Origin Station - Executive Summary |
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Coastal States Crude Gathering Company Origin Station RMP Executive Summary 1. Accidental Release Prevention and Emergency Response Policies We at Coastal States Crude Gathering Company's Origin Station are strongly 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 trained emergency response personnel will be available to control and mitigate the effects of the release. We have also coordinated with the Corpus Christi Fire Department to provide additional emergency response expertise. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass a Petroleum Storage and Pipeline Pump Station. We have eight regulated substances present at our facility. These substances include Methane, Ethane, Propane, Propylene [1-Propene], Isobutane [Propane, 2-methyl], Butane, Isopentane [Butane, 2-methyl-], and Pentane. The regulated substances at our facility are components of the Propane, Propylene, Butane, Liquified Petroleum Gases (LPG), and Gasoline products stored and transported by pipeline. The maximum inventory of regulated substances at our facility is: Methane 3,800 lb Ethane 22,000 lb Propane 1,400,000 lb Propylene [1-Propene] 310,000 lb Isobutane [Propane, 2-methyl] 230,000 lb Butane 510,000 lb Isopentane [Butane, 2-methyl-] 250,000 lb Pentane 220,000 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 conduct the required offsite consequen ce analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 flammable substances involves a catastrophic release from the Station Operations. In this scenario, 339,095 lb of a flammable mixture containing Isobutane [Propane, 2-methyl], Butane, Isopentane [Butane, 2-methyl], and Pentane, is released. The release quantity has been limited to 85% of the maximum capacity of the source by a system of administrative controls. 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 calculated distance of 0.56 miles is obtained corresponding to an endpoint of 1 psi overpressure. The alternative release scenario submitted for Program 2 flammable substances involves a rele ase from the Station Operations, which is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 1,507.00 lb. of Propane in 0.5 minute. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.06 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 Risk Management Program regulations (40 CFR part 68). The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Safety Information Origin Station maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Hazard Review Origin Station conducts comprehensive studies to ensure that hazards associated with our proce sses are identified and controlled efficiently. The methodology used to carry out these analyses is the "Checklist" method. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of at least once every five years. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was completed on June 18, 1999.. Operating Procedures For the purposes of safely conducting activities within our covered processes, Origin Station 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. Training Origin Station has a comprehensive 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. Maintenance Origin Station carries out highly documented maintenance checks to ensure the mechanical integrity of process equipment. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Compliance Audits Origin Station conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The mo st recent comliance audit was conducted on June 18,1999. 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. Incident Investigation Origin Station 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. 5. Five-year Accident History Origin Station 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 Origin Station maintains a written emergency response plan to deal with accidental releases of hazardous material s. The plan includes all aspects of emergency response, including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies 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 processes that would require a modified emergency response. 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. |