BMS, Inc. - Executive Summary |
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BMS, Inc. owns and operates a liquified petroleum gas (LP-gas) distribution and storage facility in Pearland, Brazoria County, Texas. The facility is designed to distribute and store the following LP-gases: propane, propylene, butane, isobutane, isobutylene, and butylene. The primary purpose of the facility is to repackage and distribute LP-gases to both retail and wholesale customers for use as a fuel. Section 112(r) of the Clean Air Act applies to the BMS, Inc. facility because the facility handles and stores the following RMP-regulated flammable gases: propane, propylene, butane, isobutane, isobutylene, and butylene in excess of threshold quantities. Two requirements of this section specifically apply to operations at the plant: 1. '112(r)(1) - Purpose and General Duty Clause - The essence of the general duty clause is that an owner/operator that stores and uses hazardous chemicals in any quantity has a fundamental obligation to ensure a safe operation and to have plans in pl ace in the event of an accident to appropriately manage the situation. BMS, Inc. is committed to ensuring the safe operation of its LP-gas distribution and storage facility, as well as all of its other operations, to ensure a safe workplace for our employees and a safe location for our neighbors in the community. BMS, therefore, has procedures in place to prevent accidents and is committed to emergency preparedness both for our facility and community-wide by coordinating with the local Fire Department. 2. Risk Management Plan - The BMS, Inc. LP-gas distribution and storage facility handles and stores propane, propylene, butane, isobutane, isobutylene, and butylene in excess of thresholds specified in '112(r). Even prior to the promulgation of '112(r), BMS, Inc. management has been very aware of the potential hazards posed by the handling and storage of flammable gases. Programs have been established to prevent any accidental releases and to train personnel for emergency evacuation p rocedures in the event of a release. These programs are documented and described in this Risk Management Plan. In accordance with the RMP definition for a "process", the LP-gas distribution and storage facility is defined as one process consisting of ten tanks that are interconnected. Tanks #1 and 10 hold propane; Tanks #2, 5 and 9 hold propylene; Tanks #3 and 8 hold n-butane; Tank #4 holds isobutane; Tank #6 holds butylene; and Tank #7 holds isobutylene. For planning purposes, BMS has considered the impact of a "worst case" accident, defined to be a catastrophic release of 120,000 pounds of propylene from Tank #9, the storage tank holding the largest quantity of a flammable gas. The maximum quantity in the storage tank has been limited to 88% by written procedural mechanisms. It is assumed the entire quantity instantaneously forms a vapor cloud, finds an ignition source, and explodes. Using the National Oceanic and Atmospheric Administration's (NOAA's) RMP*Comp methodology, a potential radius of impact due to the explosion was calculated to extend to be 0.4 miles. Demographic information based on the 1990 census indicates that three people distributed among three households live within this radius. No other public receptors and no environmental receptors are located within this radius. It should be emphasized that the probability of the worst-case catastrophic event evaluated in this report is extremely remote - far less than natural catastrophes such as tornadoes and floods that could produce much more severe and extensive damage and injury. A consideration of the 0.4-mile radius has been incorporated into BMS, Inc.'s notification and emergency response planning. BMS, Inc. also considered the impact of a more likely release. This alternative release is characterized as a sheared pipe on the tank, resulting in a release of propylene, a flammable gas liquified under pressure. Assuming the release goes unmitigated, using EPA's April 1999 version of the Risk Management Program Guidance for Offsite Consequence Analysis (RMP Guidance for OCA) the release rate was estimated to be 12,000 pounds per minute and was assumed to result in a vapor cloud fire (flash fire) with a potential impact distance of 0.1 mile to the lower flammability limit (LFL). This represents the maximum distance at which the radiant heat effects of a vapor cloud fire involving the proposed propylene release might have serious consequences. There are no public receptors and no environmental receptors located within this radius. BMS, Inc. has implemented safety precautions and procedures designed to prevent and mitigate catastrophic releases. BMS, Inc. has active operating, maintenance, training, and inspection procedures. In addition, BMS, Inc. has coordinated with local emergency responders including the Pearland Volunteer Fire Department and the Local Emergency Planning Committee. BMS, Inc.'s management is committed to the following: q Preventing accidents; q Tr aining our employees in correct procedures in the event of an accident; q Participating in community emergency preparedness; q Addressing any citizen concerns by fully explaining potential hazards associated with BMS, Inc. operations and all steps being taken to prevent and mitigate accidents; and q Being a good corporate citizen of Brazoria County. With these objectives in mind, this Risk Management Plan has been developed to provide information about our management of the risks associated with the LP-gas process. Most important, BMS, Inc. stresses its commitment to ensuring a safe operation for its employees, its visitors, and its community. In addition to the above Clean Air Act requirements, BMS, Inc. is in compliance with the OSHA PSM, EPCRA, and Department of Transportation Texas Railroad Commission NFPA 58 requirements. Additionally, BMS, Inc. has conducted a process hazard analysis (PHA) on the LP-gas distribution and storage process and currently implementing recommendation s made to further improve the safe operation of this process. As a result of the PHA study, in order to avoid an accidental release due to a pull away during loading/unloading operations, BMS has revised the loading and unloading operating procedures to require that chock blocks be placed at the tires on the passenger side of the cargo tank vehicles. This would ensure that the operator or driver walks around the vehicle to check before driving away. Additionally, in order to prevent overfilling, the procedures were revised to ensure that the operator or the driver stays by the cargo tank vehicle and/or the storage tank during the entire transfer operation to monitor the gauges during filling. Additional improvements that BMS will be implementing before the end of 1999 include the following: 7 Installation of remote controlled or automated emergency shutoffs on the cargo tank vehicles. 7 Implementation of a leak detection program at a frequency of every six months. 7 Further devel opment of the written maintenance program. 7 Further development of the incident investigation system. 7 Formation of a team of management and operations representatives to review existing procedures. provide suggestions for further improvements, and ensure they are reviewed and updated annually. 7 Review the training. |