Intercoastal Terminal, Incorporated - Executive Summary |
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Accidental Release Prevention and Emergency Response Policy Intercoastal Terminal, Incorporated is committed to the safety of their workers and the public. Personnel are trained in safe equipment operation to reduce the potential for accidental release of toxic materials and/or ignition of flammable substances. Plant personnel are advised to report all releases and unsafe conditions to the plant manager and/or company president immediately. As part of any emergency response action, appropriate Intercoastal personnel are trained to contact the Texas City Local Emergency Planning Committee (LEPC), Texas City Fire Department (currently the Texas City LEPC), contracted emergency response teams, company president, plant manager, and other pertinent emergency and/or regulatory agencies immediately. Intercoastal Terminal does not have the equipment and trained personnel necessary to be the sole responder to a catastrophic release. Emergency Response Program Personnel receive basic s afety training and are aware of emergency response procedures. Intercoastal emergency response activities are supported by contracts with emergency response professionals (currently Garner Environmental). Intercoastal currently stores and drums Toluene Diisocyanate (TDI) under contract with Bayer Corporation. Under this contract Bayer will respond on-site to help mitigate, neutralize, and clean up TDI releases. Intercoastal personnel respond directly to small releases of toxic chemicals. Intercoastal maintains a written emergency response plan that describes the responsibilities of plant personnel in the event of an accidental release or other emergency (e.g., fires, explosions, unsafe conditions, injuries). Intercoastal currently provides EPA Emergency Planning and Community Right-to-Know (EPCRA) Tier II reports to the Texas City - LEPC for substances evaluated under RMP regulations. Stationary Source and Regulated Substances Handled Intercoastal Terminal, Inc. owns and operates a bulk product terminal located in Texas City, Texas (Galveston, County). The terminal receives, stores, and ships petroleum and industrial chemical liquids for various clients. The facility is located in a highly industrialized area of Texas City surrounded by both petroleum refineries and other bulk storage terminals. Materials are received and shipped through marine docks (typically by barge) and tank trucks. At the time of this report, typical operation is receipt of materials by tank truck or barge and transfer out by barge. Little material is shipped out by tank truck. Intercoastal stores the liquid materials in twelve above-ground atmospheric storage tanks. Common materials stored at the site include various grades of fuel oil, gasoline blend stock, and petroleum refinery fractions. In addition, Toluene Diisocyanate (TDI) is currently stored on-site. TDI is received by tank truck and unloaded into an atmospheric storage tank (currently Tank 11-11). The TDI is transferred from the tank and loaded into drums. The drums are placed into shipping containers which are shipped off-site. No other regulated toxic chemicals (above listed threshold quantities) are currently handled at the facility. Intercoastal receives, ships, and/or stores flammable petroleum mixtures such as naphtha. Worst-Case Release Scenarios and Alternative Release Scenarios Terminal processes (e.g., marine loading/unloading, truck loading/unloading, material storage, drum filling) are integrated and within close proximity of one another (facility total area is approximately 5 acres). The worst-case and alternative release scenarios were therefore based on the terminal being a single integrated process. The worst-case and alternative release analysis for toxic chemicals focuses on TDI unloading, storage, and drum filling operations. The toxic chemical worst-case scenario assumes that a storage tank is ruptured and the entire TDI content (Tank 11-11 capacity of 3 ,800,000 lb) is released in the tank farm area which is mitigated by earthen berm and concrete dike. The distance to the TDI toxic endpoint of 0.007 mg/l was estimated to be 0.31 miles off-property. The alternative release scenario for TDI is a drum spill (or overfill) that releases the entire drum content of 55 gallons resulting in a distance to toxic endpoint of 0.1 mile. The most flammable substances handled at the terminal - at the time of this report - are naphtha and petroleum refinery fraction type liquid mixtures that are used in gasoline blendstock (unfinished gasoline product that is blended on-site). The naphtha and blendstock can be stored in any of three internal floating roof (IFR) storage tanks. The worst-case scenario for flammable substances was assumed to be a vapor cloud explosion of the total content (11,000,000 lb) of all three IFR tanks simultaneously, resulting in a distance to over pressure end point of 1.9 miles. The alternate scenario was assumed to b e a liquid pool (6500 lbs naphtha released) fire that would produce harmful radiation (potential for 2nd degree burns) out to 405 feet from the fire's center. This scenario could be the result of a tank overfill, pipeline break or similar release that forms a pool that ignites. No flammable gases above threshold quantities are handled at the site at the time of this report. At the time of this report, the nearest residential receptors (i.e., privately owned residences, schools, parks) are over 1 mile from the terminal. Industrial receptors (e.g., guard shacks, industrial canal), that may be considered public receptors for RMP purposes, are within the toxic and distance to over pressure end points estimated in this report. Residential receptors are within the distance to over pressure end point for the worst-case analysis of a flammable substance vapor cloud explosion only. Residential receptors are not within the toxic endpoint for a worst-case or alternative case TDI release or alternative flammable substance release based on the equations and look-up tables provided in the EPA RMP guidance. Five -Year Accident History Intercoastal has no record of an accidental release that caused any injury or death to off-site personnel within the last 5 years. No deaths or serious on-site injuries have been recorded during the same period. Document Management System Intercoastal terminal's plant manager has the responsibility to develop, implement, and integrate the risk management program elements. General Accident Prevention Program and Chemical-Specific Prevention Steps The safe handling of TDI is a primary concern for facility personnel, Intercoastal management, and Bayer Corporation (current supplier of TDI). Bayer Corporation provides on-site safety seminars for Intercoastal personnel. Bayer Corporation has emergency response staff available in the Houston-Galveston-Texas City area trained in mitigating, neutralizing, and clean-up of TDI releases. Ba yer Corporation has provided emergency contact number (currently (281) 383-6700) for Intercoastal personnel in the case of a TDI release . Garner Environmental Services, Inc. ((409) 935 - 0308) is a professional emergency response and clean-up company that has been contracted by Intercoastal in the event of any emergency condition involving a chemical spill to land or water. Intercoastal personnel are trained on-the-job in the safe handling of TDI. Personnel are trained to report situations that may result in accidents (e.g., equipment wear and/or malfunctions, unsafe practices, etc..) to the plant manager and superiors. Intercoastal personnel are empowered to take action to reduce potential unsafe conditions. Intercoastal personnel are trained to handle flammable and highly flammable substances in a safe manner to reduce the potential for release, fire, and/or explosion. Marine barge loading operations are conducted to U.S. Coast Guard standards. This includes periodic pipeline pressure tests to ensure piping integrity and connection of grounding equipment to reduce material ignition by static electricity or spark. Incoming tank truck manifests are checked to ensure they meet Department of Transportation (DOT) requirements (Intercoastal does not own or maintain tank trucks or marine barges). The storage tank loading/and unloading operations are monitored by Intercoastal personnel to reduce the potential for vessel overfills and unsafe conditions. The handling of naphtha, and other components of the gasoline blendstock, are carefully monitored to reduce the potential for ignition. Safety Information - Intercoastal maintains Material and Safety Data Sheets (MSDS) on all chemicals that are brought on-site. MSDS are readily available to terminal and emergency response personnel. Maximum onsite inventories of toxic and/or flammable substances are kept. Equipment specifications, codes, and standards to operate terminal equipment and processes are on file. Hazard Review - Intercoastal has conducted hazard identification reviews of plant processes. They will continue to conduct reviews focussing on RMP regulated substances and will document opportunities for equipment malfunction, safeguards to prevent such malfunctions and control the associated hazards, and steps to detect or monitor releases. Operating Procedures - Intercoastal has written operating procedures for each process in contact with a regulated substance (e.g., TDI, flammable substances). Training - Intercoastal provides on-the-job and classroom training on operating procedures, health and safety hazards, emergency operations and safe work practices for terminal employees. Intercoastal will continue to provide and document all training activities. Garner Environmental periodically conducts safety training drills (e.g., table top spill drills) on-site with Intercoastal personnel and Bayer provides on-site training on safe handling of TDI. Intercoastal conducts periodic safety meetings and equipment training at the terminal. Key Intercoastal personnel have been trained and certified as required by OSHA under 29 CFR 1910.120 (HAZWOPER Training). Maintenance - Intercoastal performs periodic and regular maintenance and inspections of terminal equipment to help reduce accidental failure and ensure safe operation. Incident Investigation - Intercoastal will investigate each incident which resulted in, or could have resulted in, a catastrophic release of a regulated substance within 48 hours of the occurrence. A summary of the accident investigation, corrective actions, and recommendations on resolutions will be documented. The findings will be reviewed with terminal operators. Compliance Audit - Every three years Intercoastal will certify that they have evaluated compliance with the prevention program requirements of each covered process. Planned Changes to Ensure Safety Intercoastal plans to ensure safety by increasing safety training, acciden t awareness, and communication between terminal personnel and emergency response and safety organizations. Intercoastal has an approved written emergency response plan in place that covers much of the facility's marine barge operations (i.e., barge loading/unloading to and from tanks) as required by the U.S. Coast Guard Oil Pollution Act of 1990. This plan has be augmented recently by Intercoastal staff to include additional RMP (40 CFR 68) elements. The written plan will be continuously evaluated and supplemented by Intercoastal staff. The plan will be made available to the EPA, Texas City Local Emergency Planning Committee (LEPC), Texas City Fire Department, and contract emergency response teams. These emergency response team members will be invited to make comment to the written plan and to visit the site to review emergency response procedures. Intercoastal's plan will become part of the overall LEPC emergency plan and the National and Area Contingency Plans as determined by the regulatory agencies. The RMP plan will be kept on-site and be freely accessible to Intercoastal personnel, regulatory and emergency response agencies and team members. |