ST Services- Jacksonville Terminal - Executive Summary

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EXECUTIVE SUMMARY 
 
ST Services is committed to the safety of our employees and the surrounding community. It is ST Services policy to comply with all federal, state, and local laws as well as accepted industry practice for the storage and handling of butane and other liquified petroleum gases. An integral part of our compliance and safety program is employee training. Employees are trained in the safe handling of all products stored at the facility, including butane, and are trained in appropriate emergency actions required in response to a potential release. 
 
Employee training includes participation in internal response drills with government agencies, including the Local Emergency Planning Committee (LEPC), U.S. Coast Guard, and the Fire Department. Employees are trained and must demonstrate an understanding of the required tasks before being allowed to supervise the unloading of butane railcars. 
 
ST Services Jacksonville facility is a "for hire" bulk liquid terminal. The facility ha 
ndles butane as a service for a customer. The butane is delivered to the terminal in railcars. At our customer direction, the butane is blended into gasoline stored in tanks at the facility. Once the desired gasoline formulation is achieved, the gasoline is shipped out of the facility by truck. Butane may be "stored" at the facility in railcars for a limited amount of time depending on our customers demand for the product. Four railcars, containing as much as 606,600 pounds of butane, may be stored on the facility rail siding at one time. The terminal does not currently operate any permanent butane storage. 
 
The butane handling facility has been designed to meet the requirements of standards set forth in NFPA 58 and is operated in compliance with the OSHA standard for the storage and handling of Liquified Petroleum Gases (29CFR1910.110). The facility has also implemented a Process Safety Management Program (PSM) in compliance with the requirements of OSHA 29 CFR1910.119. The PSM progra 
m requires routine training of personnel, scheduled inspections and maintenance of process equipment, safety audits and hazard analysis, detailed written operating procedures, and development of an Emergency Action Plan (EAP). These requirements, and the safety requirements of the referenced standards, provide for the continued safe operation of the facility. 
 
In addition to the PSM program developed according to OSHA, ST Services has developed a Risk Management Plan (RMP) as required by the U.S. Environmental Protection Agency (EPA) at 40 CFR Part 68. This program has many of the same elements of the PSM program, with additional requirements to address off-site consequences of a catastrophic failure of the butane system. As required by this program, ST Services has developed a worst case release scenario (WRS). The scenario modeled involved the sudden release and ignition of the entire contents of a railcar. Though an unlikely occurrence, EPA has chosen this scenario to predict the ma 
ximum amount of damage that could be caused by a catastrophic failure of the system. 
 
The WRS involves the explosion of a vapor cloud resulting from the sudden and catastrophic failure of a full railcar. The modeling of this scenario is predicted to have offsite impacts to a distance of 0.43 miles. The alternative release scenario, using the same size release but a different EPA-approved model, results in offsite consequences to a reduced distance of 0.19 miles. These models do not provide any consideration for preventative or protective measures in place at the facility. 
 
In addition to the prevention programs described above, the facility has a release monitoring system to detect flammable vapors near the butane rail siding and the vapor combustor. This system will shut down the vapor combustor to prevent the ignition of vapors resulting from a spill or release. The butane unloading system is equipped with a detection and deluge system, an emergency stop system, and excess flow valve 
s which prevent the uncontrolled release of butane liquids or vapors during unloading. 
 
ST Services has an established relationship with the Jacksonville Fire Department and Local Emergency Planning Committee. The facility cooperates with the emergency organization and has participated in drills as requested. 
 
There have not been any accidental releases of butane at the facility in the past five years. 
 
Access to the facility is controlled by security fences and an automated entry security system. Only qualified contractors (including trained truck drivers and maintenance contractors) and employees are permitted to enter the operating areas of the facility. 
 
The Process Safety Management Program and Risk Management Program provide a framework for continual review and improvement of the butane system operations. Routine internal audits, safety committee meetings, and audits by third party experts, provide for continued safe operations. Identified hazards are reviewed and recommendations 
developed and implemented to assure operational integrity.
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