Almeda Facility - Executive Summary
Coastal States Crude Gathering Company |
RMP Executive Summary
1. Accidental Release Prevention and Emergency Response Policies
We at Coastal States Crude Gathering Company's Almeda Facility are committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. However, if such a release does occur, our highly trained emergency response personnel will be available to control and mitigate the effects of the release. We have also coordinated with the Houston Fire Department Emergency Response Team to provide additional emergency response expertise.
2. The Stationary Source and the Regulated Substances Handled
Our facility's primary activ
ities encompass a Liquified Petroleum Gas (LPG) Fractionation Plant with LPG processing, storage, and transportation. We have five regulated substances present at our facility. These substances include Propane, Isobutane [Propane, 2-methyl], Butane, Isopentane [Butane, 2-methyl-] and Pentane. The regulated substances at our facility are components of the LPG feed to the plant, the fractionated product streams, and the gases stored in underground caverns.
The maximum inventory of each regulated substance at our facility is:
Propane 530,000,000 lb
Isobutane [Propane, 2-methyl] 460,000,000 lb
Butane 320,000,000 lb
Isopentane [Butane, 2-methyl-] 170,000,000 lb
Pentane 120,000,000 lb
3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario
To evaluate the worst case scenarios, we have used EPA's Offsite Consequence Analysis Guidance Reference Tab
les or Equations. For alternative release scenario analyses, we have employed the EPA's RMP Guidance for Propane Storage Facilities Reference Tables or Equations. The following paragraphs provide details of the chosen scenarios.
The worst case release scenarios submitted for Program 3 flammable substances involve catastrophic releases from two different storage wells in the Almeda Facilities process. These two release scenarios have the potential to affect different land areas and different public receptors.
The worst case release scenario involves the release of 2,150,000 lb of Isobutane [Propane, 2-methyl]. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the maximum distance of 1.04 miles is obtained corresponding to an endpoint of 1 psi overpressure.
An additional worst case release scenario involves the releas
e of 1,750,000 lb of Propane. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the maximum distance of 0.97 miles is obtained corresponding to an endpoint of 1 psi overpressure.
The alternative release scenario submitted for Program 3 flammable substances involves a release from the Almeda Facilities process, which is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 7,182 lb of Propane in 10 minutes. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 PSI overpressure is 0.10 miles.
4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under EPA's RMP regulations (40 CFR Part 68). The Almeda F
acilities process is also subject to OSHA's PSM (Process Safety Management) regulations (29 CFR 1910.119). The following sections briefly describe the elements of the release prevention program that is in place at our stationary source.
Process Safety Information
Coastal States Crude Gathering Company's Almeda Facility maintains a detailed record of safety information that describes the chemical hazards, operating parameters, and equipment designs associated with all processes.
Process Hazard Analysis
Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodologies used to carry out these analyses are Hazard and Operability Analysis (HAZOP) and What If. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at least once every five years. Any findings related to the hazard analysis are addressed in a timely mann
er. The most recent PHA/update was performed on December 11, 1995.
For the purposes of safely conducting activities within our covered processes, Coastal States Crude Gathering Company's Almeda Facility maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes.
The Almeda Facility has a training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least once every three years, and more frequently as needed.
The Almeda Facility carries out documented maintenance checks on process equipment to ensure proper operations.
Process equipment examined by these checks includes, among others; pressure vessels, storage wells, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with prior training in maintenance practices. Furthermore, these personnel are given specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. The most recent review/revision of maintenance procedures was performed on May 5, 1997.
Management of Change
Written procedures are in place at the Almeda Facility to manage changes in process chemicals, technology, equipment, and procedures. The most recent review/revision of management of change procedures was performed on March 15, 1996. Process operators, maintenance personnel, or any other employee whose job tasks are affected by a modification in process conditions, are promptly notified of
the modification. They are also given any training required to safely deal with the modification.
Pre-startup safety reviews related to new processes, and to modifications in established processes, are conducted as a regular practice the Almeda Facility. The most recent review was performed on September 22, 1998. These reviews are conducted to confirm that construction, equipment, operating, and maintenance procedures are suitable for safe startup prior to placing equipment into operation.
Coastal States Crude Gathering Company Almeda Facility conducts audits on a regular basis to determine whether the provisions set out under the PSM and RMP rules are being implemented. The most recent compliance audit was conducted was conducted on July 31, 1998. These audits are carried out at least once every three years, and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner.
tal States Crude Gathering Company promptly investigates any incident that has resulted in, or could reasonably result in, a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of five years.
The Almeda Facility approaches process safety management and accident prevention on a team basis. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the PSM and RMP rules, including information resulting from process hazard analyses.
On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a th
orough evaluation of safety performance of the contractor is carried out. Coastal States Crude Gathering Company's Almeda Facility has a strict policy of informing the contractors of known potential hazards related the contractor's work and the associated plant processes. Contractors are also informed of all the procedures for emergency response to an accidental release of a regulated substance.
5. Five-year Accident History
Coastal States Crude Gathering Company's Almeda Facility has had an excellent record of preventing accidental releases. Due to our stringent release prevention policies, there has been no accidental release during the last five year reporting period.
6. Emergency Response Plan
The Almeda Facility maintains a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response, including adequate first aid and medical treatment, evacuations, notification of local emergency response agencie
s and the public, as well as post-incident decontamination of affected areas.
To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our plant processes.
Our emergency plan has been coordinated and verified with the Houston LEPC is the Local Emergency Planning Committee.
7. Planned Changes to Improve Safety
The developments and findings that result from the implementation of the various elements of our accidental release prevention program are regularly evaluated to determine whether any changes could be made to improve safety at our facility. All of the changes that have been identified, to date, have been implemented.