Odfjell Terminals (Baytank) Inc. - Executive Summary |
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Executive Summary Odfjell Terminals (Baytank) Inc. ; 12211 Port Road ; Seabrook, Texas 77586 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At Odfjell Terminals (Baytank) Inc. we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: A description of our facility and the storage and transfer of substances regulated by EPA's RMP regulation A summary of results from our assessment of the potential offsite consequences from accidental chemical releases An overview of our accidental release prevention programs A five-year accident history for a ccidental releases of chemicals regulated by EPA's RMP rule An overview of our emergency response program An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment STATIONARY SOURCE AND REGULATED SUBSTANCES Our public marine terminal stores and transfers a variety of chemicals. The facility stores the chemicals in pressurized tanks and transfers them to and from various transportation modes including tank truck, rail car, barges and ships. The processes are storage and transfer only. The storage and transfer is actually three processes: Toxic and other flammable Storage and Transfer Propylene Storage and Transfer Acetaldehyde Storage and Transfer The systems and procedures for storage and transfer of propylene and acetaldehyde are specific to those chemicals and therefore are identified as separate processes. The systems for storage and transfer of other flammables and all toxics are the same basic design and use the same procedures. We have identified the following toxic chemicals that have the potential to cause offsite consequences in the event of a substantial accidental release: acrylonitrile, epichlorohydrin, chloroform, allyl alcohol, cyclohexylamine, ethylenediamime, nitric acid (80 %), propylene oxide, toluene diisocyanate (2,4) and vinyl acetate monomer. Not all of these chemicals are currently stored at our facility. We have identified the following flammable chemicals that have the potential to cause offsite consequences in the event of a substantial accidental release: propylene , acetaldehyde, isoprene, 1-pentene, and isopropylamine. Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment in the storage and transfer of these chemicals KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RM P rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the systems to limit the exposure distances for each scenario: Worst-case Release Scenario (WCS) Regulated Toxics The WCS for toxics is the rupture of a storage tank of acrylonitrile. The release is contained by a concrete dike limiting the evaporation pool surface area. The cloud of evaporating acrylonitrile would reach offsite endpoints and nearby public receptors including residents, schools, parks, a hospital, and industrial neighbors. Alternative Release Scenarios (ARSs) Regulated Toxic Chemicals Baytank identified ten ARSs for the regulated toxics. Each scenario was the overflow on a storage resulting in a pool. The pool surface area is limited by concrete dikes containing the release, and a foam blanket would be applied within 30 minutes of the rele ase. The cloud of evaporating toxic substances would reach offsite endpoints and nearby public receptors including residents and industrial neighbors. Worst-case Release Scenario Regulated Flammable Chemicals The WCS for flammables is the rupture of a sphere containing acetaldehyde resulting in a vapor cloud explosion as defined in the RMP Rule. The blast effects could reach offsite endpoints and nearby receptors including a school, residences and industrial neighbors. Alternative Release Scenario(s) (ARSs) Regulated Flammable Chemicals Baytank identified the ARS for the regulated flammables as the overflow on a propylene sphere resulting in a vapor cloud fire. The pool surface area is limited by concrete dikes containing the release. This sphere has a deluge system, and foam blanketing was assumed to be applied within 30 minutes of the release. This ARS event has the potential to reach an offsite endpoint, but only neighboring industrial facilities might be affected. GE NERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs including: Process safety information, process hazard analysis, operating procedures, training, mechanical integrity, management of change, pre-startup review, compliance audits, incident investigation, employee participation, hot work permit procedure and contractor safety. As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: 1. All tanks are pressurized with two levels of pressure relief with the first relieving to an abatement device at 80% of design pressure; 2. Temperature, pressure and level instrumentation including alarms. ; 3. All key parameters are monitored in a central control room; 4. All operations and maintenance employees are trained to the te chnician level of HAZWHOPER; 5. Systems are pressure tested before chemicals are introduced; 6. Systems integrity is checked before and during each transfer ; and 7. Systems integrity is checked at frequent intervals during static conditions both by sight, sound and smell and an analyzer. In addition the Propylene and Acetaldehyde Storage and transfer systems have: 1. Spheres designed and built to the ASME Code; 2. Automatic Shutdown; 3. Area leak detectors; and 4. All components are dedicated to propylene and acetaldehyde service. These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. FIVE-YEAR ACCIDENT HISTORY We keep records for all significant accidental chemical release s that occur at our facility. There have been two accidents as a result of chemical releases. Both accidents were chemical exposures in 1995 resulting in restricted duty for less than a week. For each of these incidents, we have conducted formal incident investigations to identify and correct the root causes of the events. EMERGENCY RESPONSE PROGRAM We maintain an emergency response and contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan and we are members of the local Mutual Aid Association. Elements of our emergency response plan that reduce the impact on the defined receptors are: Community alert system, foam blanketing to reduce evaporation, deluge systems for spheres, 6000 gpm pressurized fire water system, trained responders and frequent drills. PLANNED CHANGES TO IMPROVE SAFETY The following is a list of improvements that we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases: 1. Further development of the control room function including built-in interlocked (permissive) logic and integrated alarms, 2. Automatic valve closing in transfer process to prevent overfill, 3. Installation of automatic scales and more sophisticated meters to prevent contamination and overfills, 4. Implement a document management system that will allow operators to display procedures on control room displays, and 5. Development of a more rigorous management system for tracking equipment status as it moves from operations to maintenance and back (turnover procedures). |