Martin Transport, Inc. - Executive Summary |
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EXECUTIVE SUMMARY Martin Transport, Inc. Kilgore Mobil Pipeline Kilgore, Texas Accidental release prevention and emergency response policies At the Martin Transport, Inc. Kilgore Mobil Pipeline facility, we handle flammable substances considered hazardous by the U.S. Environmental Protection Agency (EPA). It is necessary to observe certain safety precautions in handling flammable substances to prevent unnecessary human exposure, to reduce the threat to our own personal health as well as our co-workers, and to reduce the threat to nearby members of our community. It is our policy to adhere to all applicable Federal and state rules and regulations. Safety depends on the manner in which we handle flammable substances combined with the safety devices inherent in the design of the facility, with the safe handling procedures that we use, and the training of our personnel. We at Martin Transport, Inc. are strongly committed to employee, public, and environmental safety. This commitm ent 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 process at our facility. This commitment led our company to financially contribute to the Gregg and Harrison Counties First Call. Telephone Warning System. Additionally, it is our policy to implement appropriate controls to prevent possible releases of regulated substances. If an accidental release should occur, the facility is prepared to work with the Gregg County Local Emergency Planning Committee (LEPC), the Kilgore Fire Department, and other authorities, to mitigate any release and minimize the impact of the release to people and the environment. Facility description and regulated substances handled The Martin Transport, Inc. Kilgore Mobil pipeline is a storage and distribution facility for liquefied petroleum gas (LPG). LPG is delivered to the facility via truck transpor t and is stored in a 30,000-gallon aboveground storage tank. LPG is transferred from the facility via a pipeline. The pipeline is owned and operated by Mobil. LPG is regulated under 40 CFR 68 as a result of being a mixture containing regulated chemicals with flash points and boiling points less than 730F and 1000F, respectively. Based on EPA guidelines, all scenarios can be based on the predominant flammable component of the mixture or the major component of the mixture (greater than 1% of the total) with the highest heat of combustion. Therefore, the scenarios are based on butane. The regulated substance handled at the Kilgore Mobil Pipeline facility is LPG. The maximum quantity of LPG that can be stored at this facility is 140,000 pounds in one 30,000-gallon aboveground storage tank. The worst-case release scenario and the alternative release scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario The EPA define s the worst-case release scenario as the failure of our largest storage tank when filled to the greatest amount allowed. The entire contents of the tank are assumed to release as a vapor cloud, which finds an ignition source. Ten percent of the released quantity is assumed to participate in the resulting explosion. The worst-case release scenario as defined by the EPA is highly unlikely to occur. During the evaluation, the scenario assumes none of the facility's mechanical controls or safety systems are operational, assumes no emergency response efforts take place, and assumes the release occurs under the worst weather conditions. Martin Transport, Inc. Kilgore Mobil Pipeline facility worst-case release scenario would result in a release of 140,000 pounds of LPG, primarily butane. To evaluate the worst-case release scenario, we have utilized RMP*Comp the EPA recommended software. Based on 140,000 pounds of LPG (butane) released, the distance the affect of a vapor cloud explos ion is expected to have no serious harm to the general public is 0.4-mile from the location of the storage tank. The EPA states an alternative release scenario is a release that is more likely to occur than the worst-case scenario and will reach an endpoint off-site. Active and passive mitigation systems may be considered for the alternate release scenario. The alternative release scenario deemed most likely to occur is the failure of a flexible transfer hose while transferring LPG from a truck transport to the storage tank. The flexible transfer hose has a nominal diameter of 2-inches. Excess flow valves at the truck transport and check valves at the storage tank function to stop the flow of LPG if a transfer hose fails. Additionally, a check valve at the loading rack would control any LPG in the hard piping between the loading rack and the storage tank, thereby eliminating any contributions to the release from the hard piping. Therefore, the LPG released would be limited to 40 pounds, the amount in the transfer hose. The scenario assumes the entire quantity of LPG in the transfer hose and iron piping is released. RMP*Comp estimates the distance endpoint for the release of 40 pounds of LPG, primarily butane as 0.01-mile. The hazard endpoint extends offsite. The general accidental release prevention program and the specific prevention steps Our Kilgore Mobil Pipeline facility complies with the Occupational Safety and Health Administration (OSHA)'s Process Safety Management (PSM) rule, EPA's Accidental Release Prevention Rule, and with all applicable state codes and regulations. Our facility has taken all the necessary steps to comply with the accidental release prevention requirements under 40 CFR part 68 of the EPA. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Martin Transport, Inc. maintains a detailed record of safety information that de scribes the chemical hazards, operating parameters, and equipment designs associated with the process. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that the hazards associated with our process are identified and controlled efficiently. The methodology used to carry out these analyses is a "What if" checklist. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at least once every five years. Any findings related to the hazard review are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our process, Martin Transport, Inc. maintains written operation 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 i s readily accessible to operators involved in the processes Training Martin Transport, Inc. has a comprehensive training program to ensure employees are competent in the operations and procedures associated with the process. Mechanical Integrity The Kilgore Mobil Pipeline carries out maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks include; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls, and pumps. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Martin Transport, Inc. to manage changes in process chemicals, technology, equipment, and procedures. Process operators, maintenance personnel, or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with th e modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Martin Transport, Inc. The reviews are conducted to confirm that construction, equipment, operating, and maintenance procedures are suitable for safe startup prior to placing equipment into operations. Compliance Audit The Kilgore Mobil Pipeline conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every three years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Martin Transport, Inc. promptly investigates any incident that resulted in, or could reasonably result in a catastrophic release of butane. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to p revent the release from reoccurring. All investigation reports are retained for a minimum of five years. Employee Participation It is our belief at Martin Transport, Inc., that process safety management and accident prevention are a team effort. Our employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. Contractors Occasionally, Martin Transport, Inc. hire contractors to conduct specialized maintenance or construction activities. We have a strict policy of informing the contractors of known potential hazards related to the contractor's work and the process. Contractors are also informed of emergency response procedures should an accidental release occur. Five-year accident history The Martin Transport, Inc. Kilgore Mobil Pipeline facility has an excellent record of preventing accidental releases over the last five years. Due to our stringent release prevention policies, there has been no accidental relea se of LPG during this period that resulted in deaths, injuries, or significant property damage onsite, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. Emergency response program The Kilgore Mobil Pipeline facility has a written emergency response program, in accordance with OSHA standard 29 CFR 1910.119. The program includes all aspects of emergency response including pre-emergency planning, employee training, adequate first aid and medical treatment, and evacuations. Additionally, the program includes procedures for notification of the Gregg County LEPC, the Kilgore Fire Department and use of the First Call. Telephone Warning System. First Call. is a telephone warning system for citizens of Gregg and Harrison Counties. First Call. uses computers and a recorded human voice to provide citizens with critical information concerning an emergency. This system will allow citizens to take immediate action to protect themse lves in the event of an emergency and permits emergency response agencies to focus on other activities to bring the emergency under control. Planned changes to improve safety Safety improvement is an on-going process at the Martin Transport, Inc. Periodic evaluations are preformed to assess the maintenance of safe conditions. There are no additional specific safety recommendations. |