IMTT-Bayonne - Executive Summary

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EXECUTIVE SUMMARY 
 
Accidental Release and Emergency Response Policies 
 
The IMTT- Bayonne facility is a liquids bulk storage terminal, providing tank storage capacity for customers. The terminal has a mission to provide the highest quality service to customers while maintaining a safe workplace and protecting the environment. The terminal is proactive in achieving these goals. The terminal policy is to prevent releases before they happen and to provide the appropriate level of emergency response should an accidental release or other emergency occur. 
 
The Stationary Source and Regulated Substances Handled 
 
The IMTT- Bayonne terminal requires an RMP because it stores several compounds in excess of the RMP threshold quantities as identified in the Federal Register, January 31, 1994. These include the following: 
 
      Butane - rail car unloading racks and operations in Yards 4 and 6 
 
      Propylene oxide/ methylene chloride blend  - tank 12638 along with associated loading and unloading syst 
ems and operations 
                                                                                                                                                                                  Ethylenediamine - tank 14370 along with associated loading and unloading systems and operations 
 
Worst Case Release Scenarios 
 
The worst case release scenarios for these regulated substances include: 
 
Flammable regulated substances: 
 
Scenario: 
 
   A railcar in either yard 4 or yard 6 containing butane ruptures, releasing the entire contents, 150,000 lb., of  butane.  
 
   100% of the butane is released into the air. 
 
   A vapor cloud explosion occurs.  
 
Administrative Controls: 
 
   ISO 9000 operating procedures 
 
   Operators present during all unloading operations. 
 
Mitigation Measures: 
 
   Unloading systems are designed to API Practice 251 
0. Design features include excess flow valves and automatic shutoff valves. 
 
   Fire water monitors surround the unloading systems. 
 
Toxic Regulated Substances: 
 
Release Scenario: 
 
   The tank containing ethylenediamine ruptures releasing the entire contents of the tank into a diked area.The contents are released into a diked impoundment. 
 
   The liquid pool evaporates, releasing the hazardous material into the atmosphere. 
 
   Administrative Controls: 
 
   ISO 9000 operating procedures. 
 
   Operators present during all unloading operations. 
 
Mitigation Measures: 
 
   Tank is located in a diked area. 
 
   Fire suppression foam injection into tank along with fire water lines.  
 
   Line isolation valves  
 
Alternative Release Scenarios: 
 
Flammable Regulated Substances 
 
Release Scenario: 
 
   A line ruptures during the railcar unloading resulting in a 10 minute release of butane.  
 
   100% of the released material vaporizes. 
 
   A vapor cloud explosion occurs. 
 
Administrative Controls: 
 
   ISO 9000 operating procedures 
 
 
   Operators present during all unloading operations. 
 
Mitigation measures: 
 
   Unloading systems are designed to API Practice 2510. Design features include excess flow valves and automatic shutoff valves safety switches and interlocks, safety relief valves. 
 
   Fire water monitors surround the unloading systems. 
 
Toxic Regulated Substances: 
 
   A line rupture during the ethylenediamineor propylene oxide/methylene chloride tank unloading  occurs into a contained area. 
 
   There is a 5 minute release of liquid into the dike. The liquid pool evaporates, releasing the hazardous material into the atmosphere 
 
Administrative Controls: 
 
   ISO 9000 operating procedures. 
 
   Operators present during all unloading operations. 
 
Mitigation Measures: 
 
   Unloading equipment is located in an area contained by drains. 
 
   Fire suppression foam monitor system along with fire water lines.  
 
   Line isolation valves. 
 
Accidental Release Prevention Program 
 
IMTT maintains a comprehensive accidental release prevention prog 
ram. For all materials handled on site along with the regulated substances, safety information is maintained regarding the materials, tanks and associated equipment. Hazard analyses have been carried out for the regulated processes.  
 
Operating procedures including ISO 9000 procedures and work instructions are followed in all loading and unloading operations. IMTT- Bayonne operators are trained to these procedures and receive additional safety training. 
 
IMTT- Bayonne maintains an extensive maintenance facility and provides continued inspection and maintenance of tanks, loading and unloading systems at the terminal. 
 
Incidents are tracked through an incident investigation program with prompt followup. 
 
Five-Year Accident History 
 
There have been no accidents involving any of the regulated substances per the definition in 40 CFR 68.42. 
 
Emergency Response Program 
 
IMTT- Bayonne maintains both a Spill Prevention Controls and Countermeasures Plan and an Emergency Response Action Plan. The 
se plans are supported by a fire brigade and an emergency response team. These groups maintain a large inventory of fire fighting apparatus and emergency response equipment and materials. 
 
There is an annual emergency response drill coordinated with local emergency planning and  response agencies.
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