Global Petroleum Corporation - Executive Summary |
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This Risk Management Plan (RMP) has been prepared for Global Petroleum Corporation's (Global) Revere, Massachusetts bulk petroleum terminal. This Plan has been developed in accordance with Title 40 of the Code of Federal Regulations, Part 68, "Chemical Accident Prevention Provisions". The purpose of these provisions and this RMP is to prevent accidental releases of toxic and flammable substances that can cause harm to the public and to the environment. This RMP has been developed by Triton Environmental, Inc. on behalf of Global specifically to prevent and mitigate accidental releases associated with butane storage (temporary storage) and handling operations at the Revere facility. The RMP provides a summary of the risk management program implemented at the Terminal and was developed following the Environmental Protection Agency's "Risk Management Program Guidance for Propane Storage Facilities (40 CFR 68)". The RMP is available to government agencies and the p ublic for review. This Plan has been designed to serve as a "stand alone" document, as well as, to be part of the Terminal's Integrated Contingency Plan (ICP). The following items provide an overview of Global's RMP, in accordance with 40 CFR 68.155. Stationary Source and Regulated Substances Source: Temporary Storage (Railcars): 30,000 gallons (144,738 pounds) / railcar Railcars On-site: typically two (2) railcars Permanent Storage Tank: 100 gallons (482 pounds) Regulated Substance: Butane Release Scenarios Worst Case Release Scenario A Worst Case Release would occur if the entire contents of a full butane railcar were released instantaneously, and this vapor cloud subsequently exploded. A typical railcar stores a maximum of 30,000 gallons of b utane (144,738 pounds). Using the EPA program RMP*Comp, it was determined that the distance to endpoint for this worst case release would be 0.4 miles, which extends off-site and includes public receptors. The calculation is based on 1.0 PSI overpressure. Alternate Release Scenarios Scenario one involves the rupture of the D-200 tank, which is a high pressure tank that holds a quantity of butane to assist the off-loading process. An automatic level controller limits the volume of butane stored in this tank to 100 gallons (482 pounds). Using RMP*Comp, the distance to endpoint for this release would be 0.06 miles (317 feet). The endpoint is the 1.0 PSI overpressure distance resulting from a vapor cloud explosion. This distance extends beyound the boundaries of the property. Scenario two would occur if one of the hoses that are used to off-load the butane were to catastrophically fail. In this release, only the liquid presently in the hose would be released, because there are check valves in Global's hard piping, and the railcars are equipped with excess flow valves and "Snappy Joe" ESD valves, which will halt the flow in the event of hose failure. The hoses and fixed piping are each two (2) inches in diameter. Based on the length of piping, it was estimated that the total volume of butane within the piping would be about 5 gallons. To be conservative, a volume of 10 gallons (48 pounds) was assumed. Using RMP*Comp, the distance to enpoint for this release was determined to be 0.03 miles (158 feet). The enpoint is the 1.0 PSI overpressure distance resulting from a vapor clound explosion. This distance extends beyond the boundaries of the property. Administrative Controls and Mitigation Measures to Limit Distance Global has implemented a prevention program (RMP Program 2) to administratively limit the potential for a worst case or alternative release. No passive measures, howe ver, were taken to minimize the impacts of these releases. Specific measures employed in this program include safety reviews, hazard reviews, operating procedure reviews, training and maintenance and inspection. These reviews are generally conducted once (1) every three (3) years in association with Global's Compliance Audit (40 CFR 68.58) or with major changes. The hazard review is required every five (5) years or with major changes. Maintenance and inspection is conducted annually. These procedures are outlined in Global's RMP maintained at the facility. The results of the most recent reviews are also maintained at the facility. In addition, Global has initiated its Emergency Response Program with local agencies. The fire department and police department maintain copies of the facility Emergency Plan. Appropriate contacts are also in place with emergency response contractors, if necessary (see Emergency Response Program below). Mitigation Measures No passive or active mitigation measures were taken to reduce the extent of a worst case release scenario or alternate release scenario number one. Several active measures were taken to reduce the impact of alternative release scenario number two, including check valves, excess flow valves and emergency shut-off valves. General Accidental Prevention Program and Chemical Specific Prevention Items Global has implemented a Program 2 RMP to prevent the release of flammable substances that can cause harm to the public and the environment. Program 2, in general, consists of the following: - Safety Information (Sect. 68.48) - Hazard Review (Sect. 68.50) - Operating Procedures (Sect. 68.52) - Training (Sect. 68.54) - Maintenance (Sect. 68.56) - Compliance Audits (Sect. 68.58) - Incident Investigation (Sect. 68.60) - Emergency Response Program (Sect. 68.90) This Program 2 RMP has been implemented at the facility and Global maintains a copy available for review on-site. Five Year Accident History There have been no releases of butane at Global in the five (5) years preceding implementation of this RMP. Emergency Response Program Global has developed strong working relationships with local emergency response orgaizations. In addition, Global has developed an Emergency Plan, which provides guidance for progressively managing emergency episodes, such as spills, fires, explosions and other sudden/unplanned events. In accordance with 40 CFR 68.90 (b)(2) and (b)(3), Global has coordinated repsonse actions associated with butane storage (temporary storage) and handling with the local fire department. The facility's ICP and Emergency Plan provide guidance mechanisms for notification of emergency responders. Copies of the Eme rgency Plan are maintained at the facility for use in an emergency incident, and have been forwarded to the local fire department, the locate police department and area hospitals. As such, development of a new and separate emergency response program is not required in accordance 40 CFR 68.95 since an emergency response program already exists. Safety Improvements The following list provides a summary of items implemented at Global in association with this Plan that are designed to improve safety. - Safety Review (Audit every 3 years) - Hazard Review (Audit every 3 years, update every 5 years) - Operating Procedures Review (Audit every 3 years) - Training (Audit every 3 years, training once every 3 years (minimum)) - Maintenance and Inspection (conducted annually, audit every 3 years) - Emergency Response Program (coordination with local agencies (fire department), development of an Emergency Plan) |