejsseis' jnciude transportation containers being used for on-site' storage.
'''ป ..... in1
Piping. Piping refers to a system of ^ tubular structures or pipes used to carry a fluid or gas.
Process Vessel. A process vessel is a container in which substances under certain conditions
(e.gJ, temjperature, pressure) participate in a process (e^g., substances are manufactured,
; t?|ended to form a mixture, reacted to convert them into some other final product or form, or
B ' ' ' . . ' ,' . :, ' '.
i'll, illlllir W, I",,'!' L r> '"' I"''!!:!" , , Jill!! ! l ' ':-!', r "'' .I I iili'H '! , I I I ' ' '. '.' ' ,' J "
^:; !;,liซV,.;i;f .! ; ip;,;''1' * . i,' Transfer Hose. A transfer hose is a tubular structure used to connect, often temporarily, two
October 22,1998
""imii in1!1 in *. i >. i"1;" ,; : i
anil: JIM! f,, j: I'h r.;,:. i u'
-------
41 , . Risk Management Program Guidance
. Valve. A valve is a device used to regulate the flow in piping systems or machinery. Relief
valves and rupture disks open to release pressure in vessels.
Pump. A pump is a device that raises, transfers, or compresses fluids or that attenuates gases
by suction or pressure or both.
Joint. The surface at,which two or more mechanical components are united.
Other. Specify other source of the release.
Weather conditions at time of event (if known). This information is important to those concerned
with assessing and modeling the effects of accidents. Reliable information from those involved in the
incident or from an bn-site weather station is ideal. However, this rule does not require your facility to
have a weather station. If you do not have an onsite weather station, use information from your local
weather station, airport, or other source of meteorological data. Historical wind speed and temperature
data (but not stability data) can be obtained from the National Climatic Data Center (NCDC) at (828)
271 -4800; NCDC staff can also provide information .on the nearest weather station. To the extent
possible, complete the following:
* . Wind Speed and Direction.' Wind speed is an estimate of how fast the wind is traveling.
Indicate the speed in miles per hour. Wind direction is the direction from which the wind
comes. For example, a wind that blows from east to west would be described as having an
eastern wind direction. You may describe wind direction as a standard compass reading such
as "Northeast" or "South-southwest." ~
You may also describe wind direction in degrees with North as zero degrees and East as 90
degrees. Thus; northeast would represent 45 degrees and south-southwest would represent
,202.5 degrees. Abbreviations for the wind direction such as NE (for northeast) and SSW (for
south-southwest) are'also acceptable. '
Temperature. The ambient temperature at the scene of the accident in degrees Fahrenheit. If
you did not keep a record, you can use the high (for daytime releases) or low (for nighttime
releases) for the day of the release. Local papers publish these data.
Stability Class. Depending on the amount of incoming solar radiation as well as other factors,
the atmosphere may be more or less turbulent at any given time. Meteorologists have defined
six atmospheric stability classes', each representing a different degree of turbulence in the
atmosphere. When moderate to strong incoming solar radiation heats air near the ground,
causing it to rise and generating large eddies, the atmosphere is considered unstable, or
relatively turbulent. Unstable conditions are associated with stability classes A and B. When
solar radiation is relatively weak, air near the surface has less of a tendency to rise and less
turbulence develops. In this case, the atmosphere is considered stable or less turbulent with
weak winds. The stability class is,E 6rF. Stability classes D and C represent conditions of
neutral stability or moderate turbulence respectively. Neutral conditions are associated with
relatively strong wind speeds and moderate solar radiation. The neutral category D should be
used, regardless of wind speed, for overcast conditions day or night, and for any sky
October 22, 1998 . - ' ' '
-------
Risk Management Program Guidance
42
conditions during the hour preceding or following the night. Exhibit 2 presents the stability
classes associated with wind speeds, time of day, and cloud cover.
"::': x'i : : i^.EJJBmTT2 "'' .
ATMOSPHERIC! STABILiTY CLASSES
K ''.
SURFACE WIND SPEED
AT 10 METERS ABOVE
GROUND
Meters per
second
<2
2-3
3-5
5-6
>6
Miles per
hour
<4.5
4.5-7
7-11
11-13
>13
-t ' : >* .', . .
.. DAY ; -. -:.: "''.-. ...
Incoming Solar Radiation
Strong*
A
A-B
B
C
C
Moderate
A-B
B
B-C
C-D
D
Slight**
B
C
C
D
D
'/ ANIGHT* ". ''. ^
1 ..-.-'" -"....' - - - '-.- '. r .---..'-
Thinly
Overcast
or > 4/8
low cloud
E
D
D
D
<;3/8
Cloud
F
E
D
D
to one hour before sunset to one hour after dawn.
J .:!!*,. Sun nigh In the sky with no clouds.
** Sun low in the sky with no clouds.
Precipitation Present. Precipitation may take the form of hail, mist, rain, sleet, or snow.
Indicate "yes" or "no" based on whether there was any precipitation at the time of the accident.
Unknown. If you have no record for some or all of the weather data, indicate "unknown" for
ariy missing item. We realize that you may not have weather data for accidents that occurred
in the past. You should, however, collect these data for any future accidents.
On-site impacts. Complete the following about on-site effects.
Deaths. Indicate the number of on-site deaths that are attributed to the accident or mitigation
activities. On-site deaths means the number of employees, contract employees, off site
responders, or others (e.g., visitors) who were-killed by direct exposure to toxic
coriceniratibns, radiant heat, or overpressures from accidental releases or from indirect
consequences of a vapor cloud explosion from an accidental release (e.g., flying glass, debris,
October 22,1998
-------
43 Risk Management Program Guidance
other projectiles). You should list employee/contractor, offsite resppnder, and other on-site
deaths separately.
Injuries. An injury is any effect that results either from direct exposure to toxic
concentrations, radiant heat, or overpressures from accidental releases or from indirect
consequences of a vapor cloud explosion (e.g., flying glass, debris, other projectiles) from an
- accidental release and that requires medical treatment or hospitalization. You should list
injuries to employees and contractors, offsite responders, and others separately.
Medical treatment means treatment, other than first aid, administered by a physician or
registered professional personnel under standing orders from a physician. :
Your OSHA occupational injury and illness log (200 Log) will help complete these items for
employees.
Property Damage, Estimate the value of the equipment or business structures, (for your
business alone) that were damaged by the accident or mitigation activities. Record the value
in American dollars. Insurance claims may provide this information. Do not include any
losses that you may have incurred as a result of business interruption. . '
Known offsite impacts. These are impacts that you know or could reasonably be expected to know of
(e.g., from media reports or from reports to your facility) that occurred as a result of the accidental
release. You are not required to conduct an additional investigation to determine offsite impacts.
, ' ' ;. " Q&A ''.. ' ' . '.. ,
PROPERTY DAMAGE .
Q. What level of offsite property damage triggers reporting? ,
A. Any level of known offsite property damage triggers inclusion of the accident in the five-year
accident history. You are not required to conduct a survey to determine if such damage occurred,
but if you know, or could reasonably be expected to know (e.g., because of reporting in the
newspapers), that damage occurred, you must include the accident.
Deaths. Indicate the number of offsite deaths that are attributable to the accident or
mitigation activities. Offsite deaths means the number of people offsite who were
killed by direct exposure to toxic concentrations, radiant heat, or overpressures from
accidental releases or from indirect consequences of a vapor cloud explosion from, an
accidental release (e.g., flying glass, debris, other projectiles). .
Injuries. Indicate the number of injuries among people offsite. Injury means any effect that
results either from direct exposure to toxic concentrations, radiant heat, or overpressures from
October 22, 1998
-------
.M/PII :'i JuM " "'!,,,ซ:' ,"" niiiiti :",;. i i, ". A: ' .'" fci1"1;} :
IV 411 .' i!i!! i'i'i'1! ,' ' illllltil 1 1 ' ' /n, 'i'1 '' '!' ' I HUM
!"!|l!l l!!!l"!:i" ! Jll'!l' :11|"!! Risic &!an%gement Program Guidance 44
,,].'" r '" 'ป* ' ;] isii!1!!, "if ป! 1,,'i'i1!,1" liji,:11',,! ". iiHiMiM : :"r ,",,: ;. '? i. i,';:; 'i'1:., - i,:1 ."IT:, "' u;!1".1111;!'1:; u, >
accidental releases or from indirect consequences of a vapor cloud explosion from an
accidental release (e.g., flying glass, debris, other projectiles) and that requires medical
treatment or hospitalization.
; Evacuated. Estimate the number of people offsite who were evacuated to reduce exposure
that might have resulted from the accident. A total count of the number of people evacuated is
preferable to the number of houses evacuated. People who were ordered to move simply to
improve access to the site for emergency vehicles are not considered to have been evacuated.
Sheltered. Estimate the number of people offsite who were sheltered-in-place during the
accident Sheltering-in-place occurs when community members are ordered to remain inside
their residence or place of work until the emergency is over to reduce exposure to the effects
of jie accidental release.. Usually these orders are communicated by an emergency broadcast
of similar method of mass notification by response agencies.
Ill I I ^ *'',!;! K.II! i: ,ii|.' . ' |! ;, ' !", ,!,/' fl,: . , ....... /;',:: ,!'/! I '!' J111'1'1' '' ,":"",:" V' '. ''i1'1' ''I11', I "'!>,;"; V ;'' ' iP '; "' I'1 ' ' ' '
Environmental Damage. Indicate whether any environmental damage occurred and specify
111 III I II 1 1 ' '' '';, ..'llr.i'iil'i UH L ..... ........ I ", . r; " ..... ,/ ....... ,, ...... ,ซ /; ....... ....... ..... /,:! ....... i w I ' I II ':,,!,,' ...... HUN; ........ ... ...... , ..... .......... ,', ,,i ...... ..... , ...... , !'-' ..... , ,' , ~ :
the type. The damage to be reported is not limited to environmental receptors listed in the
rule. Any damage to" the environment (e.g., dead or injured animals, defoliation, water
contamination) should be identified You are not, however, required to conduct surveys to
determine whether such impact occurred. Types of environmental damage include:
" '> ...Fish or animal kills. ^ , ...... | ^ _ ^ _ - , T ...... i .
..>,.. taWn, srirub, or crop damage minor defoliation.
> Lawn, shrub, or crop damage major defoliation.
p- Water contamination.
> Other (specify).
in :., ; , ,'|' i v, , ' ,i: :'i|i|,i i a,, ,:. M , i, ^ , , . ,.,,. ,; , ,, ,, '.,,,, 'ri| ',',,; ^\, ' , , ....... , ,. l: ,: , | ,/ , l , f: , ,,;: ,j , , , ' ., , , .; '
Initiating event. Indicate the initiating event that was the immediate cause of the accident, if known.
If you conducted an investigation of the release, you should have identified the initiating event.
lull hi , i ' i i !i ' i i * ,-" ; K;: . .;'
^Equipment Failure. A device or piece of equipment failed or did not function as designed.
Fpr example, the vessel wall corroded or cracked.
II I fill ' ..... , Y ' i ........ hlll:ili: , ..... " JliiiJi.'ill,',ail isl-ii.',^i'lSJlilli:-""i i'iilllil:, v:,-tiiL:,!'-,,! s'i Iiซi:^'i:liilLtiiUL~C't:liJh,,itLLaiiifel^^'i-..'i,ii..; i,' ^ ..."'Jii/:.1 .:,, ',,;: .: ."iliij1',:ซ., ,r.Ji
-------
45. Risk Management Program Guidance
Equipment Failure. A device or piece of equipment failed to function as designed, thereby
allowing a substance leading to or worsening the accidental release. '
Human error. An operator performed an operatipn improperly or made a mistake.lead to or
'' worsened the accident.
. Improper Procedures. The procedure did not reflect the proper method of operation, the
procedure omitted steps that affected the accident, or the procedure was written in a manner
that allowed for misinterpretation of the instructions.
. Overpressurization. The process was operated at pressures exceeding the design working
pressure.
* Upset Condition. Incorrect process conditions (e.g., increased temperature or pressure)
contributed to the release. -
By-pass Condition. A failure occurred in a pipe, channel, or valve that diverts fluid flow from
. the main pathway when design process or storage conditions are exceeded (e.g., overpressure).
By-pass conditions may be designed to release the substance to restore acceptable process of
storage conditions and prevent more severe consequences (e.g., explosion).
Maintenance Activity/Inactivity. A failure occurred because of maintenance activity or,
inactivity. For example, the storage racks remained unpainted for so long that corrosion
caused the metal to fail.
, .. Process Design. A failure resulted from an inherent flaw in the design of the process (e.g.,
pressure needed to make product exceeds the design pressure of the vessel).
, Unsuitable Equipment. The equipment used was incorrect for the process. For example, the
forklift was too large for the corridors.
Unusual Weather Conditions. Weather conditions, such as lightning, hail, ice storms,
tornados, hurricanes, floods, or high winds contributed to the accident.
Management Error. A failure occurred because management did not exercise its managerial
control to prevent the accident from occurring. This is usually used to describe faulty
procedures, inadequate training, inadequate oversight, or failure to follow existing
administrative procedures. '.-.''.*'
Whether offsite responders were notified. If known, indicate whether response agencies (e.g.,
police, fire, medical services) were contacted.
Changes introduced as a result of the accident. Indicate any measures that you have taken at the
facility to prevent recurrence of the accident. Indicate all that apply.
October 22, 1998
-------
Risk Management Program Guidance
46
Improved/Upgraded Equipment. A device or piece of equipment that did not function as
designed was repaired or replaced.
Hปi:i.IปWi I'III* . ,-.' Sllf] .r'i :))<.#' .' ilirfr ;;'.'; -,'. I*!-,:,;,,, i'" ,*''' t fL"" .n Ji-,.r, <,..!:( W \ '',,ซ ซ .' ' I ,- ., - , 1 ' . .:
is;,;,* Revised Maintenance. Maintenance procedures were clanfied or changed to ensure
appropriate and tirnely maintenance including inspection and testing (e.g., increasing the
iiSi i-;; ir; :i!v,;,;v lin
aง*liS:<: 1' . ' ,' ;.'
Changed Process. Process was altered to reduce the risk (e.g., process chemistry was
/!i:"'' '"'"sv i" ' ' ' ''' " '< <''' ' '"" '' .''ii.' ป ' ' - " .i '
changed).
Ill '.:
I 'I ' ' I J
I in i i i I i in ' :.,'
Reduced Inventory. Inventory was reduced at the facility to reduce the potential release
quantities and the magnitude of the hazard.
i ' , . ' ' ! '
Other,
None. No changes initiated at facility as a result of the accident (e.g., because none were
necessary or technically feasible). There may be some accidents that could not have been
prevented because they were caused by events that are too rare to merit additional steps. For
example, if a tornado hit your facility and you are located in an area where tornados are very
rare, it may not be reasonable to design a "tornado proof' process even if it is technically
feasible.
PART 68 INCIDENT INVESTIGATION
An incident investigation is a requirement of the rule (ง68.60 and 68.81). These requirements are
virtually identical to the requirements under OSHA PSM. For accidents involving processes
categorized in Program 2 or Program 3, you must investigate each incident which resulted in, or could
reasonably have resulted in, a catastrophic release of a regulated substance. A report, which includes
the following information, should be prepared at the conclusion of the investigation:
October 22.1998
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47
Risk Management Program Guidance
Date of incident , ,
Date investigation began
Description of the incident
Factors that contributed to the incident" .
\ '
Any recommendations resulting from the investigation.
Because the incident investigation report must be retained for five years, you will have a record for
completing the five-year accident history for updates of the RMP. " -
October 22, 1998
-------
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en , v:r -. "", - VRE ' !,ii ,*- 'v : : ;,!,;'.*?'''"' :i,
i'i:1 ซ;!,":; :^i ; m '! ; --' i, -W'. :;:"i: '.;, !^':i::!;'!i: ,! ,;;r".iv;^
"'"::" """48 '"'
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October 22,1998
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49 Risk Management Program Guidance
CHAPTER 4: MANAGEMENT
68.15 Management (Only for Program 2 and Program 3; for Program 1, go to Chapter 7.
(a) The owner or operator of a stationary source with processes subject to Program 2 or Program 3
shall develop a management system to oversee the implementation of the risk management program
'elements. . ' .
(b) The owner or operator shall assign a qualified person or position that has the overall
responsibility for the development, implementation, and integration of the.risk management program
elements. '
The owner or operator of this propane storage facility has assigned the following
qualified person, . ' . '
or this qualified position,
the responsibility for the development, implementation, and integration of the risk management
program elements. . .
(c) When responsibility for implementing individual requirements of this part is assigned to persons
other than the person identified under paragraph (b) of this section, the names or positions of these
people shall be documented and the lines of authority defined through an organization chart or similar
document. .
Any position indicated below must report to the person or position that has overall authority for the
risk management program. This is the person or position that you identified above. You may decide
that certain people will be responsible for development of the program and that other people will be
responsible for day-to-day operation of the program. You must make sure that your team(s) are
reflected in your management system and that they report to someone with overall authority. You may
use reporting diagrams to describe the reporting relationships rather than the chart below. Remember,
whichever documentation is used, it must be updated when personnel or position changes are made.
Completing Worksheet 4 will fulfill this responsibility: .
October 22, 1998
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Risk Management Program Guidance
50
. WORKSHEET 4
"" ' ''MANAGEMENT SYSTEM
Risk Management Program
Element
Safety Information:
Hazard Review:
Operating Procedures:
Training:
Maintenance:
Compliance Audits:
Accident Investigation:
Person or Position Assigned Responsibility
ill:!!- i.i. ! : ;ii;:" 8 I' .... Siliiij
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Risk Management Program Guidance
CHAPTER 5: PROGRAM 2 PREVENTION PROGRAM
EPA developed the Program 2 prevention program by identifying the basic elements that are the
foundation of sound prevention practices safety information, hazard review, operating procedures,
training, maintenance, compliance audits, and accident investigation. By meeting other Federal
regulations, state laws, industry codes and standards, and good engineering practices, you probably
have already met most of the Program 2 prevention elements requirements.
As important as each of the elements is, you will not gain the full benefit from them unless you
integrate them into, a risk management system that you implement on an on-going basis. For example,
the hazard review must be built, on the safety information; the results of the hazard review should be
used to revise and update operating and maintenance procedures. Workers must be trained in these
procedures and must use them every day. .
There are seven elements in the Program 2 prevention program, which is set forth Subpart C of part
68. Exhibit 3 sets out each of the seven elements and corresponding section numbers.
You must integrate these seven elements into a risk management program that you and your staff
implement oh a daily basis. Understanding and managing risks must be part of the way you operate.
Doing so will provide benefits beyond accident prevention. Preventive maintenance and routine
inspections will reduce the number,of equipment failures and down time; well-trained workers, aware
of optimum operating parameters, will allow you to gain the most efficient use of your processes and
raw materials.
EXHIBITS
SUMMARY OF PROGRAM 2 PREVENTION PROGRAM
Number
ง68.48 ,
ง68.50
ง 68.52 .
ง68.54
ง68.56
ง68.58
ง 68.60
Section Title "
Safety Information
Hazard Review
Operating Procedures
Training
Maintenance
Compliance Audits
Incident Investigation
October 22, 1998
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Risk Management Program Guidance 52
IS'^8.48 SAFETY INFORMATION
Jilt;!-'; '"^'^'Tilffll,':^'.^
(a) The owner or operator shall compile and maintain the following up-to-date safety information
related to the regulated substances, processes, and equipment:
|faving up-to-date information about your process is the foundation of an effective accidental release-
prevention program. Many elements (especially the hazard review) depend on the accuracy and
thoroughness of the information this element requires yo'u to have.
(1) Material Safety Data Sheets [MSDSs] that meet the requirements of 29 CFR 1910.1200(g);
The purpose of this requirement is for you to document the hazardous characteristics of propane, so
that you have the information to share with the community and your employees. An MSDS that is
constructed in compliance with OSHA's 29 CFR 1910.120b(g) effectively documents such hazards.
This is one part of OSHA's Hazard Communication Standard, and it is an example of the common
sense approach EPA and OSHA bring to the accident release prevention programs. If you do not have
an up-to-date MSDS for propane, you should request one from your propane supplier. Obtain an up-
to-date MSDS for propane and file it with your other process safety information.
(2) Maximum intended inventory of equipment in which the regulated substances are stored or
processed.
This is the total amount of propane (in pounds) which can be safely stored in your storage tanks.
Chapter, Table 2, provides the maximum capacity of propane tanks at 60ฐF. The maximum intended
inventory may be greater than your actual inventory if you limit the quantity you hold in a tank.
The maximum intended inventory of my propane distribution
facility is: '. . pounds.
V'j ' -, "'. '': ' ;::i-i'i'';. . \. '>',. w-\-s'.'' ':";;*,'v::l:i;'':V '
From Ciiapter 1
!';Tfhis may be the total that you calculated for each vessel in each process on Worksheet 1 unless you
(3) Safe upper and lower temperatures, pressures, flows, and compositions;
You need this information to understand the operating parameters for your facility. These ranges
define the safe conditions under which you operate your propane storage facility. Excursions beyond
these ranges represent abnormal conditions or upset conditions. You must first recognize what is
considered normal operation, so that you can devise safety mechanisms to guide operator responses to
abnormal situations. Many of these procedures have been developed by the National Propane Gas
Association. Transfer .the following information to your file of process safety information:
> Propane is a gas at normal temperatures and pressures. It is liquefied by storing it in a
closed container at pressures higher than its equilibrium vapor pressure. There is a
October 22.1998
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53 Risk Management Program Guidance
direct relationship between ambient temperature and the pressure inside the storage
container. As the ambient temperature increases, the pressure of the container
increases proportionately. According to NFPA 58, 1998 Edition, Table B-l.2.1,
commercial propane when heated to a temperature of 105 ฐF will produce a pressure
of 210 pounds per square inch, gauge (psig). NFPA ,58, 1998 Edition, Table 2-2.2.2
sets the current minimum design pressure for an ASME tank at 250 pounds per square
inch, absolute (psia). This design allows for a maximum vapor pressure of 215 psia at
100 ฐF. The discharge piping for pumps and compressors is currently designed to 350
psi and vapor piping is designed for 250 psi according to NFPA 58, 1998 Edition, 3-
2.10.2. The minimum temperatures are determined by the steel used in design of-
storage tank and the piping. Liquid propane (if released at atmospheric pressure) can
refrigerate steel pipes and tanks down to temperatures of -44 ฐF.
* Another property of propane in its liquid form is its ability for the liquid to greatly
expand when heated. Therefore, NFPA 58, 1998 Edition sets the maximum filling
capacity of large tanks in Table 4-4.2.2(b) to avoid overfilling.
If you have a policy to only fill your propane storage tanks to a certain volume, put that policy in
writing, and save it with this process safety information. Written procedures are considered to be
administrative controls by EPA, and you can take credit for having written administrative procedures
for certain parts of this rule.
(4) Equipment Specifications;
* ' V. ' "' - . ^
You must maintain equipment specifications for all equipment that is part of a covered process,
including your bulk storage tank(s), piping, pressure relief valves, hydrostatic relief valves, emergency
shutoff valves, temperature, pressure and level gauges, valves, pumps, compressors, and hoses.
Specifications for your bulk, propane storage tank(s) are provided on the nameplate attached to, the
tank (refer to NPGA # 4200 CETP "Basic Principles and Practices"for more informatiqn)15. If you do
not have the specifications for the other items, you can request it from your vendors. It is
recommended that you file all the. vendor specification information that you collect for your critical
equipment in one place.
(5) Codes and standards used to design, build, and operate the process.
You must document the codes and standards you used to. design and build your facility and that you
follow to operate. These codes will probably include the electrical and building codes that you must
comply with under state or local laws. Your equipment vendors will be able to provide you with
information on the codes they comply with for their products.
Table 7 summarizes the process safety information for a typical propane storage facility to give you an
idea of what may be expected. -'..'. ,
.. ' - 1S NPGA # 4200 Certified Employee Training Program, "Basic Principles and Practices" Section 1.3.
October 22, 1998
-------
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Rlslc Management Program Guidance
54
IABLE 7
MOCESS;;SA|ETY; INFORMATION ,
Example Process Safety Information: Propane Storage
Item
MSDS Propane
Maximum Intended Inventory
Nominal Water Capacity of Largest
Tank
Temperature
Pressure '
Flow Rate
Vapor Piping
Liquid Piping & Compressor
Discharge
Safety Relief Valves
RV1
RV2
RV3
RV4
Internal Valve
Excess How Valve
EFV1
EFV2
EFV3
EFV4
Emergency Shutoff Valve
ESV1
ESV2
Description
Dated 6/95
400,000 pounds
60,899 Gallons
Upper: ambient max 1 10ฐF
Lower: ambient min -15ฐF
Upper: 240 PSI @ 110ฐF
Lower: 35 PSI @ -15ฐF
Loading: 100 GPM (max)
Unloading: 265 GPM (max)
250 PSIG
350 PSIG
Each valve relieves 9,250 SCFM/air, three are required at
all times a fourth is provided to allow maintenance
Replaced 9/95
Replaced 7/96
Replaced 6/97
Installed 7/88 scheduled for replacement 7/98
3", closes at 260 GPM with 100 PSIG inlet
3", closes at 225 GPM with 100 PSIG inlet
2", closes at 100 GPM with 100 PSIG inlet
2", closes at 34,500 SCFH with 100 PSIG inlet
114", closes at 10,000 SCFH with 100 PSIG inlet
1 1/4", closes at 26,000 SCFH with 1 00 PSIG inlet
2", closes at 225 GPM with 100 PSIG inlet
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55
Risk Management Program Guidance
Item
Hydrostatic Relief Valve
HSV1
HSV2
HSV3
HSV4
HSV5
HSV6
Pump 1
Pump 2 -
Compressor 1
Compressor 2
Vaporizer
Strainer
Check valves
Sightflow Indicator
Tank Level Indicator
Tank Temperature Indicator
Tank Pressure Indicators
Other Temperature Indicators
Other Pressure Indicators
Design Codes
State or Local Codes
Piping Design
Tank Design
Vaporizer Design
Date of Most Recent Revision
8/31/98
Description
V2", opens at 450 PSIG
same
same
same , - . . . '
same . ' -
same , .
2"x 2" 75 GPM at 100 PSID
3"x 2" 100 GPM at 100 PSID
Sz 490, 200 GPM at 250 PSI, 15 HP '
Sz 690, 265 GPM at 250 PSI, 20 HP
Type: Direct Sz. 1.9.x 106 Btu/Hr Flow: 6,000 Gal/Hr
3" ' ; ' ' .
m" ' ....-...-
3", internal backcheck
10" Dial with internal float -
-20-1500p; 6" dial
0-300 PSI, 8" dial
0-200 ฐF, 3V4" dial
0-300 PSI, 2"dial
Plant Designed under NFPA 58- 1 985
ASMEB31.3
ASMENB#0012 State ID # 324576
ASME NB # 4900 State ID # 123456
Revised by:
, John Smith
October 22, 1998
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Risk Management Program Guidance
The following worksheet has been provided to help you assemble your process safety information.
(ill
(IK
: WORKSHEET 5
PROCESS SAFETY INFORMATION
'I! t
Process Safety Information Worksheet: Propane Storage
Item
MSDS Propane
Maximum Intended Inventory
Nominal Water Capacity of Largest
Tank
Temperature
Pressure
Flow Rate
Vapor Piping
Liquid Piping
Safety Relief Valves
RV1
RV2
RV3
RV4
Internal Valve
Excess Flow Valve
EFV1
EFV2
EFV3
EFV4
Emergency Shutoff Valve
ESV1
ESV2
Description
Upper: .
Lower:
Upper:
Lower:
Loading:
Unloading:
i
I,
October 22, 1998
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57
Risk Management Program Guidance
Item
Hydrostatic Relief Valve
HSV1 ':.
HSV2 , '
HSV3
HSV4
HSV5
HSV6
Pump 1
Pump 2
Compressor 1
Compressor 2
Vaporizer
Strainer
Check valves
Sightflow Indicator
Tank Level Indicator
Tank Temperature Indicator
Tank Pressure Indicators
Other Temperature Indicators
Other Pressure Indicators
Design Codes
State or Local Codes
Piping Design
Tank Design
Vaporizer Design
Date of Most Recent Revision
, ' Description
.'-,- ' . - '
'
Type: Sz. Flow:
.- '
.. _. '
ASMENB# State ID# '
ASMENB# State ID#
Revised By:
- - ,
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Risk Management Program Guidance
58
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After you have documented your safety information, you should double check it to be sure that the
,li!.^Jeง you have reflect the equipment you are currently using. It is important to keep this information
ffiffjip1-ibHdateT Whenever you replace equipment, be sure that you put the new equipment specifications
in the file and consider whether any of your other prevention elements (e.g., operating procedures or
operator training) need to be reviewed to reflect the new equipment.
(b) The owner or operator shall ensure that the process is designed in compliance with recognized
and generally accepted good engineering practices. Compliance with Federal or state regulations
that address industry-specific safe design or with industry-specific design codes and standards may be
I used to demonstrate compliance with this paragraph.
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The Equipment specifications and lists of standards and codes will probably meet the final
requirement, that you ensure mat your process is designed in compliance with recognized and
generally good engineering practices. If you have any doubt that you are not meeting this requirement,
you should contact your trade association to determine if there are practices or standards that you are
aware qf that may be useful in your operation.
' '' ' ' '
ii
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The design code used to design, build and operate your propane storage facility will likely be the
edition of NFPA 58 adopted by your state or local regulatory authority and in effect when your facility
Was built.
I I 'l| i ' ' ' '..- ; ' ',
Good practice is to keep your facility up-to-date with the current edition of NFPA 58.
'"';: ' : , ' ' ' ! \, ' ;
(c) The owner or operator shall update the safety information if a major change occurs that makes
the information inaccurate.
Modification of facility may be governed by the appropriate edition of NFPA 58 as mandated by your
state and local LJP-Gas regulations You must document the codes used to design any modifications to
your facility. List each of the major changes that have occurred at your facility, the year that the
change was installed, and the appropriate design code (the edition of NFPA 58 or the state or local
code) used in the table below:
WORKSHEET 6
MAJOR CHANGES
Description of Major Change
Reviewed By:
Year Installed
Appropriate Design Code
Date:
October 22.1998
llHIll, <", liSlili ' >' :,F '.. ill II
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59 Risk Management Program Guidance
This document has been designed using NFPA 58, 1998 Edition. Your state or local authorities may
have approved earlier editions. You should be ready to explain any'differences between your facility
design and the current requirement of your state or local regulatory authority.
68.50 HAZARD REVIEW
(a) The owner or operator shall conduct a review of the hazards associated with the regulated
substances, process, and procedures.
For a process eligible for Program 2, you do not have to perform a full Process Hazard Analysis (PHA)
as required by OSHA's PSM standard, but you must conduct a hazard review. 'EPA has streamlined
the PHA to create a requirement that will help you detect process hazards in your plant without being
overly burdensome. The hazard review will help you determine whether you are meeting applicable
codes and standards, identify and evaluate the types of potential failures, and focus your emergency
response planning efforts,
The review shall identify the following:
, (1) The hazards associated with the process and regulated substances;
(2) Opportunities for equipment malfunctions or human errors that could cause an accidental
release; .''.' -
(3) The safeguards used or needed to control the hazards or prevent equipment malfunction or
human error; and
(4) Any steps used or needed to detect or monitor releases. '
(b) The owner or operator may use checklists developed by persons or organizations knowledgeable
about the process and equipment as a guide to conducting the review. For processes designed to meet
industry standards or Federal or state design rules, the hazard review shall, by inspecting all .
equipment, determine whether the process is designed, fabricated and operated in accordance with
the applicable standards or rules. , .
You can conduct the hazard review by completing the attached checklist while you are physically
inspecting the equipment in your- propane storage facility. The Checklist has been prepared based on
the requirements of NFPA 58, 1998 Edition and supplemented with additional information from
NPGA Safety Bulletin #106-83 "LP-Gas Bulk Storage Safety Inspection Checklist". If you use this
checklist, you may have to modify it to address site-specific concerns. You must be sure that it
addresses all of your potential problems. You may need to consider external events as well as internal
failures. If you are in an area subject to earthquakes, hurricanes, or floods, you should examine
whether your plant would survive these natural events without releasing the substance. You should
consider the potential impacts of lightning strikes and power failures. If your equipment could be hit
by vehicles, you should examine the consequences of that. If you have any thing near the plant that
could burn, ask yourself what would happen if the fire affected the plant.
(c) The owner or operator shall document the results of the review and ensure that problems
identified are resolved in a timely manner. ' '
October 22, 1998
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Risk Management Program Guidance
60
lid
(d) The review shall be updated at least once every five years. The owner or operator shall also
conduct reviews whenever a major change in the process occurs; all issues identified in the review
shall be resolved before startup of the changed process.
i ill1 11 i i i i i ' , ' ,:' '.'i'''
You must complete, update, and re-validate your hazard review according to the requirements and
time-tables in the risk management program rule. You must re-validate your hazard review at least
every five years.
::: v" : ,: PROPANE,,STORAGE:FACILITY'
'. HAZARD REVIEW CHECKLIST1*17 '
Answer the questions below by indicating "Yes", "No" or "N/A" (for not applicable). "No" responses
require further comment and a projected completion date for correcting the deficiency.
,. fl!
Siting
1 . Does the arrangement of your fixed storage tanks conform with
the minimum distances allowed in Table 3-2.2.2 of NFPA 58,
1998 Edition?
2. Are your fixed storage tanks separated from any oxygen or
hydrogen storage by the minimum distances given in Table 3-
2.2.7(f) of NFPA 58, 1998 Edition?
3. Are your transfer points separated from the exposure points by
the minimum distances given in Table 3-2.3.3 of NFPA 58, 1998
Edition?
Piping, Equipment & Container Appurtenances
1. Is your storage facility designed according to ASME code for
pressure vessels?
Fixed Storage Tanks ASME?
Vaporizers ASME?
Yes/No/NA
Comments
Yes/No/NA
Comments
11 III ill
111 111 II
11
Completing the Propane Storage Facility Hazard Review Checklist does notjuarantee thatyour facility is in complete
compliance with NFPA 58,1998 Edition.
'* The Propane Storage Facility Hazard Review Checklist is based on NFPA 58,1998 Edition. Over the/ears, various
i ii changes tn NFPA 58 have been made to reduce the probability of a propane release. You should carefully review any change to
NFPA 53 since your facility was constructed and consider appropriate charges to ensure the safety of your facility. Document the
nu actions tnatyou take. You should be ready to explain any differences between the version of NFPA 58 thatyou used to construct
your facility and the current version.
1,1,1 ill i i ... .".!, , :,- . :.. :
October 22.1998
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61
Risk Management Program Guidance
Piping, Equipment & Container Appurtenances
2. Is the pressure rating of your storage tanks appropriate for the -
product in service?
Storage Tanks? . '
Vaporizers? . ; , -
3. Is the stored product properly identified?
4. On installations with multiple tanks, are the elevations of your
storage tanks arranged to prevent unintentional overfilling of the
lowest container? ~
5. On installations with stairways or ladders, are they well
anchored, supported and of slip proof construction?
6. On installations with stairways or ladders, are railings provided
and in good condition? , ' '
7. On installations with stairways or ladders, are catwalks
provided so personnel need not walk on any portion of the
container?
8. Is your piping designed according to NFPA 58, 1998 Edition,
Section 3-2. 10?
Are your pump and compressor discharge and liquid transfer
'lines suitable for a working pressure of 350 psi?
Is your vapor piping suitable for a working pressure of 250 psi?
On installations with' vaporizers, are your vaporizers
designed according to 2-5.4.2 or 2-5.4.3 or 2-5.4.4 and
2-5.4.5 or 2-5.4.6 or 2-5.4.7 of NFPA 58, 1998 :
Edition?
9. Is the relief capacity of your pressure relief devices:
For fixed storage tanks, designed according to Sections 2-3.2
and 3-2.5 or 3-2.6 of NFPA 58, 1998 Edition?
On installation with vaporizers, are your vaporizers
designed according to 2-5.4.5 or 2-5.4.6 or 2-5.4.7 of
NFPA 58, 1998 Edition? ,
Yes/No/NA
',
,v "
Comments
*
October 22, 1998
-------
111 III
111 111
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10. Is the capacity of your pressure relief devices designed
according to 2-3.2 and 3-2.5 or 3-2.6 of NFPA 58, 1998
Edition?
Have your relief devices been tested or replaced every ten years
according to the good practice recommended by Section E-2.3.2
of NFPA 58, 1998 Edition?
1 1. Do you have appropriate level gauges, temperature indicators,
and pressure gauges installed on your fixed ASME storage
tanks as specified in 2-3.3.2(b), 2-3.3.3, 2.3.4, 2.3.5 of NFPA
58, 1998 Edition?
12. Do you have the appropriate hydrostatic relief valves installed
between every section of liquid piping which can be blocked by
manual or automatic valves according to 2-4.7 and 3-2.1 1 of
NFPA 58, 1998 Edition?
13. Do you have the appropriate corrosion protection required by 3-
2.14 of NFPA 58, 1998 Edition?
14. On installations with pumps, are they installed according to 3-
2.15.1 of NFPA 58, 1998 Edition?
On installations with automatic bypass valves, are they installed
on the discharge of your pump according to 3.2.15(b)l and 2-
5.2 of NFPA 58, 1998 Edition?
15. On installations with compressors, are they installed according
to 2-5.3 and 3-2.15.2 of NFPA 58, 1998 Edition?
On installations with compressors, is there either an integral
means of preventing liquid from entering the compressor or a
liquid suction protection trap according to 3-2.15.2(b) of NFPA
58, 1998 Edition?
16. Do your compressor and pump motors conform with 2-5.1.4 of
NFPA 58, 1998 Edition?
17. On installations with liquid strainers, are they installed on the
suction of your pump or meter according to 3-2.15.3 and 2-5.5
of NFPA 58, 1998 Edition and capable of being cleaned?
18. On installations with flexible connections on pumps,
compressors or loading and unloading bulkheads, are they
installed as specified by 2-4.6 of NFPA 58, 1998 Edition?
19. Do you have either excess flow valves, backflow check valves
or internal valves as specified by 2-3.3.3 and 3-3.3.7 of NFPA
58, 1998 Edition?
I
Yes/No/NA
Comments
October 22,1998
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63
.Risk Management Program Guidance
- a, .
Piping, Equipment & Container Appurtenances
20. Do you have container appurtenance protection as specified in
2-3.7 of NFPA 58, 1998 Edition?
21. Do you have manual valves and emergency shutoff valves as
required by 2-4.5.4, 3-2.10.1 1, 3-3.3.7 and 3-3,3.8 of NFPA 58,
1998 Edition? , . .
22. On installations with vaporizing equipment, is it installed
according to 2-5.4 and 3-6 of NFPA 58, 1998 Edition?
Have the liquid traps, temperature controls, and interlocks been
tested per the manufacturer's guidelines?
23. On installations with regulators, are they installed according to
2-5.7 and 3-2.7 of NFPA 58, 1998 Edition?
24. Do you have a breakaway stanchion as required by 3-9.4.2 of
' NFPA 58, 1998 Edition?
25. On installations with swivel -type piping, are they installed as
specified by 3-2.1 0. 1 1 (a) of NFPA 58, 1998 Edition?
26. Are all above ground lines securely fastened to structural
members of adequate strength and supported at proper "
intervals? , .
27. Are pressure gauges located so that they will not be exposed to
physical damage?
28. Are there sufficient lines for all purposes, without improper dual
. use' or make-shift connections beinglised for some operations?
29. Are hoses the correct type for each use? '
30. Are hose couplings of the correct type and properly attached
(fully seated on the hose)?
31. Is adequate transfer hose storage provided?
32. Are the written transfer, loading & unloading instructions
available (see ง 68.52 of this model program)?
Human Factors
1 . Have your operators been trained on the written operating
instructions for this propane storage facility (see ง 68.54 of this
model program)? -
2. -For operators on the job on or before June 2 1 , 1 999, do they
have the required knowledge, skills and ability to perform their
duties safely?
Yes/No/NA
Yes/No/NA .
Comments
-
*
Comments
October 22, 1998
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Human Factors
3. Are your operators whose job duties require the use of the
above listed equipment understand the operating limits of the
system in regards to:
Capacity?
Pressure?
Temperature?
Adverse Weather or Natural Conditions?
4. Have your operators been trained in the correct response to
conditions which exceed the operating limits of the system?
5. Have your operators been trained in their duties for emergency
conditions?
Fire?
LP Gas Release?
Severe Weather or Natural Conditions?
6. Are the written operating instructions available to the operators
(see ง 68.52 of this model program)?
7. Do the written operating instructions reflect current operation of
the facility (see ง 68.52 of this model program)?
8. Have major modifications to your propane storage facility taken
place (see ง 68.48 of this model program)?
9. Are contractors used at the facility?
10. Are safe work practices such as lock/tag, hot work and line
opening followed at the facility?
11. Is there a written emergency response plan (see Subpart E of
this model program)?
Is it current?
Have your operators been trained?
Do you provide emergency response equipment?
Has it been checked?
Yes/No/NA
Comments
111 11
Ocwber22,1998
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65
Risk Management Program Guidance
* ' " ' . . / ' -
General Hazards
1 . Does your propane storage facility have protection against
tampering as specified in under 3-3.6 of NFPA 58, 1998
Edition?
2. Does your propane storage facility have lighting as specified in
3-3.7 of NFPA 58, 1998 Edition?
3. Is the area around your containers and transfer piping free of all
combustible material?
4. Has a fire safety analysis been performed for your propane
storage facility as suggested by 3-10.2.2 and 3-10.2.3 of NFPA
58, 1998 Edition?
5. Has your fire safety analysis been reviewed by your local fire
authority?
6. Has your facility been required by your local fire authority to
provide special protection?
Fixed Water Sprays/Monitor Nozzles?
Insulating Coatings? ....
Mounding/Burial?
Other types?
7. Has a federal, state or local agency or fire authority required:
Local Gas Detection Monitors?
Perimeter Gas Monitors and Public Alarms?
Yes/No/NA
Comments ,
'
This Hazard Review was Completed by: On (Date):
. ' -'-.
The latest date by which all changes resulting from the process hazard review are expected
to be completed is ' ' . ' -
Date ' -.
68.52 OPERATING PROCEDURES
(a) The owner or operator shall prepare written operating procedures that provide cle'ar instructions or
steps for safely conducting activities associated with each covered process consistent with the safety
information for that process. Operating procedures or instructions provided by equipment
manufacturers or developed by persons or organizations knowledgeable about the process and
equipment may be used as a basis for the stationary source's operating procedures.
October 22, 1998
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Ill 111
Risk Management Program Guidance
AfVritt^n operating procedures describe the tasks your operators must perform, safe process operating
parameters that must be maintained, and safety precautions for operations and maintenance activities.
These procedures tell your employees how to work safely every day, giving everyone a quick source of
information thai pan prevent or mitigate the effects of an accident, and providing workers and
management with a standard against which to assess performance.
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'""The National Propane Gas Association (NPGA) Certified Employee Training Program (CETP)18 and
NPGA Safety Bulletins" can be used to meet this requirement. Other training programs may be
available that wj|I also be) acceptable.
E'iTh'e following Table 8 shows how this requirement can be satisfied using CETP and the NPGA Safety
,1 iiiM, v 'I'll r": ,;"i,! !, V ^, , *r ' ' J
Bulletins. Other equivalent programs may be substituted in lieu of CETP and NPGA Safety Bulletins
to satisfy this requirement.
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The procedures shall address the following:
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iJJjj;'l; 7? [*" iifif;1'. " , ' 'ii'1 -v i "1^ National Propane Gas Association. Certified Employee Training Program. 1600 Eisenhower Lane. Suite 100. Lisle.
"I ', i.Tl',, "'''"' ' - !l!'!'ll(inols6b532l 'Telepnoner^S'O) 515-0600.' ' '
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19 National Propane C3as Association, Safety Handbook. 1600 Eisenhower Lane, Suite 100, Lisle, Illinois 60532.
telephone: (630) 515-0600.
Oelober22,1998
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67
Risk Management Program Guidance
TABLES
OPERATING PROCEDURES REQUIREMENTS
Procedure
Requirement
(1)
(2)
(3)
(4)
Initial Startup:
Normal
Operations:
Temporary
Operations:
Emergency
Shutdown and
Operation:
NPGA Certified Employee
Training Program
(CETP)
Distribution
Systems
Operations
Distribution
Systems
Operations
Transfer
Systems
Transfer
Systems
Plant
Operations
Plant
Operations
Plant
Operations
'ropane
Delivery
Plant
Operations
"Preparing Propane Storage
Containers for Installation."
"Identifying Procedures
Used to Pressure Test and
Leak Check New Propane
Distribution Systems."
"Identifying Propane
Pumps and their
Operation."
"Identifying Parts and
Devices Basic to
Compressors."
"Filling Propane Storage
Containers."
''Unloading a Propane
Transport."
"Unloading a Propane
lank Car."
'Filling Cargo Tanks on
3ulk Delivery Vehicles."
'Removing Propane from
Stationary ASME Tanks
and DOT Cylinders."
,
NPGA Bulletin
200-89
202-81
. -
v _, .
How to Control LP-
Gas Leaks & Fires
What you should do
in case of accidents
involving LP-Gas
October 22, 1998
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Risk Management Program Guidance
68
Procedure
Requirement
(5)
(6)
(7)
(8)
Normal (Manual)
Shutdown:
Startup following
a normal or
emergency
shutdown or a
major change that
requires a hazard
review: See item
'!) above.
Consequences of
deviations and
steps required to
correct or avoid
deviations.
Equipment
inspections.
NPGA Certified Employee
Training Program
(CETP)
NPGA Bulletin
202-93
1204-88
206-91
207-94
211-91
Steps to Take in the
Event of an Accident
Involving Propane
How to Handle LP-
Gas Fires with
Portable Fire
Extinguisher
Emergency Response
Guidelines
Guidelines for
Developing Plant
Emergency
Procedures
LP-Gas Fire Control
andHAZMAT
Training Guide
October 22,1998
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Risk Management Program.Guidance
(c) The owner or operator shall ensure that the operating procedures are updated, if necessary,
whenever a major change occurs and prior to startup of the changed process.
68.54 TRAINING
(a) The owner or operator shall ensure that each employee presently operating a process, and each
employee newly assigned to a covered process, have been trained or tested competent in the
Operating Procedures provided in ง 68.52 that pertain to their duties. For those employees already
operating a process pn June 21, 1999, the owner or operator may certify in writing that the employee
has the required knowledge, skills and abilities to safely carry out the duties and responsibilities as
provided in the operating,procedures.
Training programs often provide immediate benefits because trained workers have fewer accidents,
damage less equipment, and improve operational efficiency. Training gives workers the information
they need to understand how to operate safely and why safe operations are necessary. A training
program, including refresher training, is the key to ensuring that the rest of your prevention program is
effective. ' .
Complete the following to certify that employees operating a process on or before June 21, 1999, have
the requisite knowledge, skills, and abilities to operate ,the process safely.
The following employees were already operating this propane storage facility on June 21,
1999. These employees have the required knowledge, skills, and abilities to safely carry out
the duties and responsibilities as specified in the operating procedures.
WORKSHEET?
EMPLOYEES WORKING PRIOR TO 6/21/99
Employee Name
Employee I. D. #
,
Certified by:.
Owner/Operator (signature)
Date
October 22, 1998
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You must train all new workers in the operating procedures you are using to comply with ง 68.52. If
any of your more experienced operators need training on" these procedures, you should also.train them.
^ny time the procedures are revised',"you must train everyone on the changed procedures. At least
once every three years, you'must provide refresner trainingon the operating procedures even if they
have not changed. The training must cover all parts of the operating procedures, including information
on the consequences of deviations and steps needed to address deviations or upset conditions.
You are not required to provide a specific amount of training or type of training for the EPA Risk
Management Program. You should develop a training approach that works for you. If you are a small
facility, one-on-one training and on-the-job training may work best. Larger facilities may want to
provide classroom training or video courses developed by vendors or trade associations. You may
have senior operators present the 'training or use trainers provided by vendors'or other outside sources.
The form and length of the training will depend on your resources and the complexity of your
processes. If you can teach someone the."basics in two hours, that could be acceptable. The important
thing is that your workers understand how to operate' safely arid carry out their tasks properly. We are
interested in the results of the training, not the details of how you achieve them. Find a system that
works for you.
You are also required to ensure that each worker trained has understood the training and is competent
to operate the process safely. You may decide what kind or kinds of competency testing to use.
Observation by a senior operator may be appropriate in many cases. If you provided classroom
training, you may want to use both testing and demonstration or observation. You are required to
report in the RMP on the type(s) of competency testing you use.
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In the RMP, you are required to report on the date of the most recent review or revision of your
training program. You are also required to report on the type of training required (e.g., classroom or
on-the-job) and the type of 'competency tesi3ng"u''sed. You should keep > bri site any current training
materials or schedules used" The rule does riot require you to keep particular records of your training
program. It is enough for you to have on site information that supports what is reported in the RMP
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and your implementation of the training program overall. You may want to keep an attendance log for
any formal training courses and refresher training to ensure that everyone who needs to be trained is
't^ai^Sd,. $ucl} logs will help you perform a compliance audit or demonstrate compliance with the rule
' alth ough you are' not required 'to Iceep fogs for this rule.
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The following training guidelines or recommended practices qualify as industry-specific standards and
'"ttfay 't>e'! used" in" whole or hi part'to meet the training requirements. iSelect the' appropriate training from
the possibilities listed below (see ง 68.52 of this model program for more information on the written
procedures to be encompassed by the training program) and make any modifications necessary to tailor
t^
ซ All of the Operating Procedures listed in the Operating Procedure section of this guidance.
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,,I ! Certified Employee Training Program (CETP) that includes the following modules.
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Risk Management Program Guidance
iii. "Distribution System Operations."
iv. "Transfer Systems." , .-. .
' . , v. "Plant Operations."
Other recognized training programs that address similar aspects of operating an LP Gas
distribution facility which may or may not be required by the state or local authority having
jurisdiction.
(b) Refresher Training. Refresher training shall be provided at least every three years, and more
often if necessary, to each employee operating a process to ensure that the employee understands arid
adheres to the current operating procedures of the process. The owner or operator, in consultation
with employees operating the process, shall determine the appropriate frequency of refresher training.
' You must conduct refresher training at least once every three years. Make sure that your employees
understand the training and are using your operating procedures. Talk with your operators to
determine how often refresher training needs to be conducted. Remember, you must conduct refresher
training at least once every three years. . . .
(c) The owner or operator may use training conducted under Federal or state regulations or under
industry-specific standards or codes or training conducted by covered process equipment vendors to
demonstrate compliance with this section to the extent that the training meets the requirements 'of this
section. ,
Do not forget that DDT 40 CFR 172.704(c)(2) requires refresher training every three years. The DOT
training may be considered part of the training required to fulfill the refresher training requirement.
Also remember that your particular state or local authority may have additional requirements for
refresher training, which should be included in your overall training program.
(d) The owner or operator shall ensure that operators are trained in any updated or new procedures
prior to startup of a process after a major change.
Most recent review of training program.
on
Name
Date
68 56 MAINTENANCE
(a) The owner or operator shall prepare and implement procedures to maintain the on- going
mechanical integrity of the process equipment. The owner or operator may use procedures or
instructions provided by covered process equipment vendors or procedures in Federal or state
regulations or industry codes as the basis far stationary source maintenance procedures.
Preventive maintenance and inspection and testing of equipment are critical to safe operations
Waiting for equipment to fail could also mean waiting for an accident that could harm people and the
environment. Further, a thorough maintenance program will save you money by cutting down-time
caused by'equipment failures. ,
October 22, 1998
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>u must prepare and implement procedures for maintaining the mechanical integrity of your process
E-Tequipmenlt/and'train yb'iir workers' in the maintenance procedures'.' You may use procedures or
*ฃ injections from equipment vendors, in Federal or state regulations, or in industry codes as the basis
j::!;r6f youf'maintenarice program!' You should develop a schedule for inspecting and testing yoiir
equipment base3 on manufacturers' recommendations or your own experience.
ง; g jซ^. fjjlsj'stgp "Wiil''probably be to determinewnetfier you" already" meet''all the requirements. If you
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TO::-'(ป!*!''ซ. .''.;; iiiia'reyiew your existing wntten procedures and determine that they are appropnate, you do not,need to-
revise or redo these procedures. If your workers are already trained in the maintenance procedures and
carry them out, you may not need to do anything else.
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^'jtf you do not have written procedures, you will need to develop them. Your equipment vendors or
"i Ss'^Suf tnide asso_ciation may be able to provide procedures and maintenance schedules. Using these as a
' ''' lr ......... " "Hasis 'for your maintenance program is acceptable, if there are existing standards, your trade
association can provide you with the references. Copies of these standards may also provide a basis
for your maintenarice program^ If there are federal or state regulations thatrequire certain
maintenance, ydu should use these as well.
You need to determine if procedures provided by vendors, manufacturers, trade associations or others
are appropriate for your operation. If your safety information indicates that you are operating in a
standard way (e.g., using your equipment in the way it was designed), you may assume that these other
procedures will work for you. If you are using equipment for purposes other than those for which it
was designed, you need to decide whether your use changes the kinds of maintenance required.
(bj The owner or operator sfia.ll train or cause to be trained each employee involved in maintaining
the on-going mechanical integrity of the process. To ensure that the employee can perform the job
' i.ซi ''( '.':J* ': ...... 'ffjtisfa'in ..... a gafe manner, each such employee shall be trained in the hazards of the process, in how to
avoid or cprreciiinsafe conditions, and in the procedures applicable to the employees job tasks.
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(c) Any maintenance contractor shall ensure that each contract maintenance employee is trained to
perform the maintenance procedures developed under (a) [of this section.
Once you have written procedures, you must ensure that your maintenance workers are trained in the
procedures and In the hazards of the process. As with the training discussed in the previous section,
.ซ;'':'how you provide this"training"is'"up to'you.' We believe that you are in the best-position' to decide how
:::;" t " ป''.> ......... "i JUl'. ""'Ii11! I ........ *'*'' ........ ,'hra1 kll" . ...... ". ....... ; ""V .. - '."" .,' ...... ! .......... "' ..... ................... ....... i. ..... .';', i " ' ', " "'
;|ซ; , C/FJR. \yiQ.12QQj training. You do not need to repeat this training to comply with this rule.
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October 22,1998
11 liii
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73
Risk Management Program Guidance
If you hire contractors to do your maintenance, you should ensure that they are trained to carry out the
procedures. Under the rule, any maintenance contractor is required to ensure that each contract
maintenance worker is trained to perform the maintenance procedures developed by the facility. You
can help ttiis process by providing training or by developing agreements with the contractor that give
you the assurance that only trained workers will be sent to your site. For any outside worker, you must
ensure that they are informed of the hazards of your particular process. If you have standard
equipment and hire contractors that specialize in servicing your types of processes, you can ensure
their knowledge through agreements with the contractor. The Certified Employee Training Program
(CETP) and the NPGA Safety Bulletins, published by the National Propane Gas Association (NPGA),
meet this criterion. -
You may select the combination of training that best fits the duties of each employee involved with
maintaining the integrity of your propane storage and handling equipment at your propane storage
facility from the maintenance training suggested.below in Table 9:
October 22, 1998
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Risk Management Program Guidance
74
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TABLE 9
- ': MAINTENANCE TRAINING
Module Certified Employee Training Program (CETP)
Basic Principles
Basic Principles
Basic Principles
Basic Principles
Transfer Systems
Operations
Transfer Systems
Operations
Transfer Systems
Operations
Transfer Systems
Operations
Transfer Systems
Operations
Distribution Systems
Distribution Systems
Distribution Systems
Distribution Systems
Distribution Systems
Distribution Systems
Distribution Systems
Distribution Systems
Plant Operations
Plant Operations
Plant Operations
Plant Operations
Plant Operations
Plant Operations
Identifying the Proper Use of Personal Protective Equipment
Identifying the Proper Use of Tools and Equipment
Identifying by Sight Hand Tools Commonly Used by Service Technicians
Identifying Pipe/Tube, Pipe/ Fittings, and Associated Tools
Identifying Propane Pumps and Their Operation
Identifying the Standards for Sizing, Installing and Inspecting Pump Protective
Devices
Troubleshooting Propane Pumps and Metered Delivery Systems
Identifying Parts and Devices Basic to Compressors
Maintaining and Troubleshooting Compressors
Identifying the Operating Characteristics of Propane Vapor Regulators and
Metering Systems
Installing Propane Vapor Regulating and Metering Systems
Sizing Pipe for Use in Low Pressure Propane Distribution Systems
Identifying Steel/Wrought Iron Piping Materials and Installing Procedures
Identifying Tubing Materials and Installing Procedures
Identifying and Sizing Vaporizer Systems
Sizing Propane Liquid Piping Systems
Identifying Installing and Servicing Procedures for Vaporizer Systems
Identifying the Operating Characteristics of Pressure Relief Valves
Identifying and Installing Gauges in Propane Storage Containers
Identifying the Operating Characteristics of Check Valves
Identifying the Operating Characteristics of Service Valves
Installing Valves in Propane
Inspecting Servicing and Maintaining Container Valves
October 22,1998
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75 "
Risk Management Program Guidance
Module Certified Employee Training Program (CETP)
Transfer Systems
Operations
Transfer Systems
Operation
Distribution Systems
Operations
Transfer Systems
Operation
Distribution Systems
Operations
Distribution Systems
Operations
Distribution Systems
Operations
Distribution Systems
Operations
Identifying the Operation and Maintenance of Withdrawal Valves
Identifying the Operation and Maintenance of Bulkheads and Emergency Shutoff
Valves (ESVs) ',.'
Installing Propane Liquid Distribution and Vaporizer Systems
Identifying the Operation and Maintenance of Hoses, Hose End Valves, and Hose
Reels
Identifying the Causes of Corrosion on Metal Surfaces
i
Identifying Methods and Procedures Used to Protect Metal Structures from
Corrosion
Identifying Procedures Basic to Installing Anodes and Testing Cathodic Protection
Systems .
Identifying Procedures Used to Pressure Test and Leak Check !S[ew Propane
Distribution Systems ' .
(d) The owner or operator shall perform or cause to be performed inspections and tests on process
equipment. Inspection and testing procedures shall follow recognized and generally accepted good
engineering practices. The frequency of inspections and tests of process equipment shall be consistent
with applicable manufacturers' recommendations, industry standards or codes, good engineering
practices, and prior operating experience.
You must establish a schedule for inspecting and testing equipment associated with your propane
storage facility. You may obtain recommendations from manufacturers, vendors, or your trade
associations. You should, however, use your own experience as a basis for examining any schedules
'you obtain from others. Many things may affect whether a schedule is appropriate. The manufacturer
may assume a constant rate of use. If your use (e.g., the amount of propane pumped per hour) varies
considerably, the variations may affect the wear on the equipment. Extreme weather conditions may
also impact wear on equipment. ,
'Talk with your workers as you prepare, or adopt these procedures and schedules. If their experience
indicates that equipment fails more frequently than the manufacturer expects, you should adjust the
inspection schedule to reflect that experience. Your hazard review should have identified these
potential problems areas as well and should be used as you develop schedules. For example, if you
determined that exterior pipe corrosion is one of the hazards, your schedule would need to address
inspections for corrosion and replacement (or painting) before failure occurs. -Your trade association
may also be able to provide advice on these issues.
October 22, 1998
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Ill ill
Risk Management Program Guidance
76
WHAT MAINTENANCE DOCUMENTATION MUST I KEEP?
SEilh the RMP, you are required to report on the date of the most recent review or revision of your
^.li^nte.n.ance procedures and the date of the most recent equipment inspection or test and equipment
inspected or tested. You must keep on site your written procedures and schedules as well as any
jj^^agreements you'have'wlm'cdritractors. The mle ddes'nbVreJ^ire that you keep particular records of
|i|;:yb'usf ffiaintenance 'program? It is enough for you to have" on "site iriformation that supports what is
|[|'j&pibrte& in the RMP and your implementation of the maintenance program overall. For example, you
- ii'jrifigywanf to keep maintenance logs to keep track of when inspections and tests were done.
The "Maintenance Inspection Checklist and Tests for Propane Distribution Facilities"20 should be
completed annually. The NPGA CETP sections referenced above, can be used to prepare maintenance
inspection frequencies for individual equipment.
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October 22,1998
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77
Risk Management Program Guidance
Maintenance Inspection Checklist and Tests for Propane Storage Facilities
I. Construction Code Compliance
a) .
b)-,
Check manufacturer's data plate. Is it securely
attached and legible?
For each fixed storage vessel? .
On installations with vaporizers, for each vaporizer?
Are the data plate(s) free of corrosion?
n. Conditions of Container(s) and Vaporizer(s) and Paint
a).
b)
Are above-ground containers properly painted?
Fixed storage tanks?
On installations with vaporizers, the vaporizers?
Are containers and vaporizers free of corrosion
damage, dents, gouges, or other damage?
III. Foundations
a)
b)
c)
d)
Are foundations in good condition?
Are footings free of settling which might cause
misalignment or piping strain?
Are containers and vaporizers free of. corrosion at
masonry contact area?
Are saddle pads in good condition?
IV. Container Connections '
a)
Have excess flow and back flow check valves been
recently checked for proper operation?
V. Tank Fittings
a)
b)
c)
Are! all ACME (or other type) connectors in good
condition with good gaskets and are they plugged or ;
capped? (See NPGA Bulletin #1 34 "Care and
Inspection of ACME Threaded Hose Couplings.")
Are all unused openings plugged or capped?
Are all fittings and hoses leak free?
Yes
Yes
Yes
Yes
Yes
No and Comment
- . '
No and Comment
.
No and Comment
No and Comment
No and Comment
-
-
October 22, 1998
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Risk Management Program Guidance
78
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Maintenance Inspection Checklist and Tests for Propane Storage Facilities
d)
e)
f)
Are all hoses marked "for LP-Gas service" with a
pressure rating of 350 psig (see NPGA Bulletins # 107-
91 and #121-89)?
Are all hoses properly secured, protected, and in
serviceable condition and are dust caps on delivery
hoses when not in use?
Are all hoses free from cuts or abrasions that expose
the reinforcing fabric and free from soft spots or bulges
when under pressure and without kinks, dents or flat
spots?
VI. Gauges
a)
b)
c)
d)
e)
Are pressure gauges in good condition and are they
suitable for 250 psig service (such as 0-400 psig)?
Are thermometers in good condition and checked for
accuracy?
On installations with vaporizers having temperature
controls, are they in good condition and have they been
tested in accordance with manufacturer's
recommendations?
Are liquid level gauging devices approved for the
service involved and in good condition?
On installations with vaporizers having level control
devices, are they in good condition and have they been
tested in accordance with manufacturer's
recommendations?
VII. Pressure Relief Valves
a)
b)
c)
d)
e)
Is the relief valve data plate legible?
Do relief valves or vent stacks have protective caps or
closures to prevent entry of foreign matter?
Are weep holes for moisture drainage open and is gas
impingement on the container avoided?
Have the relief valves on containers larger than 2000
gallons and on vaporizers been tested or replaced
within the last 10 years as per NFPA 58, 1998 Edition
recommendation in E-2.3.2?
Does external visual inspection of the relief valve
discharge indicate no corrosion or obstruction?
Yes
Yes
- ,
No and Comment
No and Comment
'i PI'
October 22,1998
11 Sll1 n I.
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79
Risk Management Program Guidance
Maintenance Inspection Checklist and Tests for Propane Storage Facilities
Vffl. Emergency Shut-off Valves
a)
b)
c)
d)
e)
f)
Are valves in good condition and do they shutoff
tightly?
Does the emergency shutoff control system function
properly? . -
Are the remote shutoff controls installed in an
accessible area away from the transfer area?
Are the shutoff controls 'clearly identified?'
On installations with vaporizers having automatic
shutoff controls, are they accessible, identified and
been tested according to manufacturer's
recommendations?
Are the emergency shutoff valves and manual transfer
valves on your loading or unloading stations protected
from pull away damage by a break-away-stanchion.
IX. Presence of Combustibles
a)
Is the area within 10 ft. of the container(s) and
vaporizers free of weeds, long grass, rags, paper, wood
or other combustible debris?
X. Pipe (for Fixed Storage Tanks and Vaporizers)
a)
b)
c)
d)
Are all connections tight?
Are there sufficient lines for all purposes, without dual
use, or are make-shift connections being used for some
purposes? -'.'..
Are connections labeled "liquid" or "vapor"?
Are there visible signs of exterior corrosion?
XI. Valves (for Fixed Storage Tanks and Vaporizers)
a)
b)
c)
.d)
Are valves in good working order?
Do seats shut off tightly?
Is packing free of leaks?
Are necessary valve handles available at the valve
location? ;
Yes
Yes
Yes
Yes
No and Comments
No and Comments
No and Comments
No and Comments
- -
October 22, 1998
-------
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81
Risk Management Program Guidance
Maintenance Inspection Checklist and Tests for Propane Storage Faculties
e)
Is the compressor crank case oil at the proper level?
XV. Electrical Equipment
a)
b)
Do all switches, etc. function properly? "
Are all housings properly assembled to maintain seal?
Yes
No and Comments
Inspected By:
-
These procedures were last reviewed or inspected by:
Inspection
Date:
Date:
Name (signature)
Piece of Equipment Inspected:
,
Most Recent
Date:
68.58 COMPLIANCE AUDITS
(a) The owner or operator shall certify that they have evaluated compliance with the provisions of
this subpart at least every three years to verify that the procedures and practices developed under the
rule are adequate and are being followed. .. . - .
(b) The compliance audit shall be conducted by at least one person knowledgeable in the process.
(c) The owner or operator shall develop a report of the audit findings.
(d) The owner or operator shall promptly determine and document an appropriate response to each
of the findings of the compliance audit, and document that deficiencies have been corrected. .
(e) The owner or operator shall retain the two (2) most recent compliance audit reports. This,
requirement does not apply to any compliance audit report that is more than five years old.
Any risk management program should be reviewed periodically to ensure that employees and
contractors are implementing it properly. A compliance audit is a way for you to evaluate and measure
the effectiveness of your risk management program. An audit reviews each of the prevention program
elements to ensure that they are up-to:date and are being implemented and will help you identify
problem areas and take corrective actions. As a result, you'll be running a safer operation.
October 22,1998
-------
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i -"At least every three years, you must certify that you have evaluated compliance with EPA's
requirements for the prevention program for each covered process. At least one person on your audit
teami must bekno wledgeable about the process. You must develop a report of the audit's findings,
= aetenMne'and dgcume^nf^^^ finding, arid""document that you have '
'^^^^^^py'Je'gciency1.'
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j purpose of the compliance audit is to ensure that you are continuing to implement the risk
ieiit program"as requiredT 'kemBrnB'^'^^^'^'^^'^^^^!!! program is an on-going process; it
js not a set of docuinents that you develop and put on a shelf in case the government inspects your site.
be in compliance (and gain the benefits) procedures must be followed on a daily basis; documents
st be kept up-to-date. The audit will check these items and provide you with items that need to be
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You must check each of item in the prevention program. Because propane storage is a simple process,
the audit should not take a long time. You may want to develop a simple checklist of your own, or you
may use the following audit checklist.
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~'Once you have the checklist, you, your chief operator, or some other person who is knowledgeable
jJKabput'you'r process, singly or as a team, should walk through the facility and check on each of the
items, writing down comments and recommendations. You may want to talk with employees to make
sure if they have been trained and are familiar with the procedures.
You must respond to each of the findings and document what actions, if any, you take to address
problems. You must take steps to correct any deficiencies you find and document that the deficiencies
have been corrected.
You may choose to have the audit conducted by a qualified outside party. For example, you may have
Somebne form another part of your company do the audit or hire an expert in your process. If you do
either of these, you should have someone from your facility work with the person, both to understand
'i\^& findings and answer questions!
I
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Remember, this is an audit of compliance with the prevention program provisions of this rule. You
tW"''$&"~ป * ' ' ' '.' .y.".JII.ซ "> .'ซ',,, J' fr - ,.. - ,,.,, iK,vr,,ii,; , M, T.,iS .,,.,-Sn,.., .-i.if,.- . ,. , .,.,.. ... ; , , , . ., .
may choose to expand the scope to cover your compliance with other parts of the rule and the overall
safety of your operation, but you are not required to do so. You must keep a written record of the
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(d) The owner or operator shall investigate each incident which resulted in, or could reasonably have
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fฃ^) An incident investigation shall be initiated as promptly as possible, but not later than 48 hours
following the incident.
1998
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-------
83 ...... Risk Management Program Guidance
(c) A summary shall be prepared at the conclusion of the investigation which includes at a minimum:
Date of incident; '
' Date investigation began;
A description of the incident;
The factors that contributed to the incident; and,
Any recommendations resulting from the investigation.
(d) The owner or operator shall promptly address and resolve the investigation findings and
recommendations. Resolutions and corrective actions shall be documented.
(e) The findings shall be reviewed with all affected personnel whose job tasks are affected by the
findings. , "
(f) Investigation summaries shall be retained for five years.
See NPGA "LP-Gas Safety Handbook", NPGA bulletin #202-93 "After Accident Procedure."
/ . ': ' : ' . ' , .
Incidents can provide valuable information about site hazards and the steps you need to take to prevent
accidental releases. Often, the immediate cause of an incident is the result of a series of other
problems that need to be addressed to prevent recurrences. For example, an operator's mistake may be
the result of poor training. Equipment failure may result from improper maintenance or misuse of
. equipment. Without a thorough investigation, you may miss the opportunity to identify and solve
these problems.
You must investigate each incident which resulted in, or could have resulted in, a "catastrophic"
. release of propane. A catastrophic release is one that presents an imminent and substantial
endangerment to public health and the environment. Table 10 below briefly summarizes the steps you
must take to comply with ง 68.60. . ; .
October 22, 1998
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Rjsk Management Program Guidance
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TABLE 10
INCIDENT INVESTIGATION REQUIREMENTS
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Initiate an investigation promptly
Summarize the investigation in a report
Address the team's findings and
recommendations
Review the report with your staff, affected
employees and contractors
Retain the report
Begin investigating no later than 48 hours
following the incident
Among other things, this report will include the
factors contributing to the incident, Remember
that identifying the root cause may be more
important than identifying the initiating event.
Remember, also, that the purpose of the report
is to help management take corrective action.
Promptly address the incident report findings
and recommendations and document
resolutions and corrective actions.
You must share the report - its findings and
recommendations - with workers whose job
tasks are affected by the findings.
Keep incident investigation summaries for
five years.
You should start with a simple set'of procedures that you will use to begin an investigation. You may
Want to assign someone to be responsible for compiling the initial incident data, and putting together .
the investigation team. If you have a small facility, your "team" may be one person who works with
the local responders, if they were involved in the incident.
The purpose of the investigation is to find out what went wrong and why, so you can prevent it from
happening again. Do not stop at the obvious failure or the "initiating" event (e.g., the hose was
clogged, the operator forgot to check the connection or the hose cap was not replaced after it was last
used); try to determine why the failure occurred. In many cases, the underlying cause will be what
matters, .If the accident occurred because, of operator error, you should determine if the operator made
the mistake because tie or she had been trained in the wrong procedures or because design flaws made
the mistake likely i tf you write off the accident as operator error alone you miss the chance to take the
steps needed to prevent such errors the next time. Similarly, if equipment fails, you should try to
decide whether it had been used or maintained improperly.
Remember, your goals are to prevent accidents, not to blame someone, and correct any problems in
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many cases, ah investigation will not take long. If you have a complex facility, if equipment has
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-------
85
Risk Management Program Guidance
the manufacturer and your trade association to determine if similar equipment has suffered similar
failures.
You must develop a summary of the accident and its causes and make recommendations to prevent
recurrences. You must address each recommendation and document the resolution and any actions
taken. Finally, you must review the findings with operators affected by the findings'.
You must maintain the summary of the accident, recommendations, and actions. A sample format is
shown in Worksheet 8 below that combines all of these in a single form. Note that the form also
includes accident data that you will need for the five-year accident history. These data are not
necessarily part of the incident investigation report, but including them will create a record you can use
later to create .the accident history.
WORKSHEETS
SAMPLE INCIDENT INVESTIGATION REPORT
Date:
Duration:
Substance: Propane
Weather:
Quantity Released:
^
Description:
Findings
x
Recommendations
Actions
The expected completion date of any changes recommended by the investigation.
October 22, 1998
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II 111 11 111 III 111 I I 111 111 111
in 11 in mi in ill
Risk Management Program Guidance
86
October 22,1998
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87 . Risk Management Program Guidance
CHAPTERS: EMERGENCY RESPONSE
68.90 Applicability.
(a) Except as provided in paragraph (b) of this section, the owner or operator of a stationary source
with Program 2 and Program 3 processes'shall comply with the requirements ofง 68.95.
(b) The owner or operator of a stationary source whose employees will not respond to accidental
releases of regulated substances need not comply with ง 68.95 of this part provided that they meet the
following: "
(1) Not Applicable. , .
(2) For stationary sources with only regulated flammable substances held in a process above the
threshold quantity, the owner or operator has coordinated response actions with the local fire
department; and
(3) Appropriate mechanisms are in place to notify emergency responders when there is a need for
a response. <
-68.95 Emergency response program.
(a) The owner or operator shall develop and implement an emergency response program for'the
purpose of protecting public health and the environment. Such program shall include the following
- elements: . " '. ,
(1) An emergency response plan, which shall be maintained at the stationary source and contain
at least the following elements:
(I) Procedures for informing the public and local emergency response agencies about
accidental releases;
(ii) Documentation of proper first-aid and emergency medical treatment necessary to treat
accidental human exposures; and
(Hi) Procedures and measures for emergency response after an accidental release of a
regulated substance;
(2) Procedures for the use of emergency response equipment and for its inspection, testing, and
maintenance;
(3) Training for all employees in relevant procedures; and
(4) Procedures to review and update, as appropriate, the emergency response plan to. reflect
changes at the stationary source and ensure that employees are informed of changes.
(b) A written plan that complies with other Federal contingency plan regulations or is consistent with
the approach in the National Response Team's Integrated Contingency Plan Guidance ("One Plan")
and thai, among other matters, includes the elements provided in paragraph (a) of this section if the
owner or operator also complies with paragraph (c) of this section. . '. .
October 22, 1998
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II,
ป'!ซ,
Risk Management Program Guidance
88
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(c) The emergency response plan developed under paragraph (a)(l) of this section shall be
coordinated with the community emergency response plan developed under 42 U.S.C. 11003. Upon
request of the local emergency planning committee or emergency response officials, the owner
operator shall promptly provide to the local emergency response officials information necessary for
developing and implementing the community response plan.
I I I . K.1' , , , ' '
,1, , ,
If you have at least one Program 2 or Program 3 process at your facility, then part 68 may require you
to implement an emergency response program, consisting of an emergency response plan, emergency
response equipment procedures, employee training, and procedures to ensure the program is
up-to-date. This requirement applies if your employees will respond to some releases involving
regulated substances. The emergency response section of EPA's rule allows the owner or operator of a
propane storage facility to decide first whether the employees will respond to an accidental release of
propane and then what involvement the employees will have in the event of a release of propane.
If you choose not to have employees respond, then the response actions must be coordinated with the
local fire department and appropriate mechanisms must be in place to notify emergency responders
when there is a need for a response. You may want to consider this option when there is a public
response agency, trained and capable of responding to a propane release and the owner or operator is
, unable to safely field an appropriate response team. You, however, are responsible for ensuring
effective emergency response to any releases at your facility. If your local public responders are not
capable of providing such response, you must take steps to ensure that effective response is available
(e.g., by hiring response contractors).
, iff . , (',- ...'a;;-:, ','' r ..i1 ~| .'.,, .
WHAT IS RESPONSE?
EPA has adopted the definition of response specified under OSHA's HAZWOPER Standard. OSHA
defined emergency response as "a response effort by employees from outside the immediate release
area or by other designated responders ... to an occurrence which results, or is likely to result, in an
uncontrolled, release of a hazardous substance." The key factor here is that responders are designated
for such tasks by their employer. This definition excludes "responses to incidental releases of
hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the
time of release by employees in the immediate release area, or by maintenance personnel" as well as
"responses to releases of hazardous substances where there is no potential safety or health hazard (i.e.,
action
could be considered an incidental response and you would not need to develop an emergency response
ป if your employees are limited to such activities.
However, due to the nature of propane, only the most minor incidents would be considered incidental
"Irl'K* ' IB IJ'llt
-------
89 Risk Management Program Guidance
to ensure that your community has a strategy for responding to and mitigating the threat posed by a
release of propane from your facility. To do so, you must ensure that you have set up a way to notify
emergency responders and your local fire department when there is need for response.
ELEMENTS OF AN EMERGENCY RESPONSE PROGRAM (ง68.95)
If you will respond to releases of regulated substances with your own employees, your emergency
response program must consist of the following elements:
An emergency response plan (maintained at the facility) that includes:
> Procedures for informing the public and emergency response agencies about releases, - >
> Documentation of proper first aid and emergency medical treatment necessary to treat human
exposures, and
> Procedures and measures for emergency response. *
Procedures for using, inspecting, testing, and maintaining your emergency response equipment;
Training for all employees in relevant procedures; and
Procedures to review and update, as appropriate, the emergency response plan to reflect changes at
the facility and ensure that employees are informed of changes.
'',.
Finally, your plan must be coordinated with the community plan developed under the Emergency
Planning and Community Right-to-Know Act (EPCRA, also known as SARA Title HI). In addition, at
the request of local emergency planning or response officials, you must provide any information
necessary for developing and implementing the community plan.
Although EPA's required elements are essential to any emergency response program, they are not
comprehensive guidelines for creating an adequate response capability. Rather than establish another
set of federal requirements for an emergency response program, EPA has limited the provisions of its
rule to those the CAA mandates. Because you have propane on site, you are already subject to at least
one federal emergency response rule: OSHA's hazardous waste operations and emergency response
standard (HAZWOPER) (29 CFR 1910.120). Under HAZWOPER, any facility that handles
"hazardous substances" (a broad term that includes all DOT hazardous materials and all CAA
regulated substances, and thus applies to all facilities with covered processes) must comply with either
29 CFR 1910.38(a) (emergency action plan requirements) or 1910.119(q). If your employees will
respond to a release, as described above, you are subject to the 29 CFR 1910.119(q) requirements.
October 22, 1998
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What is a Local Emergency Planning Committee?
Local emergency planning committees (LEPCs) were formed under the Emergency Planning
and Community Right-to-Know Act (EPCRA) of 1986. The committees are designed to serve
as a community forum for issues relating to preparedness for emergencies involving releases of
hazardous substances in their jurisdictions. They consist of representatives from local
government (including law enforcement and firefighting), local industry, transportation groups,
health and medical organizations, community groups, and the media. LEPCs:
+ Collect information from facilities on hazardous substances that pose a risk to the
community;
+ Develop a contingency plan for the community based on this information; and
+ Make information on hazardous substances available to the general public.
Contact the mayor's office or the county emergency management office for more information on
yourLEPC.
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If you choose to respond, then you must prepare a written emergency response plan. You may wish to
consider using a format that complies with other Federal contingency plans such as the National
Response Team's Integrated Contingency Plan (One Plan) with procedures for the use of emergency
response equipment and appropriate training for the response personnel. At a minimum, your plan
must describe:
Your procedures for informing the public and offsite emergency response agencies of a release. .
This must include the groups and individuals that will be contacted and why, the means by which
they will be contacted, the time frame for notification, and the information that will be provided.
The proper first aid and emergency medical treatment for employees, first responders, and
members of the public who may have been exposed to a release of a regulated substance. This
must include standard safety precautions for victims (e.g., apply water to exposed skin
immediately) as well as more detailed information for medical professionals. You must also
indicate who is likely to be responsible for providing the appropriate treatment: an employee, an
employee with specialized training, or a medical professional.
Your procedures for emergency response in the event of a release of a regulated substance. This
must include descriptions of the actions to be taken by employees and other individuals on-site
pver the entire course of the release event:
ป Activation of alarm systems and interpretation of signals;
* Safe evacuation, assembly, and return;
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Risk Management Program Guidance
Selection of response strategies and incident command structure;
Use of response equipment and other release mitigation activities; arid
Post-release equipment and personnel cleanup and decontamination.
Table 11 can be used:
TABLE 11
EMERGENCY RESPONSE PLAN - NPGA REFERENCES
Emergencyjlesponse Plan Criteria
Procedures for informing the public and
local responders.
Document first-aid and any emergency
medical treatment necessary to treat
exposure to propane and/or a. propane
fire.
Document the actions required to respond
to a propane release.
NPGA Reference Procedure
LP-Gas Safety Handbook, "Guidelines for Developing Plant
Emergency Procedures," NPGA #207-94. '
LP-Gas Safety Handbook, "Material Safety Data Sheet,
MSDS, for Odorized Propane," NPGA #210-89. - - ' .
1. LP-Gas Safety Handbook, "How to Control LP-Gas Leaks
and Fires," NPGA #200-89. . *
2. LP-Gas Safety Handbook, "How to Handle Small LP-Gas
Fires with a Portable Fire Extinguisher, "'NPGA #204-88.
If you have already developed a written emergency response plan that incorporates the NPGA bulletins
listed above and that addresses the specific criteria, listed in EPA's rule, then you are not required to
rework your existing plans. Assemble the written plans that you have already developed and review
them to ensure that they are up-to-date.
PLANNING COORDINATION
One of the most important issues in an emergency response program is deciding which response
actions will be assigned to employees and which will be handled by offsite personnel. As a result,
talking to public response organizations will be critical when you develop your emergency response
procedures. Although EPA is not requiring you to be able to respond to a release alone, you should not
simply assume that local responders will be able to manage an emergency. You must work with them
to determine, what they can do, and then.expand your own abilities or establish mutual aid agreements
or contracts to handle those situations for which you lack the appropriate training or equipment.
If you have already coordinated with local response agencies on how to respond to potential releases of
regulated substances and you have ensured an effective response, you do not need to take any further .
action. ' .
Keep in mind: Your coordination must involve planning for releases of regulated substances from all
covered processes and must cover: ... ,
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Risk Management Program Guidance
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What offsite ; response assistance you will require for potential release scenarios, including
fire-fighting, security, and notification of the public;
' ;:,;|fow you" will request offsite "response assistance; 'and'
',,,,^|งip 'will be in charge of the response operation and how will authority be delegated down the
internal and offsite chain of command.
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j. iiYpu. will decide what degree of response your employees can safely take, weighing the type of
jn^o1 iiste the public responders are capable of supplying and designing a plan that melds the two
together. You can coordinate the facility plan with your community plan by involving your local
emergency response officials in the development of your facility emergency response plan. Your
facility plan can take advantage of any parts of the community plan where there is overlap. An
example of overlap may be the procedures in the community plan concerning public notification and
closure of streets in the vicinity of a release and the requirement that the written facility plan contain
p planning officials, you may
~ jigcj^etp SJlSf6, Jb? ;, responsibility for public notification with the facility taking responsibility for the
nearby neighbors very close to the facility and the community notification system taking responsibility
II "for neighbors further away. ..... "
ENCY EQUIPMENT
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Jf you already have written procedures for using and maintaining your emergency response equipment,
you do not need to write new procedures.
-""Keep in mind: Your procedures must apply to any emergency equipment relevant to a response
s ii j&Xplving a covered process, including all detection and monitoring equipment, alarms and
qomrnunicatipns systems, and personal protective equipment not used as part of normal operations
(and thus not subject to the prevention program requirements related to operating procedures and
The procedures must describe:
How and when to use the equipment properly;
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How and when the equipment should receive routine maintenance; and
How and when the equipment should be inspected and tested for readiness.
Written procedures comparable to those necessary for process-related equipment under Program 2
Prevention Programs will be considered sufficient to meet this requirement.
EMPLOYEE TRAINING
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If you already train your employees in how to respond to (or evacuate from) releases of regulated
v^U^stancesVtnen you do riot need a new training program.
Keep in mind: Your training must address the actions to take in response to releases of regulated
Substances from all covered processes. The training should be based directly on the procedures that
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fyb'u have included in your emergency response plan and must be given to all employees and
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If they will only need to evacuate, then their training should cover when and how to evacuate their
location. . ' . . ' . - .
If they may need to activate an alarm system in response to a release event, then their training .
should cover when and how to use the alarm system.
If they will serve on an emergency response team, then their training should cover how to use
emergency equipment and how the incident command system works.
Emergency response training conducted in compliance with the OSHA HAZWOPER Standard and 29
CFR-1910.38 will be considered sufficient to meet this requirement.
RESPONSE PLAN EVALUATION
If you already have a formal practice for regular review and updates of your plan based on changes at
the facility, you do not need to develop additional procedures.
Keep in mind: You must also identify the types of changes to the facility mat would cause the plan to
be updated (e.g., a new covered process) and include a method of communicating any changes to the
plan to your employees (e.g., through training). You may want to set up a regular schedule on which
you review your entire emergency response.plan and identify any special conditions (e.g., a drill or
exercise) that could result in an interim review.. .'
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CHAPTER 7: RISK MANAGEMENT PLAN
If you are subject to the risk management program rule, you must submit your Risk Management Plan
-(RMP)'which describes your risk management program. EPA has developed an electronic submission
system that will make filing the RMP easy. To submit your RMP electronically, you will need to
download free software, called RMP*Submit, from EPA's Internet website at
http://www.epa.gov/ceppo. RMP*Submit will be available in early 1999. The software will provide
you with all the necessary instructions to complete your RMP. You submit the completed electronic
RMP to EPA by copying it onto a 3Vฃ-inch diskette and mailing the diskette to EPA. If you do not
have access to a computer, you may file a paper version. The necessary submission forms for the
paper version will be available in early 1999 from the hotline or EPA's Internet website at
http://www.epa.gov/ceppo.
The RMP consists of a brief executive summary, and a set of data. The executive summary should be a
brief description of the facility^ the worst-case release scenario, steps you take to prevent accidents (for
example, complying with state and local laws), emergency response information (for example, your
coordination with the fire department), and any steps you are planning to take to improve safety (for
example, upgrading equipment to meet newer editions of NFPA-58). The rest of the, RMP is filling in
names, addresses, and numbers, and checking boxes. If you have completed the previous chapters of
this guidance, you have already gathered most of the information that you will need to complete the
RMP.
Your first RMP must be submitted by June 21,1999. ,
October 22,1998
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ACRONYMS
ANSI American National Standard Institute
ASME American Society of Mechanical Engineers
ASTM American Society of Testing Materials
BLEVE Boiling Liquid Expanding Vapor Explosion , .
CAA Clean Air Act
CAS Chemical Abstract Service . . ;
CEPPO ' Chemical Emergency Planning and Prevention Office of EPA
CETP Certified Employee Training Program , ,
CFR Code of Federal Regulations .
DOT Department of Transportation
ฐF Degrees Fahrenheit
FR , Federal Register ,
ft Feet ,
EPA Environmental Protection Agency (United States)
EPCRA Emergency Planning and Community Right-to-know Act of 1986
GPA Gas Processors Association
GPS Geological Positioning System
HAZWOPER HAZardous Waste Operators and Emergency Response
kg Kilograms
LEL Lower Explosive Limit or lower flammable limit '
LEPC Local Emergency Planning Committee '
LFL Lower Flammable Limit or Lower Explosive Limit (LEL)
LP-Gas Liquefied Petroleum Gas or Propane . ' -,
kw Kilowatts
m Meters . " , .
m2 Meters x Meters or Meters Squared. A measure of area. -
.mi ..Miles , '
MSDS Material Safety Data Sheet(s)
NAICS North American Industry Classification System (formerly Standard Industrial
Classification [SIC] codes)
NFPA National Fire Protection Association
NIOSH National Institute of Occupational Safety and Health
NPGA National Propane Gas Association
OCA RMP. Offsite Consequence Analysis Guidance from EPA
OPA-90 Oil Pollution Act of 1990
OSHA Occupational Safety and Health Administration (Department of,Labor)
PHA Process Hazard Analysis .
psi, psia, psig pounds per square inch, pounds per square inch absolute, pounds per square inch
' gauge
RCRA Resource Conservation and Recovery Act (EPA)
RMP Risk Management Plan (documents to submit)
SCFM Standard Cubic Feet per Minute
SERC State Emergency Response Commission
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SPCC Spill Prevention Control and Countermeasures
;.;TWA . Time Weighed Average
U1A A Form describing construction kept by National Boiler Safety on every pressure vessel
constructed under the ASME Boiler Safety Code
UFL Upper Flammable Limit or Upper Explosive Limit (UEL)
USGS United States Geological Survey
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October 22.1998
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