Paktank Corporation - Deer Park Terminal - Executive Summary
PAKTANK CORPORATION - DEER PARK TERMINAL |
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES
Paktank Corporation - Deer Park Terminal is committed to operating and maintaining our processes 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 workers, the public, as well as the protection of the environment. This documents provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including:
7 A description of our facility and storage of chemicals that are regulated by EPA's RMP regulation.
7 A summary of the results of our assessment of the potential offsite consequences from accidental chemical releases.
7 An overview of our accidental release prevention programs.
7 A five-year history of accidental releases for chemicals that are regulated by EPA's RMP rule.
7 An overview of our emergency
7 An overview of planned improvements at the facility to help prevent accident chemical releases from occurring and therefore adversely affecting our employees, the public, and the environment.
STATIONARY SOURCE AND REGULATED SUBSTANCES
Paktank Corporation - Deer Park Terminal is a for-hire liquid storage terminal. Chemicals and refined petroleum products represent the majority of the bulk liquids stored, handled and transported in this facility. Products are received into and transported from the facility via ship, barge, pipeline, tank car, and tank truck. At this time the facility is storing five chemicals (Chloroform, Propylene Oxide, Vinyl Acetate Monomer, Isoprene and 1,3 Pentadine) that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release.
KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS
EPA's RMP rule requires that we provide information about the worst-case scenario(s) and a
lternative 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 - Regulated Toxic Chemicals
The worst - worst-case release scenario for a regulated toxic chemical is the failure of a 55,000-barrel storage tank contained by a concrete firewall. The scenario assumes a 60-minute release time with worst-case weather conditions. The distance to the endpoint under the guidelines established by EPA is potentially 7.6 miles before enough vapor is dispersed to no longer pose a significant hazard to the public. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for passive mitigation measures was taken into account in evaluating this worst case scenario.
Alternative Release Scenario- Regulated Toxic Chemicals
The worst alternative re
lease scenario involves the development of a .50" hole at the manifold of a 30,000-barrel storage tank which is contained by a concrete firewall The leak is detected and isolated within seven hours. Total loss of product is 61,620 pounds, which results in the endpoint under the guidelines set by EPA, of 0.19 miles, before dispersing enough to no longer pose a significant hazard to the public.
Worst-case Release Scenario - Regulated Flammable Chemicals
The worst case release scenario for a regulated flammable chemical is the failure of a 55,000-barrel storage tank contained by a concrete firewall. The scenario assumes a 60-minute release time with worst- case weather conditions. The distance to the endpoint under the guidelines established by EPA is potentially 1.5 miles before enough vapor is dispersed to no longer pose a significant hazard to the public. Although we have numerous controls to prevent such releases and to manage their consequences, no credit for passive mitigation
measures was taken into account in evaluating this worst case scenario
Alternative Release Scenario (s) - Regulated Flammable Chemicals
The alternative release scenario is an 8" diameter transfer line rupture at the tank manifold which is contained by a concrete firewall. The leak is detected and isolated within one hour. Total loss of product is 1,496,149 pounds, which results in the endpoint under the guidelines set by EPA, of 0.24 miles, before dispersing enough to no longer pose a significant hazard to the public.
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 address each key feature of a successful prevention program including:
7 Process safety information
7 Process hazard analysis
7 Operating procedures (ISO 9002)
7 Mechanical integrity
7 Management of change
7 Pre-startup review
7 Compliance a
7 Incident investigation
7 Employee participation
7 Hot work permit
These individual elements of our prevention program are utilized to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business. With our 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 in the past five years that have had an adverse impact on the community or that meets the EPA Risk Management Program (RMP) reporting requirements.
EMERGENCY RESPONSE PROGRAM
We maintain various contingency plans, which address 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 th
e community emergency response plan.
We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. Our accidental release prevention programs and our contingency planning efforts help us to effectively mange the hazards that are presented to our employees, the public, and the environment.
PLANNED CHANGES TO IMPROVE SAFETY
The following is a list of proposed improvements to be implement at the facility to help prevent and/or better respond to accidental chemical releases:
Proposed installation of a high temperature alarm at the discharge area of the pump for Isoprene and 1,3 Pentadine.
Proposed installation of a low- level probe at the tank for Isoprene and the 1,3 Pentadine.
Proposed installation of a flow meter for tank truck loading of chloroform.