EGP Fuels Company, Mont Belvieu Storage Facitlity - Executive Summary

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RMP Executive Summary 
EGP Fuels Company 
Mont Belvieu Storage Facility 
EGP Fuels Company policy is to protect its employees, property, environment and the general public from any harm that may occur as a result of an emergency affecting this plant.  This plan complies with the policy of providing a safe work environment for all employees, contractors, visitors and neighbors.  It extends to the design, training and implementation of a comprehensive emergency management program that saves lives and reduces property damage in the unlikely event of an emergency. 
Prevention is the primary goal.  However if an emergency should ever occur, the immediate goal is to contain the emergency and its effects within facility boundaries, mitigate the incident as quickly as possible and prevent any threat to the general public and neighbors.  It is EGP Fuels Company policy to operate in an environmentally responsible manner consistent with environmental knowledge, policy and regulation that best serv 
es the needs of the employees, community and the company.  Life preservation is the prime consideration, so all procedures will be carried out in a manner to minimize risk to employees and emergency response personnel.  Rescue and medical activities have priority over all other actions.  
The EGP Fuels Company facility stores Ethane, Butylene, Butane, Iso-butane, Natural Gasoline and mixed hydrocarbons in underground storage wells.   
This facility has no substantial amount of any toxic materials that are covered by this regulation.  
Worst-Case Scenario 
A worst case scenario is designed to be a theoretical exercise which calculates the potential impact on the community based upon extreme conditions prescribed by the EPA.  The worst-case scenario involving a flammable stored in a salt dome is a 10-minute release through the largest diameter of the wellhead, followed by a vapor cloud explosion.  Weather conditions are assumed to be the least favorable possible, existing safety systems  
and procedures can not be considered, and trained emergency personnel are assumed to stand idly by.  These assumptions make the worst-case scenario highly unlikely.  The "endpoint" for an explosion is defined by the EPA as the point where overpressure has decreased to one pound per square inch.  At a one pound overpressure, you could experience being knocked down to the ground if caught outside.  Buildings could experience some minor damage such as broken windows.  Persons and buildings inside this "endpoint" distance would experience greater effects.  The worst case scenario for this facility involves the shearing of a 20" wellhead resulting in a 10-minute release of butane.  The butane vapor is assumed to form a vapor cloud, which then explodes.  The explosion would cause a one pound overpressure extending to offsite areas. 
Alternative Release Scenario 
Scenarios that are more realistic or alternative release scenarios were also developed to better model a real world event.  The alte 
rnative release scenarios allow a facility's safety systems to work and apply typical weather conditions.  These scenarios may be used by local government and industry to prepare emergency response plans.  The alternative release scenario for EGP Fuels Company is a 10-minute release of iso-Butane from a 1" pipe rupture followed by a flash fire.  The end point distance for a flash fire is defined as the point where the concentration of flammable material in the air is low enough not to ignite.  In this case, the endpoint distance  extends to offsite areas. 
EGP Fuels Company follows Department of Transportation and Texas Railroad Commission regulations that are appropriate to pipelines and underground storage facilities.  These regulations include DOT 195, Railroad Commission of Texas Statewide Rules and Railroad Commission of Texas Barbers Hill Special Field Rules.  In addition, EGP Fuels Company follows other health, safety and environmental regulations appropriate to a chemical stor 
age facility.  By Corporate policy, we operate safely and with concern for the environment.  We take this responsibility seriously.  The plant is designed following recognized design practices and procedures.  Detailed operating procedures and training assure that the facility will be operated safely during normal and emergency situations.  A sophisticated control system monitors the operation of the plant and if necessary an emergency shut down system will accomplish a safe and orderly shut down.  EGP Fuels Company has conducted process hazard analyses to determine the risks that exist in our process and opportunities to reduce those risks.  EGP Fuels Company uses modern maintenance practices, tools and systems to keep equipment operating reliably and detect repair needs in their early stages.  To improve equipment reliability, EGP Fuels Company conducts mechanical integrity inspections and failure analysis to determine the root cause of failures.  Qualified personnel who have been tr 
ained in plant maintenance procedures maintain the plant.  A Management of Change system controls changes to equipment and procedures. 
There have been no incidents at the facility that meet the EPA Risk Management Program (RMP) reporting requirements: 
The Emergency Planning and Response plan consists of four elements: prevention, preparedness, response and recovery.   
Prevention is supported by policies and procedures intended to assure the plant is operated in a safe manner.  Inspections and audits of practices assure that the policies and procedures are being followed.  Periodic reviews of the procedures and training serve to reinforce the importance of operating the plant in a safe manner. 
Preparedness includes development of emergency procedures, obtaining and installing emergency equipment and notification devices, development and training of a plant emergency response team, coordination with neighboring companies, local authorities and MAMB (Mutual Aid Mont Belvieu).  The p 
lant has a written Emergency Planning and Response Manual and a team trained to implement the plans contained in the manual.  The facility has a system of alarms, radios and telephones that can be used to communicate with employees neighboring facilities and local agencies.  Periodic drills are conducted for likely scenarios, and emergency pre-planning is conducted for many recognized emergency events.  A review is conducted following each drill to assess the effectiveness of these preparations.  
Response is conducted under the Incident Command System (ICS) as outlined in 29 CFR 1910.120.  There are ICS trained personnel on site at all times.  The Local Emergency Planning Committee (LEPC) and Mutual Aid Mont Belvieu (MAMB) are the points of contact for offsite agencies. 
Recovery procedures include incident investigation, damage assessment, clean-up and restoration.  In addition, a review of the emergency response is conducted to evaluate and improve the response plans for the future. 
We are constantly reviewing and revising existing procedures, developing new procedures, and researching methods to increase employee awareness.   
EGP Fuels Company has demonstrated a willingness to be involved with community programs, and to be a responsible good neighbor.  These practices are part of the management commitment.
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