Frontier Marketing, Incorporated - Executive Summary |
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Executive Summary for Frontier Marketing, Inc. 1. Accidental Release Prevention and Emergency Response Policies We at Frontier Marketing, Inc. are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as safety information, hazardous materials storage procedures, maintenance, and employee training associated with the process of hazardous materials warehousing at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. 2. The Stationary Source and the Regulated Substances Handled We have 1 regulated substance present at our facility. This substance is present in two different concentrations and two types of containers: Hydrogen Fluoride, Anhydrous is present in our warehouse in tank trucks. These containers are ASME carbon steel pressure vessels. Built according to DOT specifications for an MC-312 cargo tank. Typical capacity is 5,000 gallons. Maximum number of cargo tanks on inventory will be four. Hydrofluoric acid, 70 solution is present in 55-gallon drums. These drums can be plastic (polyethylene) or metallic with a plastic liner. These drums are all new non-reusable drums that meet DOT specifications for packaging of hydrofluoric Acid 70% solution. Maximum number of drums is 800. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario To perform the required offsite consequence analysis for our facility, we have used EPA software RMP*Comp. The following paragraphs provide details of the chosen scenarios. The worse case scenario was calculated using the biggest container on our warehouse. This is a 40,000 pound liquid spill and vaporization from a tank truck of hydrogen fluoride. The quantity of HF released, duration of the release, wind speed and atmospheric stability used were the recommended values by EPA on their RMP Guidance. The tank trucks are parked outside in gated and lighted area. Therefore NO passive mitigation is available. This scenario will have offsite consequences. The estimation of public receptors within the distance to the endpoint was determined using Landview III Environmental Mapping Software. We are reporting two alternative release scenarios: One for anhydrous hydrogen fluoride. The alternative release scenario will be a release of hydrogen fluoride gas from a safety relief valve on the tank truck. The duration of the release was estimated at 15 minutes. This scenario will have offsite consequences. The number of public receptors was determined using Landview III - Environmental Mapping Software. There is no passive mitigation available. There is an emergency capping kit on every tank truck and this will be considered as active mitigation. The second alternative release scenario will be for hydrofluoric acid, 70% solution. The scenario will be the rupture of a 55-gallon drum. The scenario is the release of liquid hydrofluoric acid from a one-inch hole caused by a forklift. This liquid release will be inside a dedicated storage building; therefore passive mitigation will be available. There will be offsite receptors. The number of public receptors was determined using Landview III. Environmental Mapping Software. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Frontier Marketing, Inc maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associa ted with all processes. Process Hazard Analysis Our facility conducted comprehensive study to ensure that hazards associated with our storage process are identified and controlled efficiently. The methodology used to carry out these analyses is checklist method recommend by the Chemical Manufacturers Association Warehouse Assessment Protocol. The studies were undertaken by a team of qualified personnel with expertise in engineering and process operations and will be revalidated at a regular interval of three years. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 06/03/1999. Operating Procedures For the purposes of safely conducting activities within our covered processes, Frontier Marketing, Inc maintains written operating procedures. These procedures address various modes of operation such as segregation and storage procedures; Use of Forklifts; Loading and unloading; Examination for damaged and labeling; Stock Controls; Site security; Bracing and Stacking and Handling of damaged containers. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Frontier Marketing, Inc has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every year and more frequently as needed. Mechanical Integrity Frontier Marketing, Inc carries out maintenance checks on equipment used to move storage containers to ensure proper operations. Equipment examined by these checks includes among others; forklifts and dock equipment. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Compliance Audits Frontier Marketing, Inc conducts aud its on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent compliance audit was conducted on 06/15/1999. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Frontier Marketing, Inc promptly will investigate any incident that could reasonably result in a catastrophic release of a regulated substance. These investigations will be done to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports will be retained for a minimum of 5 years. Employee Participation Frontier Marketing, Inc truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. 5. Five-year Accident History Frontier Marketing, Inc. has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan Frontier Marketing, Inc will notify the local emergency responders when there is a need for assistance on an emergency situation. We believe that the size of our operation and the number of employees we have do not allow to develop an emergency response team. We will focus on employee safety and adopt a policy as a non-responding facility as described on 40 CFR 68.90(b). Frontier Marketing Inc. will provide all necessary information regarding quantities and characteristics of the regulated substances stored at this facility to the El Paso Fire Department to help plan the response to an emergency at this location. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. The construction of a building for the storage of anhydrous hydrogen fluoride tank trucks is one of the major steps we want to take to improve safety at our facility. These changes are expected to be implemented by 11/30/1999. |