BOC Gases - Lincoln - Executive Summary |
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The BOC Gases Lincoln facility, owned and operated by The BOC Group, Incorporated is located at Lomar Dr. & Old Ferry Rd., Lincoln, AL. The management and employees of the Lincoln facility are committed to the prevention of any accidental releases of MAPP (Methylacetylene-Propadiene/Propylene/Propane Mixture). If an accidental release should occur, the facility is prepared to work with the local fire department, or other authorities to mitigate any release and minimize the impact of the release to the community and the environment. The Lincoln operation is a MAPP (Methylacetylene-Propadiene/Propylene/Propane Mixture) storage and distribution facility which is generally unmanned. When manned, the facilities primary operation is the distribution ,unloading of MAPP (Methylacetylene-Propadiene / Propylene/Propane Mixture) from railcars (35,000 gal/144,700 lb.) into two 18,000 gal (73,400 lb ) high pressure ASME storage tanks. The MAPP is then transfilled into DOT approved road tanker s and distributed to customers. The worst-case scenario, based on the EPA's definition for a flammable gas release, would be the rupture of the 35,000 gallon MAPP Rail Car Tank. The results would be a maximum release of 145,000 lbs of MAPP over a 10 minute period. The endpoint of 1 psi overpressurization was determined to be 0.42 miles using the RMP*Comp. (1.06) software. The weather conditions used were a wind speed of 1.5 meters/sec., Stability Class F, an air temperature of 77 degrees F and urban topographical terrain. The impacted area would affect 44 residents and no special receptor based on the 1990 US Census data obtained from "Land View III". Two business / industries are also within the endpoint which are; National Ammonia and Dallas Propane. No passive/active mitigation or administrative controls were considered in this assessment. The alternative release, or more probable, scenario which was determined to be the release of MAPP from a 1 =" pressure safety . The maxim um flow was determined to be 2,160 lb/min for 60 minutes. The distance to a Vapor Cloud Fire endpoint is <0.1 miles. The release endpoint of 34mg/L was determined to be <0.10 miles using the RMP*Comp. (1.06) software. The Weather conditions used were a wind speed of 3.0 meters/sec., Stability Class D, and air temperature of 77 degrees F and urban topographical terrain. The affected area would affect 2 residents and two business/industries based on Land View III and actual observations. No special population or environmental receptors are affected by this scenario. Passive and Active Mitigation systems in place that would reduce the likelihood of a release or the release itself. These include check valves in the fill lines, Excess Flow Valves, a preventive maintenance schedule for the system, safeties and testing of the tanks. The facility has developed a comprehensive prevention program designed to prevent accidental releases of MAPP in accordance with EPAs Risk Management Part 68, Program Level #2. The program utilizes state-of-the-art technology, sound engineering practices, administrative controls and active employee participation. Written process safety information was developed for the MAPP system to enable managers, supervisors, and employees to identify and understand the process hazards. This information was utilized to develop a Hazard Review Checklist (HR) which assists management and employees in making decisions for improving safety and reducing the consequences of releases of MAPP. The HR focuses attention on equipment, instrumentation, utilities, human actions, (routine and nonroutine), and external factors that might impact the process by identifying potential failure points or failure modes in the process. The HR was review and updated on December 9, 1998 and will be updated at least every 5 years. Detailed 0perating procedures exist which describe tasks to be performed, dates to be recorded, operating conditions to be maintained, samp les to be collected, and safety and health precautions to be taken. The procedures were reviewed/approved to ensure they are technically accurate by employees, managers and personnel with the technical expertise/knowledge of the process. The operating procedures were review on December 9, 1998 and are annually reviewed/revised as necessary to reflect current operations. Employees are thoroughly trained, including maintenance and contractor employees. The training meets and exceeds the requirements as outlined in OSHAs hazard communication standard 29 CFR 1910.1200. Training includes operating procedures, safe work practices, emergency procedures (including alarms), special assignments, evacuation and emergency response; safety rules and procedures; routine and nonroutine work authorization; and other pertinent process safety information. Each employee trained has a defined and documented program based on their job duties. The training goals and objectives have been established and written in clear and measurable terms. Hands-on training is provided to employees to enhance their senses beyond listening. In addition, employees receive traditional classroom instruction including lectures, videos, programmed and on-the-job instruction. Employees are encouraged to actively participate. The employees are periodically evaluated to ensure they posses the necessary skills and knowledge via written tests, observation and/or oral interviews. The training program was last reviewed in December 1998. An on-going mechanical integrity program (maintenance) is used to ensure safe process operations. Equipment used to store, process, or handle MAPP has been designed, constructed, installed, and maintained to minimize releases. The mechanical integrity program includes the identification and categorization of equipment/instrumentation, inspection/tests and their frequencies, development of maintenance procedures and training of maintenance personnel, criteria for accept able test results, documentation of test/inspection results, and documentation of manufacturer's recommendations to prevent failure of equipment and instrumentation. This program was review in December 1998 Management of Change (MOC) procedures have been developed for permanent changes to process chemicals, technology, equipment and facilities. MOC procedures are designed to ensure that prior to any change occurring, that technically qualified personnel with knowledge and expertise of the chemical process, reviews and approves the proposed changes. This would include both technical and mechanical changes. Process changes include all modifications to equipment, procedures, raw materials and processing conditions other than "replacement in kind". A Process Change Authorization is required for all changes. Management of Change procedures were review on __________. Process incidents which result in or could reasonably have resulted in a release of MAPP are investigated, including "n ear misses", within 48 hours of the incident. The purpose of the incident investigation is to identify the underlying causes of the incident and to implement corrective action to prevent similar incidents and avoid past mistakes. Process incidents are investigated by a Team which include both management and employees and is multidisciplinary. An incident report is prepared following the investigation which includes the findings, conclusions, and recommendations. The Facility Manager is responsible for ensuring that all report recommendations are completed or resolved by those individuals responsible for follow-up. All resolutions are communicated to all affected employees. The facility receives a compliance audit in accordance with EPA's Risk Management Standard Part 68 at least once every three years. The audit includes an evaluation of the design and effectiveness of the risk management system and a field inspection of the safety and health conditions, and practices to ensure com pliance. The Team uses an audit tool to document each audit step and ensure an effective audit is conducted. A Protocol Policy has been developed to ensure that proper follow-up is accomplished. BOC Gases will make available all information, including any Trade Secret information as it relates to compliance with this regulation. The facility has an Emergency Response Plan which has been integrated with the local community Emergency Response Plan. All employees and contractors are trained in the plan prior to commencement of work. The Emergency Plan is tested and critiqued twice a year to insure that it is current. Changes are made and reviewed if deficiencies are found. The site does not have trained Emergency Responders at the technician level, however, BOC maintains trained technician level Emergency Responders on 24hr. call through out the US. Safety improvement is an on-going process at the facility. Periodic evaluations are performed to assess the maintenance of safe con ditions. There are no additional specific MAPP safety recommendations for implementation at this time. |