Lucy Woodstock Marine Terminal - Executive Summary |
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EXECUTIVE SUMMARY Lucy-Woodstock Marine Terminal's Commitment to Safety, Accident Prevention and Emergency Response Lucy-Woodstock Marine Terminal is committed to safe, clean and efficient storage and handling of butane. The resources invested in accident prevention, such as training personnel and considering safety in the design, installation and operation of our butane system demonstrate this commitment. Facility Description and Substance Handled Lucy-Woodstock Marine Terminal is located at 2455 N. 2nd St., Memphis, TN. Lucy-Woodstock stores, loads and unloads butane. Butane is a flammable gas under normal temperature and pressure. However, under pressure butane is a liquid. Butane meets the definition of a NPFA 4 flammable. Butane Sphere T-101 provides storage space for 48,000 barrels of butane. Safety relief valves are set to relieve to atmosphere at 75 psi. Instrumentation on T-101 consists of a level indicator, level transmitter, level alarm high and level alarm high -high. A safety switch and firesafe valve is provided on the tank suction line to the tank loading pump to close in the event of an emergency. Pump P-3 is utilized for loading of butane tank trucks, and if required, Pump P-7 may be utilized to unload tank trucks. Worst-Case and Alternative Release Scenarios A worst-case scenario is defined as the catastrophic release of the largest single inventory of the regulated substance. For flammable substances, such as butane, the release consists of the entire contents of the sphere over a 10 minute period. The worst-case scenario assumes that none of the many safety systems and process controls are operational. The safety systems and process controls at Lucy-Woodstock Marine Terminal include mechanical integrity of the butane system, detectors, alarms, etc. The alternative release scenario can be defined by the terminal and can take credit for mitigation systems in place. One worst-case scenario and one alternative release scenario a re presented in this RMP. Distances for the worst-case and alternative release scenario have been determined using the look-up tables in the EPA Guidance Document. The worst-case release is a release of the entire contents of the butane sphere (9,095,000 lbs.). The distance to the endpoint is 1.68 miles. This release scenario does have an offsite impact. The public and some of the regulation's public receptor types are impacted. No environmental receptors are impacted. The alternative release scenario selected by Lucy-Woodstock Marine Terminal is a BLEVE (Boiling Liquid Expanding Vapor Explosion) of the butane sphere (9,095,000 lbs.). The safeguards to prevent this scenario include fire water system and monitor for the tank, emergency response from terminal personnel and the Memphis Fire Department, lack of ignitions sources, mechanical integrity program on equipment and piping, and qualified operational personnel. The distance to the endpoint of 5 Kw/m2 is 1.23 miles. This r elease scenario does have an offsite impact. The public and some of the regulation's public receptor types are impacted. No environmental receptors are impacted. General Accidental Release Prevention Program - Specific Steps Lucy-Woodstock Marine Terminal has a comprehensive accidental release prevention program. The program addresses the butane handling that is covered by the EPA's RMP rule and OSHA's Process Safety Management regulation. The accidental release prevention program involves process design, equipment design, and construction to meet all applicable codes and standards. In addition, there are a number of safety systems, such as process controls, warning alarms, and operational controls in place to prevent a release from occurring. Lucy-Woodstock Marine Terminal has written safety information on the butane process, equipment and procedures available to all employees who work in the terminal. This includes information on the hazards of butane, the technology of the process, and the equipment in the process. The overall effectiveness of the accidental release prevention programs are monitored by a Process Hazard Analysis (PHA) which has been performed for the butane system. The PHA provides a method for understanding potential hazardous events, the means by which they occur and what actions are likely to prevent them from occurring. A team approach is used on the PHA to evaluate the potential consequences of failures in the butane system. The safeguards in place for each hazard are recorded and evaluated on a case-by-case basis. Recommendations are then made to improve safety where the existing safeguards were not considered adequate by the PHA team. A PHA of the butane system was completed in 1998 and will be updated on a 5-year cycle. The basis for proper and safe operation of the butane system is provided by written operating procedures. These procedures define the operating limits, identify safety and health consideration, and detail t he operation and function of safety systems. Specific modes of operation covered are startup, normal operations, emergency and normal shutdown, and temporary operations. To complement the written operating procedures, Lucy-Woodstock Marine Terminal's employees receive training in specific safety and health hazards, operation of the butane system, emergency operations and all applicable safe work practices for the system. Lucy-Woodstock Marine Terminal has a mechanical integrity program to ensure that all equipment is regularly inspected and maintained. All inspections and maintenance operations are documented. Lucy-Woodstock Marine Terminal has quality assurance measures to ensure that new equipment is suitable for its intended use and that the proper material and spare parts are used when repairs are made. Lucy-Woodstock Marine Terminal has a comprehensive system to manage change. The management of change (MOC) procedure ensures that any change that is not like-in-kind is docum ented and analyzed to ensure that the change is safe. The MOC procedure ensures that all changes are documented, properly authorized, and that all employees whose job tasks will be affected by the change are informed and receive appropriate training prior to the change. A pre-startup safety review will be conducted for any new covered process or significant modification to the butane system. The purpose of these reviews is to ensure that safety features, procedures, personnel, and equipment are appropriately prepared prior to operation. The performance of these safety programs and procedures is monitored through audits, periodic drills and inspections. Lucy-Woodstock Marine Terminal will investigate any incident that results in, or could result in, a release of butane. These investigations will follow a written procedure and be performed by a team from Conoco. The goal of incident investigation is to determine the root cause of the accident and to develop corrective actions to p revent reoccurrence of the incident. All corrective actions taken in response to the investigation team recommendations will be tracked until complete. The employee participation plan details employee involvement in safety and the prevention program. Conoco has a contractor safety program to ensure that contractors who work in or adjacent to the butane system are properly trained and meet safety criteria defined by Conoco. Five Year Accident History As a result of Lucy-Woodstock Marine Terminal's commitment to safety, there have been no accidents as defined in the RMP rule in the last 5 years. Emergency Response Program To be prepared for potential fires, Lucy-Woodstock Marine Terminal communicates with the Memphis Fire Department who is contacted by the terminal in the event of a butane release. Lucy-Woodstock Marine Terminal has an Emergency Response Plan and employees have received HAZWOPER training. Safety Improvements To achieve Lucy-Woodstock Marine Terminal's excellent safety track record, safety improvements have been made over the last decade. These include: - installation of fire water monitors - installation of hydrocarbon detectors - installation of additional process controls and alarms Lucy-Woodstock Marine Terminal will continue to monitor the effectiveness of the prevention programs and provide continuous improvement. |