Martin Underground Storage, Inc. - Executive Summary |
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Facility ID: 23678 EXECUTIVE SUMMARY Martin Underground Storage, Inc. Arcadia, Louisiana Accidental release prevention and emergency response policies At the Martin Underground Storage, Inc. facility, we handle butane, which is considered a hazardous flammable gas by the U.S. Environmental Protection Agency (EPA). The same properties that makes butane valuable as a fuel also makes it necessary to observe certain safety precautions in handling butane to prevent unnecessary human exposure, to reduce the threat to our own personal health as well as our co-workers, and to reduce the threat to nearby members of the community. It is our policy to adhere to all applicable Federal and state rules and regulations. Safety depends on the manner in which we handle butane combined with the safety devices inherent in the design of the facility combined with the safe handling procedures that we use and the training of our personnel. We at Martin Underground Storage, Inc. are strongly commit ted to employee, public, and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. If an accidental release should occur, the facility is prepared to work with the Arcadia Fire Department, and other authorities, to mitigate any release and minimize the impact of the release to people and the environment. Facility description and regulated substances handled The Martin Underground Storage, Inc. facility stores butane and propane in separate salt dome storage caverns. Truck transports and pipelines are used to deliver product to the storage caverns and to distribute product to customers. Transfer pumps are used in the product transferring process between the storage ca verns and the truck transports or pipeline. Products are temporarily staged in aboveground storage vessels, located near the loading racks, to facilitate truck transport loading and unloading. Access to the site is restricted to authorized facility employees, authorized management personnel, and authorized contractors. The regulated substance handled at our Underground Storage facility is butane and propane. The maximum quantity of butane that can be stored at this facility is 150,000,000 pounds in two underground salt dome storage caverns and four aboveground storage tank. The maximum quantity of propane that can be stored at this facility is 39,000,000 pounds in an underground salt dome storage cavern and two aboveground storage tanks. The worst-case release scenario and the alternative release scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario The EPA defines worst-case release scenario as the failure of o ur largest storage tank when filled to the greatest amount allowed. The entire contents of the tank are assumed to release as a vapor cloud, which finds an ignition source. Ten percent of the released quantity is assumed to participate in the resulting explosion. The worst-case scenario as defined by the EPA is highly unlikely to occur. During the evaluation, the scenario assumes none of the facility's mechanical controls or safety systems are operational, assumes no emergency response efforts take place, and assumes it occurs under the worst weather conditions. Martin Underground Storage, Inc. worst-case release scenario would result in a release of 81,000,000 pounds of butane from a 17,000,000-gallon salt dome storage cavern. To evaluate the worst-case release scenario, we have utilized the EPA recommended software called RMP*Comp. Based on 81,00,000 pounds of butane released, the distance the affects of a vapor cloud explosion is expected to have no serious harm to the gen eral public is 3.5 miles from the location of the cavern. The EPA states an alternative release scenario as a release that is more likely to occur than the worst-case scenario and will reach an endpoint off-site. Active and passive mitigation systems may be considered for the alternate release scenario. The alternative release scenario deemed most likely to occur is a the failure of a flexible transfer hose while transferring butane from a truck transport to a temporary storage tank. The flexible transfer hose has a nominal diameter of 2-inches. Excess flow valves at the truck transport function to stop the flow of butane out of the truck transport. According to Mr. Dale Halverson, product flow limitations during a release would not likely trigger operation of the excess flow valve in the storage vessel. Therefore, the butane released would be limited to the amount contained in a 42,500-gallon temporary storage tank until the emergency shut-off valves could be actuated. The gre atest amount of butane that could be contained in the storage tank is 170,000 pounds. In this alternative release scenario, RMP*Comp calculated the release rate of butane through a 2-inch opening as 9,540 pounds/minute. This scenario was modeled using a release duration of 1 minutes, based on Mr. Halverson's estimate to allow facility personnel to identify the failure and to implement actions to stop the release. At this rate, only 9,540 pounds of butane would be released. RMP*Comp modeled the distance endpoint for the release of 9,540 pounds of butane as 0.08-mile. The general accidental release prevention program and the specific prevention steps Our Underground Storage facility complies with the Occupational Safety and Health Administration (OSHA)'s Process Safety Management (PSM) rule, EPA's Accidental Release Prevention Rule and with all applicable state codes and regulations. Our facility has taken all the necessary steps to comply with the accidental release prevention requirements 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 Martin Underground Storage, Inc. maintains a detailed record of safety information that describes the chemical hazards, operating parameters, and equipment designs associated with the butane and propane processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that the hazards associated with our butane and propane processes are identified and controlled efficiently. The methodology used to carry out these analyses is a "What if" checklist. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at least once every five years. Any findings related to the hazard review are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our butane and propane processes, Martin Underground Storage, Inc. maintains written operation procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes Training Martin Underground Storage, Inc. has a comprehensive training program to ensure employees are competent in the operations and procedures associated with the processes. Mechanical Integrity The Truck Terminal facility carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls, and pumps. Maintenance operations are carried out by qualified personnel wi th previous training in maintenance practices. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Martin Underground Storage, Inc. to manage changes in process chemicals, technology, equipment, and procedures. Process operators, maintenance personnel, or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Martin Underground Storage, Inc. The reviews are conducted to confirm that construction, equipment, operating, and maintenance procedures are suitable for safe startup prior to placing equipment into operations. Compliance Audit The Truck Terminal facility conducts audits on a regular basis to dete rmine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every three years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Martin Underground Storage, Inc. promptly investigates any incident that resulted in, or could reasonably result in a catastrophic release of butane or propane. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All investigation reports are retained for a minimum of five years. Employee Participation It is our belief at Martin Underground Storage, Inc., that process safety management and accident prevention are a team effort. Our company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. Contractors Occasionally, Martin Underground St orage, Inc. hire contractors to conduct specialized maintenance or construction activities. We have a strict policy of informing the contractors of known potential hazards related to the contractor's work and the processes. Contractors are also informed of emergency response procedures should an accidental release of butane or propane occur. Five-year accident history The Martin Underground Storage facility has an excellent record of preventing accidental releases over the last five years. Due to our stringent release prevention policies, there has been no accidental release of butane or propane during this period that resulted in deaths, injuries, or significant property damage onsite, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. Emergency response program The Underground Storage facility has a written emergency response program, in accordance with OSHA standard 29 CFR 1910.119. The program includes all aspect s of emergency response including pre-emergency planning, employee training, adequate first aid and medical treatment, evacuations, notifications of local emergency response agencies and the public, as well as post-incident decontamination of affect areas. Planned changes to improve safety Safety improvement is an on-going process at the Underground Storage facility. Periodic evaluations are preformed to assess the maintenance of safe conditions. There are no additional specific butane or propane safety recommendations for implementation at this time. |