John Zink Apache Facility - Executive Summary
JOHN ZINK COMPANY |
THE RISK MANAGEMENT PLAN (RMPlan)
Introduction and Policies
Under the Koch Environmental Excellence Program (KEEP) at Koch Industries, Inc., we are committed to being associated with unmatched environmental performance as measured by our employees, customers, regulators, and the public. Our KEEP management philosophy goals are achieved by the personal commitments of our employees and contractors, and by open communication with our employees, customers, neighbors, and with regulators. The accidental release prevention and emergency response programs we have at our facilities are part of the high standards we strive for through KEEP. Our high standards are achieved by operating in compliance with all required environmental permits and regulations, by operating and maintaining our assets in such a manner that any unpermitted release will be unintentional and acknowledged as unacceptable, by remedying any short
comings found during regular audits of our facilities, and by reporting promptly to regulators any shortcomings found during the course of our audits as required by law.
The John Zink Company, Apache Facility is a research and development center operated by Koch Glitsch Engineering Company, Inc. (Koch). The facility tests flares and burners using custom blended fuels specified by the customer. Propane, butane and propylene are the flammable substances regulated under the Risk Management Program (RMP) that are present at the Apache Facility in amounts above threshold quantity. There are no RMP-regulated toxic substances at this facility. The facility is classified as Program Level 2 under the regulation. At the facility, the propane, butane, and propylene are received via tanker trucks and stored in pressure vessels until needed for test procedures. The purpose of this Risk Management Plan (RMPlan) is to provide information about our operations at the facility, our programs to prev
ent accidental chemical releases, our emergency response plans in case an accidental release should occur, our 5 year accident history, and our planned changes to improve safety at the facility.
Worst Case and Alternative Release Scenarios
As specified by the U. S. Environmental Protection Agency (EPA) RMP Regulations, our worst case release scenario for flammables would be the loss of all of the propane in our largest vessel causing a vapor cloud explosion. In the case of the John Zink Apache Facility, this would involve our 12,000 gallon propane bullet. Such a scenario is highly unlikely, however, using the EPA Offsite Consequence Analysis (OCA) methods, the distance that the resulting vapor cloud explosion could cause an overpressure of 1 psi would be approximately 0.3 miles. An overpressure of 1 psi is EPA's threshold for measurable impacts. Although we have controls to prevent such releases (such as emergency shutdown) and to manage their consequences, no credit for any con
trols or mitigation measures was taken into account when evaluating this scenario. The alternative release scenario, characterized as a more likely scenario that would involve offsite consequences, is calculated to reach approximately 0.2 miles (approximately 1,050 feet) from the release point. This distance calculation is also based on the EPA OCA methods which are known to overpredict the impact of any potential release from such a scenario. No credit for any controls or mitigation measures was taken into account when evaluating this scenario. We selected the alternative release scenario based on a release of butane due to an overfill of the bullet and the relief valve on the bullet becoming stuck open. We have several mitigation measures in place to greatly reduce the chance that such an event could ever occur. These mitigation measures include level gauges on all tanks to prevent the chance of an overfill. Also, a John Zink employee authorizes and supervises the filling of t
he tank. This employee and the truck driver stay with the loading operation until it is complete. This system also reduces the chance that an overfill could occur and minimizes the impact if it does occur.
We have discussed these potential releases with our employees and with local emergency response officials in Tulsa County, thereby further reducing the possibility of any impact on the public.
The John Zink Apache Facility has just begun operating under the strict guidelines of the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) Program. The analysis of the potential hazards of our process, detailed training of our employees, and emphasis on safety that is needed to comply with the PSM Program will help us avoid any serious accidents in the future. Part of this program has also involved identifying and taking steps to avoid potential accidental chemical releases. A few examples of the additional prevention features impl
emented at this facility include:
7 Emergency shutdown devices are located throughout the facility in order to shutdown the entire facility during emergency situations.
7 Fire hydrants are available for the fire department, which is located approximately one mile from the facility, to cool the tanks in the event of a fire.
7 Visual level gauges are provided on all tanks to prevent overfills.
7 Surveillance cameras were installed in the test center and positioned to monitor activities and detect fires.
These safeguards as well as the vigilance of our trained employees have helped us operate safely at this facility since we acquired it in 1990.
Five Year Accident History
No incident having resulting in onsite or offsite impacts from a release of an RMP substance has occurred at the John Zink Apache Facility within the last five years. Although we take pride in that record, we also place daily emphasis on our prevention and safety programs to ensure this record continues.
Emergency Response Program
Any emergency response necessary for the John Zink Apache Facility is coordinated with the City of Tulsa Fire Department, the City of Tulsa Police Department, the Tulsa HazMat Team, and the Tulsa Area Emergency Management Agency. The John Zink Apache Facility Director of Operations is responsible for coordinating all emergency actions. A specific Emergency Response Plan for the facility is in place and that plan has been coordinated with local officials, along with evacuation procedures, regular drilling, and training. Our Emergency Response Program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations.
Planned Changes to Improve Safety
Diligent compliance with our RMP Prevention Program forms the framework on which we will continue to improve the level of safety at the John Zink Apache Facility. Some of the key components of the safety improvements we expe
ct to achieve are as follows:
7 A deluge system at the tanks is in the planning stage to reduce the impact of a fire near those tanks and to prevent a BLEVE.
7 The Management of Change provisions ensure that we consider the potential safety and health impacts of any change we make to process chemicals, technology, equipment or procedures.
7 The Process Hazard Analysis (PHA) provisions serve as a tool to ensure continual evaluation of potential hazards, thereby leading to continual improvements in our safety standards.
7 The Mechanical Integrity provisions ensure that process equipment and instrumentation are designed, constructed, installed and maintained to minimize the risk of hazardous releases, thereby serving as an integral part of our safety program.
7 Internal and third party compliance audits will ensure we maintain and increase our level of safety protection.
7 An ongoing dialogue with the Tulsa Area Emergency Management Director or his designate will ensure a constant state
of readiness to respond to any potential emergencies, as well as a means to implement improvements as the need develops. In this way, we shall bolster our strong commitment to the safety of our workers and the community.
We encourage all interested citizens or community organizations to contact the Tulsa Area Emergency Management Director for the latest information on emergency response for the county. We plan to diligently integrate our response capabilities and personnel with those of the county on an ongoing basis.