GATC - Waycross, GA Tank Car Facility - Executive Summary
ACCIDENTAL RELEASE PREVENTION PROGRAM |
RISK MANAGEMENT PLAN
GENERAL AMERICAN TRANSPORTATION CORPORATION
WAYCROSS, GEORGIA TANK CAR MAINTENANCE FACILITY
COVERED PROCESS: RAIL CAR CLEANING
GATC operates a railroad tank car service center in Waycross, Georgia. The facility is subject to Program 3 requirements. Facility operations include painting and sandblasting, railcar interior cleaning, an organic scrubber system, an ammonia flare for venting cars containing ammonia, and a flare for venting flammable gases. Before a tank car is cleaned, any remaining contents in the car must be removed. These processes, specifically the venting operations, involve the use of the following regulated toxic substances in excess of the threshold quantity:
7 Ammonia 7 1,3 Butadiene 7 Chlorine
7 Butane 7 Butene 7 Isopentane
7 1 Butene 7 2 Butene 7 2 Methyl 1 butene
7 2 Butene cis 7 2 Butene trans 7 3 Methyl 1 butene
7 Isobutane 7 Isoprene 7 2 Methylproprene
ne 7 Propylene 7 Nitric Acid
7 Hydrochloric Acid 7 Pentane 7 1 Pentene
7 1,3 Pentadiene 7 2 Pentene (E) 7 2Pentene (Z)
7 Dimethylamine 7 Ethlyamine 7 Oleum
7 Methylamine 7 Trimethylamine
GATC also transports in its railcar fleet other commodities which it does not process, has never processed, and does not intend to begin processing, at the facility, but which are included on the regulated toxic substances list for accidental release prevention. GATC has established administrative controls to prevent these commodities from arriving at the facility. Nonetheless, the regulation still requires preparation of worst case and alternate release scenarios for these commodities. Based upon engineering judgement and process knowledge, the alternate release scenarios for these substances were assumed equal to the worst-case release scenario. These substances are as follows:
7 Bromine 7 Carbon Disulfide 7 Chloroform
7 Ethyl Chloride 7 Allyl Alcohol 7 Formaldehyde
7 Ethylene Oxide 7 Methyl M
ercaptan 7 Methyltrichlorosilane
7 Hydrazine 7 Hydrogen Sulfide 7 Methyl Chloride
7 Methyl Isocyanate 7 Sulfur Dioxide 7 Titanium Tetrachloride
7 Phosphorus Trichloride 7 Toluene Diisocyanate 7 Trichlorosilane
7 Vinylidene Chloride 7 Hydrogen Chloride (Anhydrous)
7 Hydrogen Fluoride
(conc. 50% greater)
Finally, there is an additional third category of substances which GATC processes, but only if the railcar contains less than the regulated threshold quantity (TQ). GATC has established administrative controls to prevent cars from arriving at the Facility carrying the following commodities in excess of the TQ:
7 Acetaldehyde 7 Methyl Ether 7 Propylene Oxide
7 Vinyl Acetate Monomer 7 Vinyl Chloride 7 Ethyl Ether
7 Acrylonitrile 7 Epichlorohydrin 7 Ethylenediamine
It is noted that GATC has applied for a Title V Operating Permit, but the permit number had not been issued as of this writing.
RELEASE PREVENTION AND EMERGENCY RESPONSE POLICY
GATC is committed to managing and operat
ing the facility in accordance with relevant regulations and good operating practices. These operating practices strive to minimize the risk of an accidental release of a regulated substance from the rail car cleaning process. If an accidental release were to occur, GATC has response measures in place to minimize the release impact.
WORST-CASE RELEASE SCENARIO ANALYSIS
The worst-case release scenario incorporated the following:
7 At the time of this writing, GATC used the latest available version of USEPA's RMP*Comp software to estimate distances to the toxic and flammable (1 psi overpressure due to an explosion) endpoints for the 59 substances listed above.
7 For the worst-case release, GATC analyzed 59 regulated substances. This release consisted of the largest quantity of a given substance released from the largest class of railcar that could potentially carry a given substance. For example, in cases where several different size railcars could transport a given substance,
the release was assumed to occur from the largest single railcar that could transport that substance. Passive mitigation measures were not included in the worst-case analysis since passive mitigation measures are not utilized at the Waycross facility.
The RMP*SUBMIT program presents one worst-case toxic release and one worst-case flammable release. The toxic substance presented in RMP*SUBMIT is anhydrous hydrogen fluoride. USEPA's RMP*Comp model was used to determine the distance to the anhydrous hydrogen fluoride toxic endpoint of 0.016 mg/L. The flammable substance presented in RMP*SUBMIT is pentane. USEPA's RMP*Comp model was used to determine the distance to the pentane flammable endpoint of 1 psi overpressure. The toxic and flammable endpoints do go offsite. These substances were presented in RMP*SUBMIT since the distance to their respective toxic and flammable endpoints is greatest.
Rail cars are inspected by GATC personnel for potential leaks and the rail car's struct
ural and operational integrity are assessed before the cleaning process begins. A rail car can only be cleaned if it enters the facility with a very small quantity of a regulated substance since the facility is not equipped to handle large quantities of regulated substances. Rail cars that arrive at the facility with large quantities of a regulated substance are returned to the customer.
ALTERNATIVE RELEASE SCENARIO ANALYSIS
The alternate release scenario incorporated the following:
7 At the time of this writing, GATC used the latest available version of USEPA's RMP*Comp software to estimate distances to the toxic and flammable (1 psi overpressure due to an explosion) endpoints for all of the toxic substances and one flammable substance that GATC processes.
7 For the alternate release, six substances were analyzed. These substances are anhydrous ammonia, chlorine, nitric acid, hydrochloric acid, oleum and pentane. The alternate release scenario for all other regulated substanc
es was assumed equivalent to the respective worst-case release scenario.
Anhydrous Ammonia Alternate Release Scenario
The anhydrous ammonia release is a 15-minute duration release, from a ruptured hose connected to the flare. No mitigation measures are in place.
Chlorine Alternate Release Scenario
The chlorine release is a 15-minute duration release, from a ruptured hose during railcar unloading. No mitigation measures are in place.
Nitric Acid Alternate Release Scenario
The nitric acid release is a hose rupture during railcar unloading, thereby forming a pool. The hose is connected to a valve on the bottom of the railcar. The nitric acid pool evaporates into the atmosphere. The hose rupture diameter is assumed to be 2-inches. The release duration is 10 minutes. Release mitigation involves closing a hand valve upstream of the chemical pump and the tank car outlet valve. Closing both of these valves within 5 minutes introduces a 50 percent spill mitigation control factor.
Hydrochloric Acid Alternate Release Scenario
The hydrochloric acid release is a hose rupture during railcar unloading, thereby forming a pool. The hose is connected to a valve on the bottom of the railcar. The pool of hydrochloric acid evaporates into the atmosphere. The hose rupture diameter is assumed to be 2 inches. The release duration is 10 minutes. Release mitigation involves closing a hand valve upstream of the chemical pump and the tank car outlet valve. Closing both of these valves within 5 minutes introduces a 50 percent spill mitigation control factor.
Oleum Alternate Release Scenario
The oleum release is a hose rupture during railcar unloading, thereby forming a pool. The hose is connected to a valve on the bottom of the railcar. The pool of oleum evaporates into the atmosphere. The hose rupture diameter is assumed to be 2 inches. The release duration is 10 minutes. Release mitigation involves closing a hand valve upstream of the chemical pump and the tank ca
r outlet valve. Closing both of these valves within 5 minutes introduces a 50 percent spill mitigation control factor.
Pentane Alternate Release Scenario
A likely alternate scenario is that the hose connected to the flare ruptures and the remaining pentane vapor escapes through the rupture. The release duration is assumed to be 5 minutes. No mitigation measures are in place.
The toxic and flammable endpoints do go offsite for the alternate release scenarios. Active mitigation measures were considered, where applicable.
RELEASE PREVENTION PROGRAM
In December 1995, GATC performed a hazard and operability (HAZOP) process hazard analysis (PHA) in order to identify potential hazards at the facility. GATC has several process controls in use such as relief valves, check valves, flares, manual and automatic shutoffs and alarms, and procedures in the event of a release. Additionally, a hose inspection and replacement policy is in place to further minimize the likelihood of a releas
GATC has developed a set of operating procedures contained in the GATC Car Cleaning Procedures Manual. The Manual documents procedures for acceptance, inspection and sampling of incoming railcars, and provides the documentation for operating the rail car cleaning system. These procedures are reviewed on an annual basis to maintain current and accurate instructions.
GATC has procedures in place to conform to requirements established by the Process Safety Management rule. Process Safety Management (PSM) is a system through which the company can manage hazards associated with processes involving highly hazardous chemicals (HHC's). Employers that produce, use, store, transport, or handle these HHC's in amounts equal to or greater than the specified quantities fall under the PSM standard. The GATC employee participation in this process is essential to a quality effort in eliminating potential workplace hazards and incidents.
GATC has developed a training plan to attempt to ensu
re that employees are knowledgeable in facility operations and to reduce the risk of accidents both during normal operations and emergencies. The procedures currently in place are designed to satisfy the requirements of 29 C.F.R. 1910.119 and OSHA PSM regulations. They will also satisfy the requirements of the Risk Management Plan (RMP) regulations.
Written procedures are in place to maintain the mechanical integrity of the process equipment. This includes preventive maintenance and inspection procedures, the frequency of such procedures, inspection responsibility, and guidance documents for these procedures.
GATC has a Management of Change procedure in place. GATC has implemented this procedure to help ensure that changes are properly reviewed and that hazards introduced by the implementation of change are identified and controlled prior to placing the change in operation.
GATC has implemented a pre-startup safety review to help ensure that certain important considerations ha
ve been addressed. This helps ensure that adequate safety measures are in place and are operational and that other aspects of the PSM/RMP program are updated and implemented as needed. This procedure, in conjunction with other PSM/RMP program elements, is intended to satisfy the requirements of 29 CFR 1910.119 and 40 CFR 68.
Compliance audits are a crucial component of the RMP program and will provide management with information on the success of the program and on areas that need improvement. Audits are conducted annually by the RMP Program to ensure that the procedures and practices developed under the RMP standards are followed.
The RMP regulation requires facilities experiencing an incident involving a covered process to follow prescribed incident investigation procedures. The purpose of the RMP incident investigation requirement is to ensure that incidents involving regulated toxic substances are investigated; that recommendations for preventing a reoccurrence are identified
and implemented; and, that appropriate personnel are briefed on the causes of the incident.
GATC has instituted an employee participation plan in the PSM/RMP development for regulated hazardous processes. The management has implemented this plan in an effort to ensure that employees potentially affected by process operations have knowledge of and access to information relative to the process. This procedure is intended to outline the employee's participation/responsibilities within the scope of GATC's PSM/RMP program, and to satisfy the requirements of 29 CFR 1910.119 and 40 CFR 68.
GATC has implemented a Contractor Safety Policy to insure that contractors comply with the Occupational Safety and Health requirements and implement an effective industrial safety program for work at the GATC facilities.
FIVE-YEAR ACCIDENT HISTORY
There have been no known accidental releases from covered processes at GATC's Waycross facility which resulted in deaths, injuries, or significant property
damage on-site, or known off-site deaths, injures, evacuations, sheltering in place, property damage, or environmental damage.
EMERGENCY RESPONSE PROGRAM
GATC has developed an emergency response program that contains:
1) Procedures for informing the public and local emergency response agencies about an accidental release;
2) Procedures that document first-aid and emergency medical treatment to treat human exposures;
3) Procedures and measures for emergency response after an accidental release of a regulated substance;
4) Procedures for the use of emergency response equipment and for its inspection, testing and maintenance;
5) Training for employees in relevant procedures; and
6) Procedures to review and update the emergency response plan.
CHANGES TO IMPROVE SAFETY
GATC has developed operating procedures contained in the GATC Car Cleaning Procedures Manual. The Manual documents procedures for acceptance, inspection and sampling of incoming railcars, and provides the documen
tation for operation of the rail car cleaning system. These procedures are reviewed on an annual basis to maintain current and accurate instructions. GATC has developed a training plan to attempt to ensure that employees are knowledgeable in facility operations and to reduce the risk of accidents both during normal operations and emergencies. Up to date and accurate instruction and continued employee training procedures will aid in future facility safety.