GALENA PARK TERMINAL - Executive Summary |
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GALENA PARK TERMINAL RMP - LEVEL 1 EXECUTIVE SUMMARY ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES: The Galena Park Terminal has a strong commitment to worker and public safety, along with resources invested in accident prevention, such as training personnel and contractors in design, installation, operations, and maintenance procedures. Our facility has handled Butadiene since 1957 without a harmful release. If an emergency were to occur, it is our policy to notify the Channel Industries Mutual Aide (CIMA) and request they respond to the emergency. DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES: The Galena Park Terminal is a "for hire" bulk liquid storage facility, occupying 196 acres with 195 aboveground atmospheric tanks and two pressure vessels. The pressure vessels accommodate the handling of 1,3-Butadiene to receive and deliver Butadiene by pipeline, tankcar, barge, and ship. The 1,3-Butadiene tanks are refrigerated for product quality reaso ns. This is the only regulated process governed by OSHA's Process Safety Management (PSM) regulation and the EPA's Risk Management Plan (RMP) regulation, meeting the NFPA 4 flammability requirements governing RMP. Butadiene storage at the Galena Park Terminal may be storage incident to transportation and may not be regulated under 40CFR Part 68. WORST CASE RELEASE SCENARIO: The Galena Park Terminal's worst case release scenario is the failure of one 40,000 barrel storage vessel filled to the greatest amount allowable, releasing 8,400,000 lbs. of refrigerated (38 degrees F) 1,3-butadiene. Relying on the services of Wilfred Baker Engineering Company of San Antonio, Texas to perform the consequence analysis, WBE utilized the commercially available DNV Technical PHAST dispersion program and the Baker-Strehlow program to identify the RMP radius of exposure for a 1 psi overpressure. According to the analyses, the greatest maximum end point for a 1 psi vapor cloud explosion is 0.1 mile f rom the center of the explosion, resulting from an instaneous release. This 0.1 mile endpoint is less than the distance to the nearest public receptor and therefore there is no offsite impact. GENERAL ACCIDENTAL RELEASE PREVENTION AND MAINTENANCE PROGRAM: The Galena Park Terminal is compliant with the thirteen (13) elements of Process Safety Management and other employee training programs, along with operating and maintenance procedures. The Butadiene storage and distribution system is governed by OSHA's Process Safety Management regulation, in addition to the U.S. Coast Guard's 33CFR, Part J 126/127 "Waterfront Facilities Handling Liquified Hazardous Gas". The facility complies with Federal and State requirements for leak detection of valves, pumps, and flanges. Inspections are conducted and documented to ensure the integrity of the tanks and equipment. FIVE-YEAR ACCIDENT HISTORY: There has been no accidental release from the butadiene process at galena park terminal that requi res reporting under the rmp rule. Futhermore the Galena Park Terminal has never had an accident involving 1,3-butadiene that caused deaths, injuries, property or environmental damage, evacuations, or sheltering inplace. EMERGENCY RESPONSE PROGRAM: The Galena Park Terminal maintains a written Emergency Response Program. The terminal is an active member of the Local Emergency Planning Committee (LEPC) , in additions to maintaining a paid membership in the Channel Industries Mutual Aide (CIMA). The facility is also a paid member of the Marine Spill Response Corporation. Members of CIMA have visited our facility and have inspected the 1,3-butadiene process. PLANNED CHANGES TO IMPROVE SAFETY: Management is in the process of increasing the intensity of annual employee refresher training, including but not limited to, operations and State, Federal and local regulatory regulations. No additional measures are necessary to prevent off-site impacts from accidental releases. CERTIFICATION STATEMENT: Based on the criteria in 40 CFR 68.10, the distance to the specified endpoint for the worst-case accidental release scenario for the following process is less than the distance to the nearest public receptor: * 1,3-Butadiene storage and handling system Within the past five years, the process has no accidental release that caused offiste impacts provided in the risk management program rule (40 CFR 68.10(b)(1)). No additional measures are necessary to prevent offsite impacts from accidental releases. In the event of fire, explosion, or a release of a regulated substance from the process, entry within the distance to the specified endpoint may pose a danger to public emergency responders. Therefore, public emergency responders should not enter this area except as arranged with the emergency contact indicated in the RMP. The undersigned certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true , accurate, and complete. F. L. Clark ___________________________________ _______________________________ Signature Senior Vice President, Terminal Operations ___________________________________ ________________________________ Title Date |