United States
       Environmental Protection
       Agency
Office of Solid Waste
   and
Emergency Response
   EPA 550-B-00-001
      March 2009
www.epa.gov/emergencies
             RISK MANAGEMENT
             PROGRAM GUIDANCE
             FOR
             PROPANE STORAGE
             FACILITIES
             (40 CFR PART 68)
Office of Emergency Management

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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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                            TABLE OF CONTENTS
INTRODUCTION
      Am I Covered?                                                               1
      What Do I Have To Do?                                                        2
PROGRAM 1
      Eligibility                                                                   5
      What Must I Do For A Program 1 Process?                                          6

PROGRAM 3                                                                      9

      What Must I Do For A Program 3 Process?                                          9
      What Are The Release Scenarios?                                                 9
      What Do I Have To Do For The Prevention Program?                                10
      What Do I Have To Do For The Emergency Response Program?                        15
      What Do I Have To Do For My RMP?                                            15

SAMPLE RMP FOR PROGRAM 1 STORAGE FACILITY                               17

SAMPLE RMP FOR PROGRAM 3 STORAGE FACILITY                               23

APPENDIX A:       HOW DO I DETERMINE IF MY SEPARATE (NON-
                   INTERCONNECTED) PROPANE TANKS ARE CO-LOCATED

APPENDIX B:       RELEASE CALCULATIONS

APPENDIX C:       CHECKLISTS AND OTHER DOCUMENTS

                   Process Safety Information
                   Propane Storage Facility Checklist
                   Operating Procedure Requirements
                   Maintenance Training
                   Maintenance Inspection Checklist and Tests for Propane Storage Facilities

LIST OF TABLES

Table 1:       Typical Water Capacity of Propane Tanks, Transports, and Railroad Tank Cars
Table 2:       Distance to a 1 PSI Overpressure
Table 3:       Distances to 1 PSI for Pipe Releases
Table 4:       Ways to Comply with Some Prevention Elements

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          TABLE OF POTENTIALLY REGULATED ENTITIES
This table is not intended to be exhaustive, but rather provides a guide for readers
regarding entities likely to be regulated under 40 CFRpart 68.  This table lists
the types of entities that EPA is now aware could potentially be regulated by this
rule and covered by this document. Other types of entities not listed in this table
could also be affected.  To determine whether your facility is covered by the risk
management program rules in part 68, you should carefully examine the
applicability criteria discussed in Chapter 1 of this guidance and in 40 CFR
68.10.  If you have questions regarding the applicability of this rule to a
particular entity, call the EPCRA/CAA Hotline at (800) 424-9346 (TDD: (800)
553-7672).
Category
Propane
manufacturers and
processors
Propane wholesalers
NAICS
Codes
32411
32511
42271
42272
SIC
Codes
2911
2865
2869
5171
5172
Examples of Potentially Regulated
Entities
Petroleum refineries
Petrochemical Manufacturers
Bulk stations and terminals
Other petroleum product wholesalers

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                                    INTRODUCTION
This guidance is intended for propane storage facilities, such as wholesale distribution facilities and bulk
storage terminals. This document is a revision of EPA's October 1998 guidance for propane storage
facilities.  The document has been revised to reflect changes resulting from the 1999 Chemical Safety
Information, Site Security and Fuels Regulatory Relief Act.

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 may need to 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 for propane storage, you must be in compliance no later than January 5, 2000, or the
date on which you first have more than a threshold quantity of a regulated substance in a process,
whichever is later.

If you have more than 10,000 pounds of propane, you are subject to part 68 unless one of the following
applies to you:

• •     The propane is stored for use as a fuel at your facility.
• •     The propane is held for sale, and the facility is a retail facility. A retail facility is one at which
       more than half of the income is obtained from direct sales to end users or at which more than half
       the fuel sold, by volume, is sold through a cylinder exchange program.

If you have more than 10,000 pounds of propane and you manufacture propane, use it as a feedstock, or
store it in bulk for sale, other than to end users, or if your retail sales do not make up more than half of
your income, you are subject to part 68. If you manufacture  or use  propane as a feedstock or store it for
wholesale distribution and use it as a fuel, the propane used for fuel is not covered by part 68; the
propane manufactured, processed, or stored for wholesale distribution is subject to part 68 provided the
quantity is greater than 10,000 pounds. If you use propane to fuel a covered process containing other
regulated substances above their thresholds, the propane is not covered, but you will have to consider the
hazards created by the propane when you conduct your process hazard analysis or hazard review.

For most propane storage facilities, 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 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.
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Table 1 assumes that tanks are filled to 88 percent of capacity, the maximum level allowable under
NFPA-58 at 60Ť F. If you always keep your tanks filled to a lower level, you should adjust these numbers
to reflect your lower inventory.  If you have larger tanks, multiply the water capacity times 3.696 to
determine pounds at 88 percent capacity.

                                          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 112J340W & 112T340W
114J340W& 114T340W
114J400W& 114T400W
Bobtails (Delivery Cargo Tank)
Capacity in Gallons
12,000
18,000
30,000
40,000
60,000
100,000
120,000
8,000-11,000
11,000-34,500
26,000 - 34,500
750 - 3200
Capacity in Pounds
44,400
66,500
111,000
148,000
222,000
370,000
444,000
30,000-41,000
41,000-128,000
96,000-128,000
2,800-12,000
Also, add up the amounts of propane in tanks that are connected or close together. If you have four 750-
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 10,000-pound threshold. You should also consider whether, if one tank exploded, the
other tanks could be affected by the shrapnel or fire. If you have several groups of propane tanks, widely
separated,  you may be considered to have multiple processes (see Appendix A for additional guidance on
determining whether your propane tanks are separated far enough to be considered multiple processes.)

WHAT DO I 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.
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• •    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.
• •    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 detailed guidance on Program 3. Propane  storage facilities subject to
part 68 will generally either be eligible for Program 1 or subject to Program 3. The OSHA PSM standard
exempts all retail facilities, using the same definition of retail facilities given above, and fuel users, but
covers wholesalers and manufacturers that process propane. Consequently,  a propane facility subject to
part 68 will generally also be subject to the OSHA PSM standard. If you are subject to the OSHA PSM
standard, you should also  see EPA's General Guidance for Risk Management Programs or OSHA's
Process Safety Management Guidelines for Compliance (OSHA 3133).

If you can qualify a process for Program 1, it is in your best interests to do so, even if the process is
already subject to OSHA PSM. For Program 1 processes, the implementing agency will enforce only the
minimal Program  1 requirements. If you assign a process to Program 3 when it might qualify for
Program  1, the implementing agency will enforce all of the requirements of the higher program level. If,
however, you are already in compliance with the prevention elements of Program 3, you may want to use
your RMP to inform the community of your prevention efforts.
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                                       PROGRAM 1
ELIGIBILITY

Some propane storage facilities will be eligible for Program 1, particularly 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 1 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 1 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
51,001-90,000
90,001 - 120,000
Distance to Endpoint
(Miles)
0.1
0.2
0.3
0.4
0.5
0.6
If you have different quantities, RMP*Comp, a software system developed by EPA and NOAA, will
allow you to calculate worst-case distances quickly. RMP*Comp can be downloaded from
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www.epa.gov/emergencies/rmp. You may also use other models to develop distance estimates (see 40
CFR 68.22 for the parameters you must use in estimating worst-case release distances). 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.

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 www .epa. gov/emergencie s/rmp).

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 a web-based submission system, called RMP* e Submit, that will make filing a RMP or making
changes or corrections to an existing plan easy. You can access this information at
www.epa.gov/emergencies/rmp. EPA's previous system for electronic submission - RMP*Submit -
will no longer be available on the EPA website after March 2009.

The RMP includes registration information (basic facility information); the worst-case  release scenario; a
five-year accident history (of accidents that caused deaths, injuries, or significant property damage on
site, known offsite deaths or injuries, offsite property or environmental damage, or evacuations or
shelterings in place); emergency response activities; a brief executive summary; and a certification
statement.
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                                               7

The executive summary should be a brief description of the facility, the worst-case release scenario, steps
you take to prevent accidents (e.g., complying with state and local laws), emergency response
information (e.g., your coordination with the fire department), and any steps you are planning to take to
improve safety (e.g., 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 storage facilities
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 Program 1  propane facility is attached.
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                                              9

                                      PROGRAM 3
If your process is not eligible for Program 1, the process is most likely in Program 3 because it is
probably subject to the OSHA PSM standard. Most propane storage facilities that are in commercial or
industrial areas or close to residential areas will be subject to Program 3.

WHAT MUST I DO FOR PROGRAM 3?

For Program 3, you must:

• •     Analyze both a worst-case release scenario and an alternative release scenario;
• •     Implement a prevention program;
• •     Implement an emergency response program if your employees will respond to a release; and
       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 or
RMP*Comp 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.

• •     Pull-Away 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).

• •     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.

Appendix B includes release calculations for alternative scenarios  as well as scenarios in addition to the
two provided above.
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                                          TABLE 3
                        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
You must estimate in the RMP residential populations within the circles defined by the endpoints 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). You may use Census data and round to two significant digits (e.g.,
1147 becomes  1100, and 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 3 prevention program is identical to the OSHA PSM Standard and has 12 elements:

+     Safety information
+     Process Hazard Analysis
+     Operating procedures
+     Training
+     Mechanical Integrity (Maintenance)
+     Pre-startup reviews
+     Management of change
+     Compliance audits
+     Incident investigation
4-     Employee participation
+     Hot work permit
+     Contractors

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 most of what 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. For a more complete discussion of the requirements, see the General
Guidance for Risk Management Programs, available at www.epa.gov/emergencies/rmp. and  OSHA's
Process Safety Management Guidelines for Compliance (OSHA 3133).

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
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                                              11

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

• •    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.

See the EPA and OSHA guidance documents cited above for more information on the elements that must
be documented as part of your safety information.

Process Hazard Analysis. You are required to conduct a process hazard analysis (PHA) 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

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                                              12

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. See the EPA and OSHA guidance documents cited above for more information on analysis
techniques and issues to be considered. Appendix C provides a checklist that you can use.

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. See the EPA and OSHA
guidance documents cited above for more information on the elements that must be included in the
procedures. A list of NPGA documents that may meet these requirements is included in Appendix C.

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 and responsibilities as provided in the operating procedures. You are not required to provide a
specific amount or type of training. You should develop a training approach that works for you. The
NPGA's Certified Employee Training Program and any training you do to meet DOT requirements may
satisfy this requirement. You must provide  refresher training. You must determine the frequency of
refresher training in consultation with any affected employees, but you must provide refresher training at
least once every three years. Training must be documented.

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 must 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 things may affect 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.
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                                              13

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.

See the EPA and OSHA guidance documents cited above for more information on these requirements.
A list of NPGA training that applies to maintenance procedures and a maintenance inspection checklist
are included in Appendix C.

Management of Change. You must prepare and implement procedures to manage changes, except
replacements in kind. The purpose of this requirement is to ensure that changes you make do not create
any new hazards  and that your employees and contractors are informed of the changes and trained in any
new procedures that are needed prior to start-up. See the EPA and OSHA guidance documents cited
above for more information on these requirements.

Pre-Startup Review. Whenever you install a new covered process or modify an existing one, you must
perform a pre-startup review to ensure that the equipment is in accordance with the  design specifications,
that all procedures related to the equipment are up-to-date, and that employees have been trained in the
operation of the new or modified process. See the EPA and OSHA guidance documents cited above for
more information on these requirements.

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 five years.

Incident Investigation. You must investigate each incident that 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. You must start the  investigation no later
than 48 hours after the accident.  You must create a report on the 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.

Employee Participation. You must develop a written plan to implement the requirements for employee
participation.  See the OSHA guidance document cited above for more information  on this requirement.

Hot Work Permit. You must issue hot work permits  for hot work conducted near your covered process.
See the OSHA guidance document  cited above for more information on this requirement.

Contractors. If you use contractors to perform maintenance, renovation, or specialty work on or near a
covered process,  you must implement a program to ensure that your contractors are qualified to perform

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                                            14
the work and are informed of the potential hazards.  See the OSHA guidance document cited above for
more information on these requirements.

Table 4 summarizes the ways that propane facilities can comply with some of these requirements.

                                         TABLE 4
               WAYS TO COMPLY WITH SOME PREVENTION ELEMENTS
Program 3 Prevention Element
Safety Information
Hazard Review
Operating Procedures
Training
Maintenance
Compliance Audits
Incident Investigation
How a Propane Facility Can Meet This Requirement
- 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
- Use checklist in Appendix C
- Review compliance with NFPA-58
- Implement NPGA Certified Employee Training Program
- Comply with NFPA-58
- Comply with NPGA safety bulletins
- Use written operating procedures for propane systems
- 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
- Implement NPGA Certified Employee Training Program
- Use checklist in Appendix C
- Establish a maintenance and testing schedule
- Document inspections and maintenance done by equipment
vendors
- Conduct and document a compliance audit every three years;
respond to each finding, and document that you have corrected
any deficiencies.
- Implement practices in NPGA's LP-Gas Safety Handbook
- Implement NPGA bulletin #202-93 "After Accident Procedure"
January 27, 2000

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                                             15

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

If you have at least one Program 3 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.

Some propane storage facilities will rely on local responders to handle any accident.  If you plan to have
your employees respond to a propane 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 3 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 3 processes, but they all contain
propane, you report only one worst-case scenario and one alternative scenario to cover all of them. (If
you have multiple Program  1 processes, you must report a worst-case scenario for each Program 1
process to establish that the process is eligible for Program  1.)

If you have one  Program 3 process, your RMP will include:

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

A sample RMP  and certification statement for a Program 3 propane facility is attached.
January 27, 2000

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                                                         16
January 27, 2000

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                                                  17
   SAMPLE RMP for PROGRAM 1 PROPANE STORAGE FACILITY
              (This sample RMP is for a fictitious facility named,  "Smith Gas Company Terminal. "
                            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 release
scenario for the following processes is less than the distance to the nearest public receptor:

        Wholesale LPG facility

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, or a release of a regulated substance from the process,
entry 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, to the 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

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 Garvin County Fire Department and request that
they respond to the emergency.

A description of your facility and the regulated substances handled. This facility wholesales LPG, supplying
retail outlets, primarily gas stations and cylinder filling operations at cooperatives. The facility consists of a single
18,000-gallon tank, which we fill to between 85% and 88% capacity.

The worst-case release scenario. Our worst-case scenario is failure of the 18,000-gallon storage tank when filled
to the greatest amount allowed (88% at 60F), resulting in a vapor cloud explosion. Since this facility is located in a
relatively remote, unoccupied area, the worst-case scenario would not affect anyone beyond our 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.


January 27, 2000

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                                                  18




Planned changes to improve safety. None.




1. REGISTRATION




1.1 Source Identification




   1. La. Facility Name:      Smith Gas Company




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




   l.l.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




   1.4.a. Facility DUNS:




   1.4.b. Parent Company #1 DUNS:




   1.4.c. Parent Company #2 DUNS:




1.5 Facility Location Address




   a. Street         42 Rural Rt 7




   b. Street-Line 2:




   c. City:  Plainville       d. State: OK    e. Zip Code:     12345   f. County:       Garvin




   g. Facility Latitude (degrees, minutes, and seconds):    34    40      20




   h. Facility Longitude (degrees, minutes, and seconds): -097   21      06




   i. Method for determining Lat/Long :       II (interpolation, map)




   j. Description of location identified by Lat/Long :    AB     Storage Tank




1.6 Owner/Operator




   a. Name:        William R. Smith




   b. Phone:       (555) 555-5555




   Mailing Address:




   c. 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




   a. Name:        William R. Smith






January 27, 2000

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                                                   19

   b. Title:         Company owner

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

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:        1

1.12. Covered by (select all that apply)

   a. OSHA PSM:   Yes

   b.EPCRA section 302:

   c. CAA Title V Air Operating Permit ID:

1.13. OSHA Star or Merit Ranking: No

1.14. Last Safety Inspection Date: 12/07/97

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

1.16. Will this RMP involve Predictive Filing? No

1.17. Process Specific Information. For each 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):
1
Storage tank
1
42272
January 27, 2000

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                                                    20
c. Chemical
c.l. Name:
Propane
c.2. CAS Number:
74-98-6
c.3. Quantity (Ibs.):
67,000
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.)        67,000 pounds




4.5. Endpoint Used: 1 psi



4.6. Distance to endpoint (miles)   0.30 miles




4.7. Residential population within distance to endpoint       0



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



a. Schools                        d. Prisons /Correctional facilities



b. Residences                    e. Recreation areas



c. Hospitals                      f. Commercial/industrial areas



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



   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)



   a. Dikes



   b. Fire walls



   c. Blast walls



   d. Enclosures



   e. Other (specify)




4.11. Graphics file name (Optional)
January 27, 2000

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                                                  21

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

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

9.8. Subject to (select all that apply)

   9.8.a. OSHA  1910.38

   9.8.b. OSHA  1910.120

   9.8.c. Clean Water Act/SPCC

   9.8.d. RCRA

   9.8.e. OPA-90

   9.8.f. State EPCRA rules/law

   9.8.g. Other (specify)
January 27, 2000

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                                                          22
January 27, 2000

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                                                   23


    SAMPLE RMP for PROGRAM 3 PROPANE  STORAGE FACILITY
                      (This sample RMP is for a fictitious facility named "Maryland LPG. "
                             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
   Title                                                   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. We also maintain a fire brigade on site to handle small emergencies.

   A description of your facility and the regulated substances handled.  This facility is a bulk terminal storing
   LPG for resale to retail propane outlets.  The facility consists of four 30,000-gallon tanks and two 120,000-
   gallon tanks.

   The worst-case and alternative release scenarios. Our worst-case scenario is failure of one 120,000-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 10-minute release and
   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, the OSHA PSM standard, 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 Howard County Fire Department and request that they help respond to the emergency. We also
   have a trained fire brigade. We have coordinated our response plans with the  fire department; members of the
   fire department have inspected our propane system and conducted a joint exercise with us.

   Planned changes to improve safety.  None.
January 27, 2000

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                                                   24




   1. REGISTRATION




1.1 Source Identification




   a. Facility Name: Maryland LPG




   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




   a. Facility DUNS:




   b. Parent Company #1 DUNS:




   c. Parent Company #2 DUNS:




1.5 Facility Location Address




a. Street         238 Main Street




b. Street-Line 2:




c. City:  Odenton       d. State: MD    e. Zip Code:     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 :       II (interpolation, map)




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




1.6 Owner/Operator




a. Name:       Mary L. Jones




b. Phone:       (410)777-1234




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






January 27, 2000

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                                                   25
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:

1.10. LEPC (Optional):   Howard County LEPC

1.11. Number of full-time employees (FTEs) On Site:        6

1.12. Covered by (select all that apply)

   a. OSHA PSM:   Yes

   b.EPCRA section 302:

   c. CAA Title V Air Operating Permit ID:

1.13. OSHA Star or Merit Ranking: No

1.14. Last Safety Inspection Date: 10/19/98

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

1.16. Will this RMP involve Predictive Filing? No

1.17. Process Specific Information.  For each 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):
1
Storage Tanks
3
42271 Petroleum Bulk Terminal
January 27, 2000

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                                                    26
c. Chemical
c.l. Name:
Propane
c.2. CAS Number:
74-98-6
c.3. Quantity (Ibs.):
1,331,000
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.)        120,000 pounds




4.5. Endpoint Used: 1 psi



4.6. Distance to endpoint (miles)   0.60 miles




4.7. Residential population within distance to endpoint       200



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



a. Schools • •                    d. Prisons /Correctional facilities




b. Residences   • • •            e. Recreation areas • •



c. Hospitals • •                  f. Commercial/industrial areas •  •



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



   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)



   a. Dikes



   b. Fire walls



   c. Blast walls



   d. Enclosures



   e. Other (specify)




4.11. Graphics file name (Optional)
January 27, 2000

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                                                   27




5. 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 all that apply)



   a. Schools                        d. Prisons /Correctional facilities




   b. Residences    • • •             e. Recreation areas



   c. Hospitals                      f. Commercial/industrial areas • •



5.9. Environmental receptors within distance to endpoint



   a. National or state parks, forests, or monuments



   b. Officially designated wildlife sanctuaries, preserves, or refuges



   c. Federal wilderness area



5.10. Passive mitigation considered (select all that apply)



   a. Dikes



   b. Fire walls



   c. Blast walls



   d. Enclosures



   e. Other (specify)




5.11. Active mitigation considered (select all that apply)



   a. Sprinkler system




   b. Deluge system



   c. Water curtain




   d. Excess flow valve



   e. Other (specify)






January 27, 2000

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                                                  28
5.12. Graphics file name (Optional)



7. PREVENTION PROGRAM - PROGRAM 3



For each process or process unit:



7.1. NAICS Code for process: 42271
7.2. Chemical name(s):
Propane
7.3. Safety information




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




   a. 1 Date of completion of most recent PHA/update           02/04/98




   a.2 Technique used              Checklist



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




   c. Major hazards identified (select at least one)




      Toxic release                    Overpressurization       • • •            Earthquake



      Fire            • • •            Corrosion                               Floods



      Explosion       • • •            Overfilling              • • •            Tornado



      Runaway reaction                Contamination                           Hurricanes




      Polymerization                  Equipment Failure        • • •            Other



                                      Loss of cooling, heating, electricity, instrument air



   7.4.d. Process controls in use (select at least one)




      Vents           • • •                    Emergency air supply



      Relief valves    • • •                    Emergency power



      Check valves                            Backup pump




      Scrubbers                               Grounding equipment     •  • •



      Flares                                   Inhibitor addition




      Manual shutoffs         • • •            Rupture disks




      Automatic shutoffs       • • •            Excess flow device       •  • •






January 27, 2000

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                                                    29




       Interlocks                                Quench system




       Alarms and procedures   • •  •            Purge system




       Keyed bypass                            Other:  Breakaway couplings



   7.4.e. Mitigation systems (select all that apply)



       Sprinkler system         • •  •            Deluge system



       Dikes                                   Water curtain




       Fire walls                                Enclosure



       Blast walls                               Neutralization




                                               Other (specify)



   7.4.f. Monitoring/detection systems (select all that apply)



       Process area detectors                    Other (specify)



       Perimeter monitors




   7.4.g. Changes  since last PHA update (select all that apply)



       Reduction in chemical inventory                   Installation of perimeter monitoring systems



       Increase in chemical inventory                     Installation of mitigation systems




       Change in process parameters                      None required/recommended




       Installation  of process controls    • • •            Other (specify)



       Installation  of process detection systems




7.5. Date of most recent review/revision of operating procedures      03/01/97



7.6. Training




   a. Date of most recent review/revision of training programs           03/01/97




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




       Classroom                       On the job      • • •



       Other (specify)



   c. Type of competency test used (select at least one)



       Written test                      Observation    • • •



       Oral test                         Other (specify)




       Demonstration   •  •  •






January 27, 2000

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                                                   30
7.7. Maintenance




   a. Date of most recent review/revision of maintenance procedures     04/01/97



   b. Date of most recent equipment inspection/test                     10/19/98




   c. What equipment inspected/tested                                Propane tanks, valves, and piping



7.8 Management of Change



   a. Date of the most recent change that triggered management of change procedure:




   b. Date of the most recent review or revision of management of change procedures: 6/14/98



7.9  Pre-Startup Review



  The date of the most recent pre-startup review:



7.10. Compliance audits



   a. Date of most recent compliance audit



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



7.11. Incident investigation:




   a. Date of most recent incident investigation



   b. Expected date of completion of any changes resulting from the investigation



7.12 Employee participation plan




   Date of the most recent review or revision of the employee participation plan: 4/16/99



7.12 Hot work permit procedures




   Date of the most recent review or revision of the hot work permit procedures: 24/12/97



7.13 Contractor safety procedures




   a.  Date of the most recent review or revision of the contractor safety procedures: 4/16/99




   b.  The date of the most recent review or revision of contractor safety performance: 4/16/99
January 27, 2000

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                                                  31

9. EMERGENCY RESPONSE

9.1. Emergency response (ER) plan

   a. Is facility included in the written community emergency response plan?       Yes

   b. Does facility have its own written emergency response plan?                Yes

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

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

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

9.5. Date of most recent review/update of facility ER plan    11/06/98

9.6. Date of most recent emergency response training for facility's employees 3/14/99

9.7. Local  agency with which the facility ER plan or response activities are coordinated

   a. Name of agency        Howard County Fire Department

   b. Phone number (410) 123-4567

9.8. Subject to (select all that apply)

   9.8.a. OSHA  1910.38

   9.8.b. OSHA  1910.120

   9.8.c. Clean Water Act/SPCC

   9.8.d. RCRA

   9.8.e. OPA-90

   9.8.f. State EPCRA rules/law

   9.8.g. Other (specify)
January 27, 2000

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                                                          32
January 27, 2000

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                     APPENDIX A
        HOW DO I DETERMINE IF MY SEPARATE (NON-
   INTERCONNECTED) PROPANE TANKS ARE CO-LOCATED?
January 27, 2000

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January 27, 2000

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                                     APPENDIX A
              HOW DO I DETERMINE IF MY SEPARATE (NON-
     INTERCONNECTED) PROPANE TANKS ARE CO-LOCATED?

   For separate, above-ground, non-interconnected propane tanks, one way to determine whether the
   tanks constitute a single process (i.e., in rule language are "co-located") is to determine whether they
   are close enough together for a vapor cloud explosion resulting from the release of the total contents
   of one tank to cause the catastrophic failure of an adjacent tank. Table A-l indicates estimated
   separation distances based on this method.
                                        TABLE A-l
          ESTIMATED SEPARATION DISTANCES FOR CONSIDERING NON-
          INTERCONNECTED PROPANE TANKS AS SEPARATE PROCESSES
Tank Capacity (gal)
500
500
1000
1000
2000
2000
Tank Confinement
Partial - High
Low
Partial - High
Low
Partial-High
Low
Estimated Separation
Distance (ft)
61
41
76
51
96
64
   The estimated separation distances in Table A-l corresponding to "Partial - High" confinement are
   based on a TNT-equivalent yield factor of 10 percent.  This is the same yield factor specified in the
   RMP rule for conducting flammable gas worst-case scenario modeling using TNT-equivalent methods
   (readers should note that the distances in Table A-l are not intended as worst-case endpoint
   distances).  This yield factor is appropriate for vapor cloud explosions occurring in areas with
   numerous obstructions, such as in pipe racks, between stacks of crates or pallets, or near other closely
   spaced structures1. Table A-l distances corresponding to "Low" confinement may be used if your
   propane tanks are located outdoors2 in relatively flat, open terrain with few structures nearby (these
   separation distances are based on a TNT-equivalent yield factor of 3%).  Otherwise, the distances
   corresponding to "Partial-High" confinement should be used to give reasonably conservative
   separation distance estimates.
          1  Vapor cloud explosions occurring in congested or confined spaces are generally stronger due to higher flame speeds
   resulting from turbulence produced in unburned gases expanding ahead of the propagating flame front.
          2 NFPA-58 generally requires propane tanks to be located outside of buildings.

February 24, 1999

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                                               A-2
   To determine whether adjacent, non-interconnected propane tanks constitute a single process,
   measure the linear distance between the tanks and compare it to the estimated separation distance in
   Table A-l for tanks of that size and with that degree of confinement.  Tanks that are separated by less
   than the estimated separation distance in Table A-l  should generally be considered a single process
   and their quantities added together to determine if the process exceeds the RMP threshold of 10,000
   pounds. Individual tanks of propane which are separated by at least the estimated separation distance
   in Table A-l for tanks of that size and with that degree of confinement may generally be considered as
   separate processes and thus not subject to the RMP  regulation.

   The distances provided in the Table above should be treated as estimates. Other methods of
   determining separation distances may provide more accurate estimates and you are free to use other
   reasonable methods if you choose. Also, the separation distances provided here should be considered
   in relation to any unique circumstances at your site, such as topography, the presence of structures and
   obstacles, the presence of blast-mitigation features,  and other site-specific factors.  For example, if
   engineered blast-barriers are located between tanks, or if your tanks are underground, smaller
   separation distances may be appropriate3. On the other hand, topographical  features, such as a
   depression between two tanks where heavier-than-air propane vapor might collect, may warrant the
   use of larger separation distances.  Additionally, you should evaluate whether there are potential
   events other than vapor cloud explosions that could reasonably be expected to cause multiple tanks to
   fail, even at distances larger than those in Table A-l. EPA believes that for most properly designed
   outdoor propane installations, such events are extremely unlikely, and that separating tanks by at least
   the appropriate distance in Table A-l is sufficient to establish separate processes.  However, you
   should evaluate your own circumstances and maintain documentation to support your determination.

   Some readers of this guidance may conclude that it will be easier to re-locate one or more of their
   propane tanks to conform to the distances provided  above rather than taking the steps necessary to
   comply with the regulation. This is certainly permitted, and in some cases may be an appropriate risk-
   reduction measure. However, when taking such actions, you should be careful to maintain sufficient
   separation distances between your propane tanks and nearby buildings, roads, and public receptors.
   EPA recommends  consulting NFPA-58 or other applicable codes or standards to identify such
   distances.
           3 NFPA-58 generally recommends against installing fire walls, fences, earth or concrete barriers, and other similar
    structures around or over non-refrigerated LP-gas containers. There are some exceptions. For example, the standard permits
    such structures to partially enclose LP-gas containers, if the structure is designed in accordance with a sound fire protection
    analysis.

February 24, 1999

-------
                      APPENDIX B
                 RELEASE CALCULATIONS
February 24, 1999

-------
February 24, 1999

-------
                  APPENDIX  B - RELEASE CALCULATIONS
   The endpoints that can be considered for the alternative release scenario are explosion damage,
   radiant heat effect and lower flammability 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
   pull-away can occur if the driver fails to remove the  hoses between the storage tank and the transfer
   vehicle (bobtail or transport) before moving the vehicle. In this case, the 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 = • -x (4 in / 2)2 x  1 ft2 / 144  in2 x 25 ft = 2.182 ft3
   Wf = 2.182 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.

   PULL-AWAY EXPLOSION

   You can use equation C-l from EPA's OCA to calculate the distance exposed to greater than 1 psi
   overpressure. This method results in a distance to endpoint of 175 feet and the endpoint is 1 psi
   overpressure.
   D = 17(0.1 xWf
   Where,
   Wf     is the weight of propane in kilograms in the vapor cloud,
   Hcf    is the heat of combustion of propane from Appendix C of EPA's OCA,
   HCTNT   is the heat of combustion of TNT from Appendix C of EPA's OCA, and
   D      is the distance in meters from the explosion where overpressure exceeds 1 psi.

   D = 17 (.1 x Wf x 46333/4680)3 = 17 (.1 x 68.6/2.2046 x 46333/4680)3 = 53.29 meters =
   D = 174.8 feet

   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.
March 4, 1999

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                                                B-2

   PROCESS  PIPING BREAKS

   Liquid propane pipe failures:  1A", 1", 2", 3", 4" and 6". (Causes:  liquid expansion [failure of
   hydrostatic valves], a pull-away [failure of breakaway devices4], collision, corrosion.) For long pipes,
   where the length to diameter ratio is significantly greater than one, flashing (i.e., conversion of
   gaseous propane to liquid) in the discharge pipe results in a two-phase release. You can estimate the
   amount released from a line shear using the following equation:

   QR = 0.0853 x HA x F x L / [Vgl x (T x Cp)05]

   Where: QR     is the release rate in pounds per minute.
           FŁA     is the cross-sectional area  of the  pipe in square inches.
           F       is the frictional factor, which is 0.85 for pipe with a length to diameter ratio of 50.
           L       is the heat of vaporization, which is 426,000 joules per kilogram for propane.
           Vgl      is the specific volume of gas minus liquid in mVkg, which is 0.056 for propane.
           T       is the temperature in Kelvins (assumed to be 298).
           Cp      is the heat capacity, which is  2,400 joules/kilogram/Kelvin for propane.
           0.0853  is a units conversion factor.

   QR can be calculated using the values in the table below for FŁA.  Now Q (the release quantity) can be
   calculated for a 10-minute release, and D (the distance to the endpoint in feet) can be calculated using
   equation C-l from EPA's OCA.  Note that Q  cannot be larger than the amount of propane contained
   in your storage tank (this should be considered especially for 6" pipes).

   Fora 1" pipe:

   QR = 512.5 pounds per minute

   Q = QR x 10 minutes = 5,125 total pounds released (Q = Wf)

   D = 17(0.1 xWf xHCf/HCTNT)a = 17 x (0.1 x 5,125 / 2.2046  x 46333/4680)a = 224

   D = 224 meters  =  735 feet = 0.1 mile

   If you use this scenario as your alternative  release scenario, the distance to endpoint is 735 feet (or
   about 0.1 mile) and the endpoint used is 1  psi overpressure.
              See NFPA 58, 1998 Edition, Section 3-9.4.2. A breakaway device is used when dispensing LPG. 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 breakaway
    device means that the breakage occurs somewhere else rather than at the breakaway device during a pull away, thus negating the effectiveness
    of some or all of the other safety devices.

March 4, 1999

-------
                                           B-3
                                        TABLE B-l
            POTENTIAL DISTANCES TO ENDPOINT FOR PIPE RELEASES
                                   (for 1 psi Overpressure)
Pipe Size (inches)
0.50
1
2
3
4
6
HA (inches2)
0.20
0.79
3.14
7.07
12.57
28.27
QR
(pounds/minute)
128
512
2,050
4,612
8,199
18,449
Q Total Amount
Released after 10
minutes (pounds)
1,281
5,125
20,499
46,122
81,995
184,488
D (Miles)
0.1
0.1
0.2
0.3
0.4
0.5
   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 ft3/lb. To convert SCFM (air) to SCFM ^^^ multiply
   by 0.808.

   The release rate from one port is 27,950 SCFM (air/ 3 = 9,250 SCFM (air)

   Q(propane) = Q(air) x 0-808 / 8.66 ft3/lb = 863 Ibs/min x 5 min = 4,3151bs = 1957.4 kg

   D = 17 (0.10 x  1957.4 x 46,333/4680)a = 211.9 meters x 3.281 ft/meter = 695.2ft / 5280ft/mile =
   0.13 miles.
March 4, 1999

-------
                                   B-4
                                 TABLE B-2
             RELIEF VALVE DISCHARGES (FOR 1 PSI OVERPRESSURE)
Relief Valve Size
(inches)
Multiport 2!/2"
Dual Port 1%"
2!/2"
F/2"
1%"
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
(min)
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
March 4, 1999

-------
                     APPENDIX C
           CHECKLISTS AND OTHER DOCUMENTS
March 4, 1999

-------
March 4, 1999

-------
                      PROCESS SAFETY INFORMATION
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:






March 4, 1999

-------
                                                      C-2
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:











ASME NB# State ID#
ASME NB# State ID#
Revised By:

March 4, 1999

-------
                                                      C-3
March 4, 1999

-------
                                                       C-4

                           PROPANE STORAGE FACILITY CHECKLIST5 6

   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.
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?
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?
Yes/No/NA



Yes/No/NA




Comments



Comments




               Completing the Propane Storage Facility Hazard Review Checklist does not guarantee that your 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 years, various changes
    in NFPA 58 have been made to reduce the probability of a propane release. You should carefully review any change to NFPA 58 since your
    facility was constructed and consider appropriate changes to ensure the safety of your facility. Document the actions that you take. You should
    be ready to explain any differences between the version of NFPA 58 that you used to construct your facility and the current version.
March 4, 1999

-------
                                              C-5
     Piping, Equipment & Container Appurtenances
Yes/No/NA
Comments
     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?
        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?
     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?
     11. 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?
March 4, 1999

-------
                                             C-6
    Piping, Equipment & Container Appurtenances
Yes/No/NA
Comments
     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 3-2.11 ofNFPA 58,  1998 Edition?
     13. Do you have the appropriate corrosion protection
        required by 3-2.14 ofNFPA 58, 1998 Edition?
     14. On installations with pumps, are they installed according
        to 3-2.15.1 ofNFPA 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 ofNFPA 58, 1998 Edition?
     15. On installations with compressors, are they installed
        according to 2-5.3 and 3-2.15.2 ofNFPA 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) ofNFPA 58, 1998 Edition?
     16. Do your compressor and pump motors conform with 2-
        5.1.4 ofNFPA 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 ofNFPA 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 ofNFPA 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 ofNFPA 58, 1998 Edition?
    20. Do you have container appurtenance protection as
        specified in 2-3.7 ofNFPA 58, 1998 Edition?
    21. Do you have manual valves and emergency shutoff valves
        as required by 2-4.5.4, 3-2.10.11, 3-3.3.7 and 3-3.3.8 of
        NFPA 58, 1998 Edition?
March 4, 1999

-------
                                                     C-7
Piping, Equipment & Container Appurtenances
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 3-2.10.11(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 being used
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)?
3 1 . Is adequate transfer hose storage provided?
32. Are the written transfer, loading & unloading instructions
available (see § 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 § 68.54
of this model program)?
2. For operators on the job on or before June 21, 1999, do
they have the required knowledge, skills and ability to
perform their duties safely?
Yes/No/NA











Yes/No/NA


Comments











Comments


March 4, 1999

-------
                                                     C-8
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 § 68.52 of this model program)?
7. Do the written operating instructions reflect current
operation of the facility (see § 68.52 of this model
program)?
8. Have major modifications to your propane storage facility
taken place (see § 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?
Yes/No/NA








Comments








March 4, 1999

-------
                                                C-9
Human Factors
1 1 . 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?
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

Yes/No/NA







Comments

Comments







This Hazard Review was Completed by: On (Date):

   The latest date by which all changes resulting from the process hazard review are expected
March 4, 1999

-------
                                     C-10
  to be completed is
                   Date
                   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
Propane 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."
Tilling Propane Storage
Containers."
:'Unloading a Propane
Transport."
'Unloading a Propane Tank
Car."
Tilling Cargo Tanks on Bulk
Delivery Vehicles."
'Removing Propane from
Stationary ASME Tanks and
DOT Cylinders."





NPGA Bulletin









200-89
202-81
202-93
204-88
206-91









How to Control LP-Gas
Leaks & Fires
What you should do in
case of accidents
involving LP-Gas
Steps to Take in the Event
of an Accident Involving
Propane
How to Handle LP-Gas
Fires with Portable Fire
Extinguisher
Emergency Response
Guidelines
March 4, 1999

-------
                                                   C-ll
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 (1) above.
Consequences of
deviations and steps
required to correct or
avoid deviations.
Equipment
inspections.
NPGA Certified Employee
Training Program
(CETP)












NPGA Bulletin
207-94
211-91




Guidelines for Developing
Plant Emergency
Procedures
LP-Gas Fire Control and
HAZ MAT Training
Guide




March 4, 1999

-------
                                      C-12
                            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
March 4, 1999

-------
                                                   C-13
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
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 New Propane
Distribution Systems
March 4, 1999

-------
                                  C-14
    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?
II. 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 #134 "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



March 4, 1999

-------
                                                   C-15
a)
b)
d)
e)
f)
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?
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)
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?





Yes





Yes








No and Comment





No and Comment



March 4, 1999

-------
                                                   C-16
a)
b)
d)
e)
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?
Have the relief valves on containers larger than 2000
gallons and on vaporizers been tested or replaced within the
last 10 years as perNFPA 58, 1998 Edition
recommendation in E-2.3.2?
Does external visual inspection of the relief valve discharge
indicate no corrosion or obstruction?
VIII. 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)
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"?




Yes






Yes

Yes







No and Comments






No and Comments

No and Comments



March 4, 1999

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                                                   C-17
a)
b)
d)
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?
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?
XII. Hydrostatic Relief Valves (for Fixed Storage Tanks and
Vaporizers)
a)
b)
c)
Are the valves in good working order and not leaking?
Are the valves fitted with protective caps?
Are the valve discharges positioned to avoid impinging gas
on the tank?
XII. Transfer Areas
a)
b)
c)
d)
e)
f)
g)
h)
I)
j)
Are hoses in good condition and free of deterioration, wear,
and blisters? See NPGA Bulletin #1 14 "Guide to Hose
Inspection."
Are hoses capped or plugged when not is use?
Are hose couplings properly attached and fully seated on
the hose?
Are hose couplings worn or damaged?
Are coupling gaskets in good condition?
Are correct coupling wrenches available?
Are excess flow valves operating correctly?
Are the loading and unloading risers protected from traffic?
Are chock blocks provided for rail cars?
Have your fire extinguishers been tested and/or serviced?



Yes




Yes



Yes













No and Comments




No and Comments



No and Comments










March 4, 1999

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                                                 C-18
a)
b)
k)
m)
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?
Is adequate transfer hose storage available?
Are the written transfer instructions readily available?
XIV. Pumps and Compressors
a)
b)
c)
d)
e)
Are the shafts free of leaks?
Are pumps equipped with a spring loaded by-pass valve
where required?
Is the by-pass valve functioning properly?
Are drive belts or couplings protected by suitable guards?
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





Yes






No and Comments





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:

March 4, 1999

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