Intercontinental Terminals Company - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Intercontinental Terminals Company (I.T.C.) in Deer Park, is committed to operating and maintaining our processes (especially those using hazardous substances) in a safe and responsible manner. We use a combination of accidental release prevention and emergency response planning programs to help ensure the safety of our associates and the public, as well as the protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: * A description of our facility and our uses of substances that are regulated by EPA's RMP regulation. * A summary of the results of our assessment of the potential offsite consequences from accidental chemical releases. * An overview of our accidental release prevention programs. * A five-year history of accidental releases for chemicals that are regulated by EPA's RMP rule. * An overview of our emergency response program. * An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and therefore adversely affecting our associates, the public, and the environment. * EPA (RMP) - Required Certifications. * Detailed information (data elements) about our risk management program. STATIONARY SOURCE AND REGULATED SUBSTANCES At the present time, our facility is a for-hire bulk liquid storage facility, NAICS 493190, that stores a variety of chemicals and petrochemicals. Our processes involve the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: Toxic Acrylonitrile Vinyl Acetate Monomer Allyl Alcohol Flammables Propylene 1,3-Butadiene Isobutane Isoprene 1-Butene KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule requires that we provide information about the w orst-case release scenario(s) and alternative release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures that limit the exposure distances for each scenario: Worst-case Release Scenario(s) - Regulated Toxic Chemicals The worst case release scenario for a regulated toxic chemical, is the failure of a storage tank. The storage quantity in the tank is limited to 95% of the tank capacity by I.T.C. administrative controls. Alternative Release Scenario(s) - Regulated Toxic Chemicals The alternative release scenario involves the development of a .50" hole in a 8" dock line. The emergency shutdown system stops the flow in a time period that is less than 10-minutes. The alternative release scenario involves the development of a .50" hole in a 6" dock line. The emergency shutdown system stops the flow in a time period that is less than 10-minutes. For both worst and alterat ive regulated toxic scenerios the mitigation controls and release mitigations are: Containment area. The containment area will hold the entire amount of the dock line. Valves to permit isolation of the process (manual or automated) The storage tank are built to API 650 and are inspected to API 653 Fire suppression Trained emergency response personnel Personnel protective equipment (i.e., protective clothing, self-contained breathing apparatus) Worst-case Release Scenario(s) - Regulated Flammable Chemicals The worst case release scenario for a regulated flammable gas is the failure of a storage tank. The storage quantity in the tank is limited to 95% of the tank capacity by I.T.C. administrative controls. Alternative Release Scenario(s) - Regulated Flammable Chemicals The alternative release scenario, is the operation of an 8" relief valve for 10 minutes, resulting in the release of product. For both worst and alterative regulated flammable scenerios th e mitigation controls and release mitigations are: A containment berm that surrounds the tank. The containment area will hold the entire amount of the storage tank. Valves to permit isolation of the process (manual or automated) The storage tank are built to API 650 or API 620 and are inspected to API 653 Fire suppression Deluge systems for specific equipment Trained emergency response personnel Personnel protective equipment (i.e., protective clothing, self-contained breathing apparatus) GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS We take a systematic, proactive approach to the prevention of accidental releases of hazardous chemicals. Our management system addresses each key feature of a prevention program including: * Process safety information * Process hazard analysis * Operating procedures * Training * Mechanical integrity * Management of change * Pre-startup review * Compliance audits * I ncident investigation * Employee participation * Hot work permit * Contractors These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our associates are committed to the standard that these management systems set for the way we do business; and, we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. FIVE-YEAR ACCIDENT HISTORY There have been no releases of EPA regulated chemicals at I.T.C. in the past five years that have had an adverse impact on the community or our industrial neighbor(s). Nor have there been any incidents that are under the EPA definition. EMERGENCY RESPONSE PROGRAM We maintain an integrated contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers , the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan. We are using this information to help ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. PLANNED CHANGES TO IMPROVE SAFETY The following is a list of improvements that we plan to implement at the facility to help prevent and/or better respond to accidental chemical releases: Proposed installation of a gas detection system. Proposed installation of two emergency shutdown valves on the cargo and pipeline pump bypass lines. The tank must come out of service before the valves can be installed. Proposed installation of emergency shutdown switches outside the storage area for the cargo pumps. Proposed installation of a audio alarm on the corkin compressor. Proposed installation of a high level and high/high level alarms on the tanks. Proposed placing regulated pumps into I. T.C.'s tandem seals program. Proposed placing regulated pumps into I.T.C.'s check valves program. Proposed placing the pipelines on our non-destructive program. Proposed installation of an extension pipe on the knock-out pot. |