United States
           Environmental Protection
           Agency
Office of Solid Waste
and Emergency Response
(5104)
EPA 550-B-98-022
October 1998
www.epa.gov/ceppo/
           RISK MANAGEMENT
           PROGRAM GUIDANCE
           FOR
           PROPANE USERS AND
           SMALL RETAILERS
           (40 CFR PART 68)
Chemical Emergency Preparedness and Prevention Office
             Pnnied on recycled paper

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This document provides guidance to owners and operators of stationary sources 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.

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                                    INTRODUCTION
This guidance is intended for propane users and small retailers who have a single small or medium
capacity tank of propane or several small tanks stored in the same area. Larger distribution facilities and
-bulk storage terminals may need to consult a separate document that provides more detail and covers larger
capacity tanks.
                          x                   "                   .        -           •     .

If you have more than 10,000 pounds of propane stored in a single vessel or in a group of vessels (tanks,
cylinders) that are connected or stored close together, you must comply with the Chemical Accident
Prevention rule issued by the U.S. Environmental Protection Agency (EPA) under the Clean Air Act. The
rule is codified as part 68 of Title 40 of the Code of Federal Regulations (CFR).  The goal of this rule is to
prevent accidental releases that could affect the public or the environment.  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.                -

For most propane users  and distributors, complying with this rule will be easy because most of the
requirements are similar to those you already comply with under state or local rules based on the National
Fire Protection Association (NFPA) standard number 58 on propane. If you are complying with NFPA-58
and implementing other safe engineering practices for propane, you should have little more to do for this
rule besides filing a brief report with EPA.                           ••'.,'.

AM I COVERED?

The capacity of propane tanks is usually given as water capacity  (this information should be on the
nameplate of the tank).  Table  1 translates the water capacity (in gallons) into propane weight (in pounds).
Read the tank capacity on the nameplate and check this table. For any tanks .whose capacity is above the
grey line in Table 1, you will need multiple vessels to meet the threshold.
                       »   ••   .                       '         '      '.     .  '     .
                                           TABLE 1
                    ,            TANK CAPACITY IN POUNDS
Tank Capacity (Gallons of water)
500
1,000
1,500
, 2,000
2,700
12,000
18,000
30,000
Propane (pounds)
1,800
3,700
5,500
7,400 . .
10,000
•44,000
67,000
110,000

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Table 1 assumes that tanks are filled to 88 percent of capacity, the maximum level allowable under NFPA-
58 at 60 F.  If you always keep your tanks filled to a lower level, you should adjust these numbers to
reflect your lower inventory. Also, add up the amounts of propane in tanks that are connected or close
together. If you have six 500-gallon tanks or three 1,000-gallon tanks, you are subject to the rule if the
tanks are connected by piping, or if you store the tanks close enough together that they could be involved
in a single accident. For example, if a fire could spread to all the tanks, they are considered one "process"
and the propane in all the tanks must be counted toward the id,bOO-pound threshold. You should also
consider whether, if one tank exploded, the other tanks could be affected by the shrapnel or fire.

Most propane users will have a single "process." If you have several groups of propane tanks, widely
separated, you may be considered to have multiple processes.  In this case, you should consult.the
                                                          or the
                       You 'can['obtain  these, from the Emergency Planning and Community Right-to-
Knpw Act (EPCRA)hotline at (800) 424:9345"(fti*5c area (703) 412-9810; T.D. (800) 553-7672) or
electronically at http://www.epa.gpv/ceppo/.

WHAT DO 1 HAVE TO DO?

The first step you should take after determining that you are covered by the rule is to decide which
Program level you are in. EPA developed the rule with three Program levels to reflect different levels of
risk and levels of effort needed to'prevent accidents.

        Program 1 is a minimal set of requirements for processes that have a very low risk of affecting the
        public in the  event of an accident. A process is eligible for Program 1 if it, (a) has no public
        receptors (e.g., houses, schools, or businesses) within the distance that a 1 psi overpressure will
        reach as a result of an explosion caused by a worst-case release, and, (b) has not had an accident
        that caused deaths or injuries offsite  or required response or restoration activities at environmental
        receptors (e.g., national or state parks, federal wilderness areas) within the last five years.
        Program 2 is a streamlined set of requirements for processes not eligible  for Program 1 or subject
        to Program 3.
        Program 3 applies to processes that are not eligible for Program  1 and that are either subject to
        the Process Safety Management (PSM) Standard of the Occupational Safety and Health
        Administration (OSHA) or in certain industrial sectors (some chemical manufacturers, all
        refineries, and all pulp mills).

This document does not provide guidance on Program 3. If you are subject to the OSHA PSM standard,
you should see EPA's                                    .,-,.,

Most propane users will be either eligible for Program 1 or subject to Program 2.

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                                            '     3.

                                        PROGRAM 1
ELIGIBILITY
Many propane users will be eligible for Program 1, particularly those on farms or those that are a
considerable distance from any other business or residence. For a process to be eligible for Program 1, it
must meet the following criteria:                         .               '                ,

+      The process must not have had. an accidental release of propane that led to deaths or injuries of
        people offsite or response or restoration activities at environmental receptors in the last five years.
        Environmental receptors are limited to national or state parks, forests, or monuments; officially
        designated wildlife sanctuaries, preserves, refuges, or areas; and Federal wilderness areas; and,.

+      There are no public receptors within a distance to a l.psi overpressure from a worst-case release.

A worst-case release is defined by the rule as the loss of the contents of the single largest vessel (or piping)
containing the regulated substance.  For propane and other flammable substances, the released substance is
assumed to explode and generate a pressure wave that can damage people or structures. The rule requires
you to determine the distance to a 1 psi overpressure (at l.psi, windows will break). This scenario is
required by the regulation, and you must adopt this scenario. Table 2 provides the worst-case distance to a
1 psi overpressure for propane tanks.

                                             TABLE 2
                            DISTANCE TO A 1 PSI OVERPRESSURE
Nominal Water Capacity
(gallons)
500-1,750 '
1,751-7,000
7,001-23,000
23,001-51,000
Distance to 1 psi Overpressure
(miles)
0.1
0.2\
0.3
0.4 .
Next, you must determine if there are "public receptors" within a circle whose radius is equal to this
distance. Public 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 any
time without restriction by the stationary source where members of the public could be exposed to toxic
concentrations, radiant heat, 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." Public roads are not public receptors.

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                                               4

 If there are no public receptors within the distance to a 1 psi overpressure for your largest vessel and the
 process has not had an accidental release that caused any of the.listed offsite impacts, your process is
 eligible for Program 1.  If you have questions about whether certain areas are considered public receptors,
 call the Emergency Planning and Community Right-to-Know Act (EPCRA) hotline at (800) 424-9346 (for
 DC area (703) 412-9810; T.D. (800) 553-7672) or check EPA's General Guidance for Risk Management
 Programs (available from the hotline or electronically at http://www.epa.gov/ceppo/).

 WHAT MUST I  DO FOR A PROGRAM 1 PROCESS?

 Because your worst-case release would not affect public receptors, you only need to do two things:

 +•     Coordinate emergency response with your local fire department and any other local emergency
       planning and response agencies; and,

 *•     Complete a brief Risk Management Plan (RMP), as described below.

 Coordination with the fire department may consist of a discussion with them or a walk-through of your
 facility. The purpose is simply to be sure that the fire department is aware of the hazards associated with
 propane at your facility and ready to respond if an accident occurs. Also, contact your State Emergency
 Response Commission (SERC) to identify your Local Emergency Planning Committee (LEPC).  You can
 get contact information for your SERC from the EPCRA hotline (noted above).

 The RMP will be filed with EPA and made available to state and local agencies and the public. 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 S'/z-inch diskette and mailing the diskette to EPA.  If you do not have access
 to a computer to load the software on to, you  may file a paper version. The necessary submission forms for
 the paper version will be available in early 1999 from the hotline mentioned above or EPA's internet
 website at http://www.epa.gov/ceppo.

The RMP includes  a brief executive summary describing the facility; registration information (basic
facility information); the worst-case release scenario; a five-year accident history (covering any accidents
that caused deaths,  injuries, or significant property damage on site, known offsite deaths or injuries, offsite
properly or environmental damage, or evacuations or shelterings in place); information on emergency
response activities; and a certification statement.

The executive summaiy 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), arid 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 appropriate boxes. You do not need
to submit supporting documentation; you need only keep it onsite for inspection. Most propane users will
not have any accidents to report on  the five-year accident history.  If you do not, you need not complete
that section. A sample RMP for a small Program 1 propane user is attached.

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                                              5.  . ' . -

                                      PROGRAM 2
If your process is not eligible for Program 1 and not subject to Program 3, the process is in Program 2.
Most propane users that are in commercial or industrial areas or close to residential areas will be subject to
Program 2.              •

WHAT MUST I DO FOR PROGRAM 2?

For Program 2, you must:

4-     Analyze both a worst-case release scenario and an alternative release scenario;
4-     Implement a prevention program;   .        •
4-  ,   Implement an emergency response program if your, employees will respond to a release; and
4-     FileanRMP.     ,

WHAT ARE THE RELEASE SCENARIOS?

Worst Case Scenario. Part 68 defines the worst-case release scenario you must analyze. It is described in
the previous section of this guidance (regarding Program 1).  You can simply use Table 2 to define the
distance to the 1 psi endpoint for your largest tank.                                    .     •

Alternative Release Scenario. An alternative release scenario is a scenario that is more likely to happen.
It must reach an endpoint offsite unless no such scenario exists.  One of the following scenarios may be
appropriate for you.

4-     Pull-A way Explosion. An alternative scenario may be a hose rupture caused by a pull-away.  A
       pull-away can occur if the.driver fails to remove the hoses between the storage tank and the
       transfer vehicle before moving the vehicle. In this scenario, the failure involves 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. The release leads to a vapor cloud explosion
       (endpoint 1 psi). The quantity released is  69 pounds. The distance to the endpoint is 175 feet
       (report as 0.03 miles).

4-     Piping Break.  Another alternative scenario you may want to consider is a break in propane piping
       leading to a 10-minute release and explosion. The distance to the 1 psi endpoint is shown in Table
       3.
                                          TABLES
                        DISTANCES TO 1 PSI FOR PIPE RELEASES
Pipe Size
(inches)
0.5
1
2
Quantity Released
(pounds)
4,738
18,951
75.804
- Distance to 1 psi
0.1 _
0.2
0.3

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 Other scenarios are described in EPA's Risk Management Program Guidance for Propane Storage
 Facilities.

 You must estimate in the RMP residential populations within the circles defined by the endpoints for your
 Worst-case arid alternative release scenarios (i.e., the center of the circle is the point of release and the
 radius is the distance to the endpoint).  You may use Census data and round to two significant digits (e.g.,
 , j^ gecomes 11(jOi ang 123 becomes 120). You do  not need to conduct surveys or correct Census data.
 In addition, you must report in the RMP whether certain types of public receptors (e.g., schools, hospitals)
 and environmental receptors are within the circle.  You do not need to identify specific receptors; you
 simply need to check off the category.

 WHAT DO  I HAVE TO DO  FOR THE PREVENTION PROGRAM?

The Program  2 prevention program has seven elements:

 +      Safety information
4-      Hazard review
 +      Operating procedures
 4-      Training
 +"      Maintenance
4-      Compliance audits
•*•      Incident investigation

If you are complying with NFPA-58 or state or local laws based on it, following the guidelines in the
National Propane Gas Association (NPGA) LP Gas Safety Handbook, and implementing NPGA safety
bulletins, you are probably already doing almost everything you need to do to comply with these
requirements^ The following sections provide additional information on how your current practices will
help you comply with the EPA rule.

Safety Information. You must have up-to-date information on propane and your propane equipment.
You must have a Material Safety Data Sheet (MSDS)  on propane.  If you do not have one, contact your
supplier for a  copy.  You must also document your maximum intended inventory for your propane
equipment.  This will generally be the capacity of your tank or tanks; see Table 1.

You need information on safe upper and lower temperatures, pressures, flows, and compositions. The
following information should meet this requirement:

+      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 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°F 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°F. 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 the design  of the storage tank and the piping. Liquid propane

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                                               7

        (if released at atmospheric pressure) can refrigerate steel pipes and tanks down to temperatures of -
        44°F.

+      Another property of propane in its liquid form is its ability 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.

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. If you do not have
the information, obtain it from your vendor and keep all such information on file.

You must document the  codes and standards you used to design and build your propane facility and that
you follow to operate it.  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.

The equipment  specifications and lists of standards and codes will probably ensure that your process is
designed in compliance with recognized and generally good engineering practices.

Hazard Review.  You are required to conduct a hazard review to identify the hazards associated with your
equipment and propane,  the possible malfunctions of equipment or human errors that could cause a
release, the safeguards needed to control Hazards or prevent malfunctions or errors, and any steps needed to
detect or monitor releases., If you are required to comply with NFPA-58, your review can focus on whether
you are in compliance with that standard. 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 system would survive these natural events without releasing propane. 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 anything near the process that could burn, ask
yourself what would happen if the fire affected the propane tanks or equipment. EPA's Risk Management
Program Guidance for Propane Storage Facilities contains a checklist you may use to conduct the review.

When you complete the review, you must document the results and ensure and document that any
problems are addressed in a timely manner.                            ,

Operating Procedures.  Written operating procedures describe the tasks you or your operators must
perform, safe process operating parameters that must be maintained,  and safety precautions for operations
and maintenance activities.  These procedures tell you or your employees how to work safely every day.
Applicable portions of the National Propane Gas Association  (NPGA) Certified Employee Training
Program and compliance with certain NPGA Safety Bulletins can be used to meet this requirement. Other
programs may be available that will also be acceptable.

Training. You must ensure that any employee presently operating a process and any employee newly
assigned to a covered process have been trained or tested competent in the Operating Procedures that
pertain to their duties.  For those employees already operating a process on June 21, 1999, you may certify
in writing that the employee has the required knowledge, skills, and abilities to safely carry out the duties

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                                                8

 and responsibilities as provided in the operating procedures.. You are not required to provide a specific
 amount or t^ge of training. You should develop a training approach that works for you. You must provide
 refresher training. You must determine the frequency of refresher training in consultation with any
 affected1  employees, but you must provide; refresher training at least once every three years.

 The M]P<3A's Certified Employee Training Program and any training you do to meet DOT requirements
 may satisfy this requirement.

 Maintenance. You must prepare and implement procedures to maintain the on-going mechanical
 integrity of your propane equipment. You may use procedures or instructions provided by equipment
 vendors or procedures in Federal or state regulations or industry codes as the basis for maintenance
 procedures. You must also train maintenance workers in these procedures (if a contractor maintains your
 equipment, the contractor's employees should be trained as well). NPGA's Certified Employee Training
 Program covers many of the maintenance procedures for your propane equipment.

 YOU rnMSt..establish a schedule for inspecting and testing equipment associated with your propane storage
 facility.  You may obtain recommendations from manufacturers, vendors, or trade associations. You
 should, however, use your own experience as a basis for examining any schedules you obtain from others.
 Many Kings "may affect1 whether a schedule is appropriate.  The manufacturer may assume a constant rate
 Of use. If your actual rate of use (e.g., the amount of propane pumped per hour) varies considerably, the
 variations may cause additional wear on the equipment. Extreme weather conditions may also increase
 wear on equipment.

 If you have workers that use your propane facility, talk with them 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.

 EPA's Risk Management Program Guidance for Propane Storage Facilities includes a maintenance
 checklist that you may find useful.

 Compliance Audits. 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 who
 conducts the audit must be knowledgeable about the process. You must develop a report of the audit's
 findings, determine and document an appropriate response to each finding, and document that you have
 corrected all deficiencies. You must retain compliance audit reports for 5 years.

 Incident Investigation. You must investigate each incident that resulted in, or could have resulted in, a
^atestojpTii[cw'reIea^'of|>rop_aine. A catastrophic release is one that presents an imminent and substantial
 gndangerrnent to public health and the environment. You must start the investigation no later than 48
 hours aHer'th'e'accident You must create a report on trie accident that includes, at least, the.date of the
 accident and the date the investigation began, a description  of the accident, the factors that contributed to
 the accident, and any recommendations that resulted from the investigation. You must address the
 recommendations and share the findings with any employees whose jobs are affected by .the findings.
 Investigation reports must be retained for five years.

The NPGA "LP-Gas Safety Handbook," and NPGA bulletin #202-93 "After Accident Procedure" may
help you  comply with this requirement.   '

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Table 4 summarizes the Program 2-prevention program elements and ways that propane facilities can easily
comply with these requirements.
                                         TABLE 4
            WAYS TO COMPLY WITH PROGRAM 2 PREVENTION ELEMENTS
  Program 2 Prevention Element
     How a Propane Facility Can Meet This Requirement
 Safety Information
- Maintain Material .Safety Data Sheets on propane
- Use the information provided in this guidance
- Document NFPA-58 information
- Maintain propane equipment vendor-supplied information
- Maintain records on electrical and building codes followed
 Hazard Review
- Use checklist in EPA's Risk Management Program Guidance for
Propane Storage Facilities                              ,
- Review compliance with NFPA-58
 Operating Procedures
  Implement NPGA Certified Employee Training Program
  Comply with NFPA-58
  Comply with NPGA safety bulletins
  Use written operating procedures for propane systems ,
 Training
 - Implement NPGA Certified Employee Training Program.
 • Document training done to meet DOT requirements
 • Document training done to comply with NFPA-58
 - Comply with NPGA Safety Bulletins
 • Provide refresher training at least every three years
 Maintenance
- Implement NPGA Certified Employee Training Program
- Use checklist in EPA's Risk Management Program Guidance for.
Propane Storage Facilities
- Establish a maintenance and testing schedule  ,
- Document inspections and maintenance done fay equipment
vendors                                ••'-'.-,.
 Compliance Audits
- Conduct and document a compliance audit every three years;
respond to each finding, and document that you have corrected any
deficiencies.
 Incident Investigation
- Implement practices in NPGA's LP-Gas Safety Handbook
- Implement NPGA bulletin #202-93 "After Accident Procedure"

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                                              10

WHAT DO I HAVE TO DO FOR THE EMERGENCY RESPONSE PROGRAM?

If you have at least one Program 2 process at your facility, you may be required 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 propane. The emergency response
section of EPA's rule allows you 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 you must coordinate response actions with the local fire
department and have in place appropriate mechanisms to notify emergency responders when there is a need
for a response.

Most propane users will probably rely on local responders to handle any accident.  If you plan to have your
employees respond to apropane release, you should consult EPA's General Guidance for Risk
Management Programs to determine what you need to do to develop and implement an emergency
response program.

WHAT  DO I HAVE TO DO FOR MY  RMP?

The RMP for a Program 2 process will include the same sections covered in the Program 1 process, plus a
report on the alternative release scenario and the report on the prevention program. Except for the
executive summary, the RMP consists of names, numbers, and  check-off boxes. If you have more than one
process, you still file only one RMP.  If you have multiple Program 2 processes, but they all contain
propane, you report only one worst-case scenario and one alternative scenario to cover all of1 them. (If you
have multiple Program 1  processes, you must report a worst-case scenario for each Program 1 process in
order to establish that the process is eligible for Program 1.)

If you have one Program 2 process, your RMP will include:

4-     The executive summary (covering the alternative release scenario as well as worst-case)
4-     Registration data
4     Worst-case and alternative release data
4-     Five-year accident history (only if you've had any accidents to report)
4-     Prevention program data
4-     Emergency response data
4-     The certification

A sample RMP and certification statement for a small Program 2 propane user is attached.

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                                                   11


               SAMPLE RMP for PROGRAM 1 PROPANE USER
              (This sample RMP is for a fictitious facility named, "Smith Farms Poultry Company.
                             Any resemblance to any actual facility is accidental).


 CERTIFICATION STATEMENT

 Based on the criteria in 40 CFR 68.10, the distance to the specified endpoint for the worst-case accidental releas
 scenario for the following processes is less than the  distance to the nearest public receptor:

 •     -   Hatchery house heating system

 Within the past five years, the process has had no accidental .release that caused offsite impacts provided in the risk
 management program rule (40 CFR 68.10(b)(l)). No additional .measures are necessary to prevent offsite impacts
 from accidental releases. In the event of fire, explosion, orajelease of a regulated substance from the process, entr
 within the distance to the specified endpoint may pose a danger to public emergency responders.  Therefore, public
 emergency responders should not enter this area except as arranged with the emergency contact indicated in the
 RMP. The undersigned certifies that,tpjhe best of my knowledge, information, and belief, formed after reasonable
.inquiry, the information submitted is true, accurate,  and complete


     William R. Smith   	'               ^"^   William R Smith	     .  . '
 Signature                        •*                   ""   Print Name
                          ;             ?                "^ ^
    Company Owner      "•% _                 6/21/99
 Title               <                                     Date
EXECUTIVE SUMMARY    v                        ^ "N      -,                ,
                                    «.            *     ™*^   «|     ^w                ^
                    "'*    •  ' ' "       *„         ^  'V,,.'*    "       *  '            ~,«,,,,,
The accidental release prevention and emergency response policies at your facility This facility complies with
NFPA-58 requirements.for LP-Gas storage, and it is our policy to adhere to all apphcable federal, state, and local
laws. If an emergency swereto occur, it is our policy to notify the Garym County Fire Department and request that
they respond to the emergency.                            ^                      '•'" .
                   1                           •**                                      .

A description of your facility and the regulated substances handled. This facility is a poultry farm. We use
propane on the farm for winter heating fuel for our hatchery houses. 'The heating system consists of two 1,500-gallc
propane tanks and associated piping, valves, burners; arid ofher miscellaneous equipment.
The worst-case release scenario.  Our worst-case.scenanpjls.jfaiiure of one 1,500-gallon storage tank when filled to
the greatest amount allowed (88% at 60F), resulting in;'a<-gipj>i- cloud explosion.  Since this facility is located in a
relatively remote, unoccupied area, the worst-case scenario would not affect anyone beyond pur property.

The general accidental release prevention program and chemical-specific prevention steps. This facility complies
with EPA's accident prevention rule and all applicable state and local codes and regulations.  The propane system is
designed, installed, and maintained in accordance with NFPA-58 and state law.

Five-year accident history.  We have never had an" accident involving propane that caused deaths, injuries, property
or environmental damage, evacuations, or shelterings in place.

The emergency response program.  In the event of an emergency involving our propane system, it is our policy to
notify the Garvin County Fire Department and request that they respond to the emergency. We have discussed this
policy with the fire department; members of the fire department have inspected our propane system.

Planned changes to improve safety. None.

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                                                    12



1. REGISTRATION


LI Source Identification


    Llaa, Facility Name:     Smith Farms Poultry Company


    1 J.b. Parent Company #1 Name: N/A


    1 . 1 _.c3 Parent Company #2 Name:


J, 2, RMF 'Facility Identifier: [EPA will assign]


1.3, EPA Identifier:
                                                  11«l;":t! ....... :!•;;'• :"" :
                                                 ',,
    1 .4.c. Parent Company #2 DUNS:

                            ''>%, ...... :;A  ' ..... '%>K      •"v'f.^V
1.5 Facility Location Address      .;'                    .   v

                    ...... • ....... 1! ......... •< ......       ^T"?-" .. ..... m-\       X..:., .....
                       • .1 fly1 "• ,         „ ..... „„; 'i|   ' I,,,,; ......         ' •; 5,
    a. Street         42 Rural Rt 7                     .
                          "".,;'  ,'v.       '^V.,v   •'•rf.       iS'S'fc;,
   :•'!,!  , ................ • ........... :• ........... it, ...................... i' ..... ......... . .< • ....... , ............ .i-1 .......................... i ........ si ......... ..... . • , ..... •', ' ..... iia ....... .': ....... ]*! ....... •••• ..... ! ..... rS ..... <:••• "ir!* ...... S™!ik
    b. Street - Line 2:           .......   .       -  .-.'    •.,-'-.•••'.•," ..... -.-:
   [[[ " ........... i,, .+ ..... ,| ........   ........ , .« ..... >i,i; '-;;« ................. "~"i ........ :'^A ........... ;-<*f ...... .iSSiis1
  ............... : ...... i ........... : .................. ....................................... ":,:: ......... :a: ............. ............ , • ......... 'S ....... :*!'••;,* ............. ., ,^ ........... ',;= ................. , "^liSia;/" ........
    c. City;  Plainville       d. State: OK     e.  Zip Code:    "12345  f. County:       Garvin

   : ......  ::: ........................... %%,;  - .............. ;: %:''* ..... •:: , , ......  H-'iT-V-v • :"! %- ;%i; :%%,, •
    g. Facility Latitude (degrees, minutes, and seconds):    34   40..     20

                                'l^;1'^,;- ..... "^;^^^-'1
    h. Facility Longitude (degrees, minutes, arid seconds):, -097  ,*21      06
                                    "'           '           "
                       .                 i,    ,       .     ..
   i   .......             .,' (.I.-. I"." ' . •• ...... ..... ''SB''! ,i»- >-'-**» ..... i ..... '*!-« .......... !-«u ...      ,,
   l. Method for determining Lat/Long :       II (interpolation, map)

                                          .....        •               '
                                                        ,,,..
   j. Description of location identified by Lat/Lorig :    AB     Administrative Building
   ''  " ................. *• .............................................. "   ....... '-;,':-„   "]':'•'.   .......... '*«l*::v •!«*.,

.,,_     „    .                 '.;.'•;'•:! ..... "-• '"^-;
L6 Owner/Operator                  ;
                                    Mrj,,,, _   .    'v
                                       '^i'-i .......
   a. Name:        William R. Smith       ..  ....... „
                                           '''^iT

   b. Phone:       (555) 555-5555            '  ...... : -  r'


   Mailing Address:


   e, Street 1:      42 Rural Rt 7


   e. City:         Plainville       f. State: OK     g.  Zip:  12345


1.7. Name and title of person responsible for RMP (part 68) implementation



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                                                  13
 1.8. Emergency Contact

a. Name:        William R. Smith

b. Title:         Company owner

c. Phone:       (555)555-5555

d. 24-hour phone:   ,     (555)555-1111  e. Ext. or PIN: •

 1.9. Other Points of Contact (Optional)

a. Facility or parent company e-mail address:           -    .

b. Facility public contact phone: (555) 555-5555 ?'     .". -'.iOW-

c. Facility or parent company www homepage address:

 1.10. LEPC (Optional)    Garvin County LEPC

 1.11. Number of full-time employees (FTEs/On Site.     ,4

 1.12. Covered by (select all that apply)    "                 ^              _'      •

   a. OSHA'PSM:                      ^                *~~                   '  „         '
                                                        t*>
   b.EPCRA section 302                     "
                                *            * X          „ >         •   "'                      S
   c. CAA Title V Air Operating Permit ID.                                    "-         ,
                  .'                      ""   *^        "*    c«                                'v
1,13. OSBTA Star or Merit Ranking: No    v
                                ^                       ^   **z
1.14. Last Safety'Inspection Date: 12/07/97
                 '•;•-•:                   A             *  ^   -v  s ^           ^       '        .     •   •
1.15. Last Safety Inspection Performed by (select one) Fire department             ?•

1.16, Will this RMP involve Predictive Filing? No  t                                      ,

1.17. Process Specific Information. Fojjeach covered.process fill in the following chart. Use a separate sheet for
each process                         "*            _
Process Number:
(optional to help you -
track)
Process Description:
(optional to help you
track)
a. Program Level:
b. NAICS Code(s):
c. Chemical
1 . ' * ""' , ''.'...
Hatchery House Heating System
1 - .'• •. -••••'
11234 Poultry hatcheries
c.l. Name: . c.2. CAS Number: c.3. Quantity (Ibs.):
Propane 74-98-6 11,000

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                                                      14



4.FLAMMABLES: WORST CASE ^ ....... "


4.1 , Chemical Name              Propane


4.2. Results based on (select one)


    c. EPA's  RMP Guidance for Propane Storage Facilities Reference Tables or Equations


4.3. Scenario: Vapor Cloud Explosion



4.4. Quantity  released (Ibs.)       5,500 pounds


4.5. Endpoint Used: 1 psi


4,6. Distance  to endpoint (miles)   0.10 miles


4.7. Residential population within distance to endpoint    ,  • 0
                                           '.I,,!! '' .....             ' If"1*^
                                           '"'.:'            ""*V  '
4,8. Public receptors within distance to endpoint (select all that apply)

   '      '
                                                .
a. Schools                        dl Prisons /Correctional facilities
b. Residences                     e. Recreation areas

              """' il
   u                      .                 .
c. Hospitals                       f. Commercjal/industnal areas
                            "	IE',;,/'"'!	       ""*.,"•!	.,   ^"K'-i...  ,   »«:\
                              :«l	•	till)	I-..
4.9. Environmental receptors within distance to endpoint (select all that apply)

    V. •:#£;	^        "V	,; ""•;;,,     '	^-^(i,,.    '^%3K  "*!ii|ilsi  '  •'."

    a. National or state parks, forests, or monuments '"=;   i";,    *'


    b. Officially designated wildlife sanctuaries, preserves, of refuges

             11111	f"\i                  -'"'iir,;,,    ""''•'"''Sjt"	!,    *'^ll]?^rt "ll""™li
    c^Federal wilderness area          -v k       >,   ":

                      \1',».'• fa	-JI.JJL ••     '"^r*, ,.*-=;"--;*	'•(:>,,
4.10. Passive mitigation considered (select all that apply)

                               a**'""""l!"''«i«|i,j£),,  '"' •:,';;;**     .^*fe«».
    a. Dikes


    b. Fire walls

:      	II

    c. Blast walls
   d, Enclosures


   c. Other (specify)


4.11. Graphics file name (Optional)

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                                                   15

9. EMERGENCY RESPONSE

9.1. Emergency response (ER) plan
                      /         :               •'              ' •     •  .     •
   a. Is facility included in the written community emergency response plan?      No

   b. Does facility have its own written emergency response'plan?               No

9.2. Does facility ER plan include specific actions to be taken in response to accidental releases of regulated
substance(s)?

9.3. Does facility ER plan include procedures for informing public and local agencies responding to accidental
release?                               -              '  ~

9.4. Does facility ER plan include information on emergency health care?

9.5. Date of most recent review/update of facility ER plan

9.6. Date of most recent emergency,response, training for facility's employees
                                   i
9.7. Local agency with which the facility ER plan or response activities'are coordinated

   a. Name of agency       Garvin County Fire Department

   b. Phone number (555) 555-1000     "*                                      > -
                                                                               "X"            '
9.8. Subject to (select all that apply) '  „
         *• ^                       *& >             J"                       7*              ***•   •*"*   "*">? y
   9.8.a.OSHA 1910.38            /   *                                  " X          «/"**"   ""-
     -•>':'",-              '                                                 .,  »'>">    ~.
   9.8.b. OSHA 1910.120                                  -                               - 7-
                               *«--       t       -.  ^       "*   .                    x
   9.8.c. Clean'Water Act/SPCC    "*       '       ™" ;     -  „    '
                           •*•&- -i                   "*                           ^:--i ' *
   9.8.d. RCRA     '              „      ,         ^       "   " "           x* "^
                             taje *                                          £$!.
   9.8.e. OPA-90                   ~"

   9.8.f. State EPCRA rales/law      ^                     -"„-'''

•   9.8.g. Other (specify)                           *,    ~%

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                                                 16

             SAMPLE RMP for PROGRAM 2 PROPANE USER
                    (This sample RMP is for a fictitious facility named "Jones Nursery."
                           Any resemblance to any actual facility is accidental).
 CERTIFICATION STATEMENT

 To the best of the undersigned's knowledge, information, and belief formed after reasonable inquiry, the
 information submitted is true, accurate, and complete.

   ""Mary L, .Jones	                 Mary L. Jones	
Signature                                               Print Name
    Company Owner	                 6/21/99
Titfe.. ,     , ,       	'       Date
EXECUTIVE SUMMARY   	]	'.	"^'.'-    '  % '"./^

The accidental release prevention and'emergency response policies at your facility. This facility complies with
NFPA-58 requirements for LP-Gas storage, and it is our policy to adhere to all applicable federal, state, and local
laws. If an emergency were to occur;it is our policy to notify the Howard County Fire Department and request
that they respond to the emergency.  '"."•••'' .    ••'        	"••'•.,	""'"^i-.

A description of your facility and the regulated substances handled. This facility is a nursery. We grow trees,
flowers, and other products for sale to'the public. We use propane for winter heating fuel for our greenhouses.
The heating system consists of two 1,500-gallon propane tanks and associated piping, valves^-burners',''arid-other
miscellaneous'equipment.  '            "                      " V              ""*•"...  -•'•"•'"'""•• •""•"",
      '    .   „ ,	:.;;/;'  '               «         ,         -S    ftjh   l „,  , ..„.' ,  '„ /   ,"  *{Jf\ '\ '"  -
The worst-case and alternative release scenarios. Our worst-case scenario is failure of one 1,500-gallon storage
tank when filled to the greatest amount allowed (88% at 60F), resulting in a vapor cloud explosion. The resulting
distance to the endpoint extends offsite, and public receptors are within the distance to the endpoint. Our
alternative release scenario is a break in a 0.5-inch diameter pipe,  leading to a IQ-minute release arid explosion.
The resulting distance to the endpoint extends offsite, and public receptors are within the distance to the
endpoint.                           "       " .'.,.       " "•;.  _ '^;.	    "-•'•'

The general accidental release prevention program and chemical-specific prevention steps. This facility
complies with EPA's accident prevention rule and all applicable state and local codes and regulations. The
propane system is designed, installed, and maintained in accordance with NFPA-58 and state law.
Five-year accident history. We have never had an accident involving propane that caused deaths, injuries,
progcrty or environmental damage, evacuations, or shelterings in place.

37ie emergency response program. In the event of an emergency involving our propane system, it is our policy
to notify the Howard County Fire Department and request that they respond to the emergency. We have
discussed this policy with the fire department; members of the fire department have inspected our propane
system.'        	    '	         '        	

Planned changes to improve safety. None.

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                                                   17..,


    1. REGISTRATION


 1.1 Source Identification


    a. Facility Name:  Jones Nursery


    b. Parent Company #1 Name: N/A


    c. Parent,Company #2 Name:


 1.2. RMP Facility Identifier: [EPA will assign]


 1.3. EPA Identifier:


 1.4. Dun and Bradstreet Numbers (DUNS) N/A    '••''•"•-•• ff0^
                      ••  ' •       '           •'".' "".->-'

    a. Facility DUNS:


    b. Parent Company #1 DUNS:


    c. Parent Company #2 DUNS ^~     „              ^                 •*   "^


 1.5 Facility Location Address       *~                     *',             t      .
                  "v--*-;                                    -r             r

 a. Street         238 Main Street        "                \                    '>
                                                         V  ^                  «•

 b. Street - Line 2:                   _,                                  ",x           "'
                                                          'C           N

 c. City:  Odenton       d. State MD   _e  Zip Code.    x 21873   f County    -,  Howard


 g. Facility Latitude (degrees, minutes, and seconds).  39   .11-    15


 h. Facility Longitude (degrees, minutes, and seconds) -076   50      10


 i. Method for determining Lat/Long r      II (interpolation, map)'  "        .    V*


j. Description of location identified by Lat/Long     AB     Administrative Building


 1.6 Owner/Operator


 a. 'Name:       Mary L. Jones                       ,     ,,
                                                         \f

 b. Phone:       (410)777-1234                """  Uf-


 Mailing Address:


 c. Street 1:      238 Main St.


 e. City:         Odenton       f. State: MD    g.  Zip:  21873


 1.7. Name and title of person responsible for RMP (part 68) implementation


    a. Mary L.Jones


    b. Company Owner

-------
                                                     18
 1.8. Emergency Contact


 a. Name:        Mary L. Jones


 b.  Title:        Company owner


 c.  Phone:       (410) 777-1234


 d.  24-hour phone:       (410)777-4321  e. Ext. or PIN:


 1.9. Other Points of Contact (Optional)


 a.  Facility or parent company e-mail address:


 b.  Facility public contact phone: (410)777-1234


 c.  Facility or parent company www homepage address:
f;   '"   S^'" '	' .  -".  ' " ' "	  "   "   ... '' ".''.I. . ''"""If!	!--, "  .••"' ' ".

 1.10. L|PC (Optional):   Howard County LEPC

M,1,  , .;	IB .I,.- .i,11,1 in?..,!-,,' ,,„",'  „ .1,111,1  'i;"'1           •'- .  •	 '"'"'"ISiiii..,1.,'".
 1.11. Number of full-time employees (FTEs) On Site:
 if :"!'.  :':ii!;;:;i".;': "'"<:" ' i**',-1'"	"^I|J1^'''^'^K. ii'  :'   ;'*Jhi«;i|S.?*ili

 1,12. Covered by (select all that apply)      *  ...        v  ,
 •» '     	 '"	!	iin!*, '       „ „ ^\i||,i|,4^iif!'iii|iii.,   „„; h	 ».    	'i*l|l|
       	        '"W	'"	      .""Wfel   '"'**...„   '   •.
 ••   a.OSHAPSM:        	"• • .       	 * •:; ,   -'.-
       	'	;;	     	 "«„;;	ijjj.	, ,'*•*>*;	

     . EPCRA section 302:     """";-' **'".:;:.    ";"
 4

ilk:,''
    cl dAA"Title_V Air Operating Permit IDC


 ,1.13. QS]FI4,§tar or Merit Ranking^No"..:^


 1.14. Last Safety Inspection Date: iO/19/98


 1.15. Last Safely Inspection Performed by (select one) Fire department


 1.16. Will this RMP involve Predictive Fifing? No  ;.\
 1.17. Process Specific Information. Foreach covered process fill in the following chart.  Use a separate sheet for
 each process.                         ^b,,       ''•-"--,^f,       •.••.••
                                                          '
Process Number:
(optional to help you
track)
Process Description:
(optional to help you
track)
a. Program Level:
b. NAJCS Code(s):
c. Chemical
i ' '•"./•';!V.
"• -MCW
Greenhouse Heating System
2
11142 Nursery and floriculture production
c.l. Name: c.2. CAS Number: c.3. Quantity (Ibs.):
Propane 74-98-6 11,000

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                                                     19


 4. FLAMMABLES: WORST CASE


-4.1. Chemical Name              Propane


 4.2, Results .based on (select one)


    c. EPA's RMP Guidance for Propane Storage Facilities Reference Tables or Equations


 4.3. Scenario: Vapor Cloud Explosion


 4.4. Quantity released (Ibs.)       5,500 pounds


 4.5. .Endpoint Used: 1 psi


 4.6. Distance to endpoint (miles)   0.10 miles


 4.7. Residential population within distance to endpoint        14


 4.8. Public receptors within distance to endpoint (select all that apply)

 '                                 N*                              *           '\
 a. Schools                       d Prisons /Correctibnal.facilities


 b. Residences    •/              e. Recreation areas


 c. Hospitals                      f Commercial/industrial areas


 4.9. Environmental receptors within distance to endpoint (select all that apply)

  .  »           _                         -*       s.   ' *      jj, s
    a. National or state parks, forests, or monuments

                                                      ?**""*
    b. Officially designated wildlife sanctuaries, preserves, or refuges       ,


    c. Federal wilderness area                        "


 4.10. Passive mitigation considered (select all that apply)  s                          ,


    a. Dikes                                      -         C


  •  b. Fire walls                    ^v^
                                     "-,:,-                  ^
                                                   •*>     \ «.
   c. Blast walls                                    "       ^j


   d. Enclosures


   e. Other (specify)

              f
 4.11. Graphics file name (Optional)

-------
'JS. FLAMMABLES: ALTERNATIVE RELEASES [Program 2 processes only]



 5.1. Chemical Name      Propane



 5,2. Results based on: EPA's  RMP Guidance for Propane Storage Facilities Reference Tables or Equations



 5.3. Scenario     Vapor cloud explosion



 5.4. Quantity released (Ibs.)        4,738



 5,5, Endpoint used (select one)  1 psi



 5.6. Distance to endpoint (miles)   0.10



 5.7. Residential population within distance to endpoint        14



 5.8. Public receptors within distance to endpoint (select alfthat apply)
                                       	lif" "llffl!	^ ''.-''Ml VT Vl^i'l'lL TIL,' i-'KaLl.'!'!!
    a. Schools                 '       d. Prisons /Correctional facilities

                                " ^^jj'S'^iiJji*. "''*";''":>„      '    '""' '•',';i.

    b. Residences    ,,, ,"'i":l,li  X'^i.


 5,10. Passive mitigation considered (select all that apply)       ".  "



    a. Dikes            _-„;,,,„,	i,,",;,,!,,    '"•',,'"';'.,'



    b. Fire walls                              ,  "  "  ;

      	.,,,,,                       ,   	 '"'i ,um,!in'i!ilW ,  i-iijijiMill'iHu. , i , •
      -"••'"   •• •'-••                      '	'• .  ">«*	,   	Hi,..
    c. BJastwalh                      ;
                                                .: >'"%%
    d. Enclosures



    e. Other (specify)



5.11. Active mitigation considered (select all that apply)



    a. Sprinkler system



    b. Deluge system



   ; c, ^ater curtajn	



    d. Excess flow valve



    e. Other (specify)



5.12, Graphics file name (Optional)

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                                                  21

8. PREVENTION PROGRAM - PROGRAM 2

For each process or process unit:

8.1. NAICS Code for process: 11142
                           Propane
 8.2. Chemical name(s):
3.3. Safety information

   a. Date of most recent review/revision of safety information   02/04/97

   b. Federal/state regulations or industry-specific design codes and standards used to demonstrate compliance with
   the safety information requirement (select at least one)

      •NFPA 58 (or state law based on NFPA 58) S       - -;     ASME Standards /

      OSHA (29 CFR 1910.111)        ^                     None

      ASTM Standards         *      " *.                                   -     '

      ANSI Standards^

      Other (spebify)

   \  Comments

3.4. Hazard review             '               _                 „               •          -       '

   a. Date of completion of most recent hazard review/update            02/04/98

   b. Expected date of completion of any changes resulting from the Hazard review        02/04/98

   c. Major hazards identified (select at least one)          -^

      Toxic release                    Overpressurization       
-------
    Flares


    Manual shutoffs


    Automatic shutoffs


    Interlocks


    Alarms and procedures


    Keyed bypass
                                                       22


                                                  Inhibitor addition


                                                  Rupture disks


                                                  Excess flow device


                                                  Quench system


                                                  Purge system


                                                  Other
8,4.0. Mitigation systems (select all that apply)


    Sprinkler system         /                Deluge system


    Dikes                                      water curtain


    Firewalls                    (      ...     ^Enclosure       ,

                                "/..l,/,"'""'!.	<|''"5!%,.|..^: •..-.'. •  '^%iv
    Blast walls            *     ""'     •     ""'  "Neutralization  ,   "••',
                 ,,, •"• .;:	::  :~'~ ''	:	">;:i:*₯.;;  	i:i|:il*is,i, ; " Other (specify)
                   	i	s	"	Sjji™;!!-!,.'^	i	""".Jj.	'""	."	"	j:	'"

8.4,f, Monitoring/detectionf systems geie5t all that apply)


   Process area detectors   =    •              Other (specify)
	Ill	           	I	I    "	"'I	lljljljj,;	llllilili.;,,;, i	 " ' '»	;          	    	 :  ''
 	J  u   i       k '       i .'•. i•••:!'*WBititS*j	 ••"'•	*3L!:'^:*M'.!.i;J:	^Jiiiisf!*'^ r
  i	Penmeter monitors     	•..'	'"-  	\'	_	._


8.4,g, Changes since last PBtA update (select all mat apply)

       Reduction in chemical inventory"


       Increase in chemical inventory


       Change in process parameters


       Installation of process controls   ,


       Tnsrj-illjjiinn nf process detection systems
                                       	        ^IM      f

8.5. Date of most recent review/revision of operating procedures


8,6. Training


   a. Date of most recent review/revision of training programs


   b. Type of training provided (select at least one)


       Classroom                        On die job        /


       Other (specify)


   c. Type of competency test used fselect at least one)


       Written test                       Observation      /
                                                       Installation of perimeter monitoring systems
                                                       «'!'p'";l»rt!K;4|»i.1l1 '•'	."'"iftiii "';l' *-;iRJ	 ,   •  '
                                                       :"!.    *«ltMlj!ii,    J₯K,  • 	';,!?!;,.,
                                                       Installation of mitigation systems

                                                                  '''
                                                       None required/recommended

                                                             "' •*•&.....' '^'ift
                                                       Other (specify) .
                                                                 03/01/97
                                                                     03/61/97

-------
04/01/97

10/19/98

Propane tanks, valves, and piping
                                                   23


       Oral test                         Other (specify)

       Demonstration   >/

8.7. Maintenance

   a. Date of most recent review/revision of maintenance procedures

   b. Date of most recent equipment inspection/test

   c. What equipment inspected/tested

8.8. Compliance audits

   a. Bate of most recent compliance audit

   b. Expected date of completion of any changes resulting from the compliance audit

8.9. Incident investigation:           "

   a. Date of most recent incident investigation

   b. Expected date of completion of any ch"anges resulting from the investigation
                     -'•••:;•            ' ^                        .             >•_•.•
8.10. Date of most recent change that triggered review/revision of safety information, hazard review, operating or
maintenance procedures.or training                 (

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                                                   24

 9. EMERGENCY RESPONSE

 9,1. Emergency response (ER) plan

    a. Is facility included in the written community emergency response plan?       No

    b. Does facility have its own written emergency response plan?                No

•5,2. Docs facility ER plan include specific actions to be taken in response to accidental releases of regulated
 substances)?

 9.3. Docs facility ER plan include procedures for informing public and local agencies responding to accidental
 release?
                                                    .f
 9,4, Docs facility ER plan include information on emergency health care?

 9.5. Date of most recent review/update of facility ER plan
                                       ...... '  i       ,
 9,6. Date of most recent emergency response training for facility's employees
                  iiii'5 3 1 iiii > j*,:.1 *j|aSi ...... v i      iii: ;;•    ••"  •        ........ 1,[*L|»  '""j">,   ' '       ' "J;-'(s
                       " ..... •!'         'i1'     ' "          ":*---    -'«       •     "*••
    b. Phone number (410) 123-4567
               "i. .....      •••  ,::>:,,,
9.8. Subject to (select all that apply)
      T .......... * ........... ! .................... ............. ' "- .......... T" ..... ..............................  :
    9.g.a: SH   1910.38    "       7 .....
    9.8.C. Clean" Water Act/SPCC
               .............      '      '
   ,9.s.d.RCRA

   9.8.c. OPA-90
                                v	'•  :^.,^:
-------