Trinity Industries, Inc. Plant #25 - Executive Summary |
|
General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities 1. Accidental Release Prevention and Emergency Response Policies We at Trinity Industries, Inc. Plant #25 are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive safety 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. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities consist of rail car maintenance and repair. Railroad tank cars containing residual amounts of anhydrous ammonia, LPG, and butadiene are occasionally received. These substances are flared prior to cleaning and repair of the rail cars. The maximum potential inventory of Ammonia (anhydrous) that is expected to be present in this facility is 1,485,000 lb. while 1,3-Butadiene and Propane are expected to be present at our facility in maximum potential quantities of 1,458,000 lb. and 1,134,000 lb,. respectively. While these quantities represent potential maximum inventories, normal inventories are expected to be much less. 3. Worst Case Release Scenarios and the Alternative Release Scenarios For all worst case and alternative release scenarios, we have used EPA's RMP*Comp(TM) to determine the distance to endpoint for chemical releases and Landview III for population estimates. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 3 toxic substances involves the catastrophic release of a rail car full of anhydrous ammonia. In this scenario 148,500 lb. of anhydrous ammonia is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporat e over 10 minutes. The released quantity has been limited to 90% of the maximum capacity of the rail car due to administrative controls. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 6.9 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. The alternative release scenario for anhydrous ammonia involves a release from a rail car containing anhydrous ammonia. The scenario involves the release of 100 lb. of anhydrous ammonia over a period of 10 minutes due to a leaking hose. The release is assumed to be terminated by operator response. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of anhydrous ammonia is 0.1 miles. The worst case release scenario submitted for Program 3 flammable substances involves the catastrophic release of rail car full of 1,3-Butadiene. In this scenario 145,800 lb. of 1,3-Butadiene is released. The release quantity has been limited to 90% of the maximum capacity due to administrative controls. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the calculated distance of 0.42 miles is obtained corresponding to an endpoint of 1 psi overpressure. The alternative release scenario submitted for Program 3 flammable substances involves a release from a rail car containing 1,3-Butadiene. The release is assumed to result in a vapor cloud explosion. The scenario involves the release of 10,000 lb. of 1,3-Butadiene in 10 minutes. The release is terminated by operator response. Under neutral weather conditions, the maximum distance to the flammale endpoint of 1 psi overpressure is 0.08 miles. 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 Trinity Industries, Inc. Plant #25 maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with the covered process. Process Hazard Analysis Our facility has conducted a comprehensive study to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses was What If/Checklist (combined). This study was undertaken by a team of qualified personnel with expertise in engineering and process operations and will be revalidated at a minimum interval of 5 years. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 11/05/1999. Operating Procedures For the purp oses of safely conducting activities within our covered process, Trinity Industries, Inc. Plant #25 maintains written operating procedures. These procedures address various modes of operation. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Trinity Industries, Inc. Plant #25 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 3 years and more frequently as needed. Mechanical Integrity Trinity Industries, Inc. Plant #25 performs 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 inspections are performed by qualified personnel with previous training i n 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 Trinity Industries, Inc. Plant #25 to manage changes in process chemicals, technology, equipment and procedures. Pre-startup Reviews Written procedures are in place at Trinity Industries, Inc. Plant #25 to perform pre-start up safety reviews related to new processes and to modifications in established processes. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Trinity Industries, Inc. Plant #25 conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent comliance audit was conducted on 11/03/1999. These audits are carried out at least every 3 years and any corrective acti ons required as a result of the audits are addressed in a safe and prompt manner. Incident Investigation Trinity Industries, Inc. Plant #25 promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. 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 reports are retained for a minimum of 5 years. Employee Participation Trinity Industries, Inc. Plant #25 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. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. It is the policy of Trinity Industries, Inc. Plant #25 to inform contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History Trinity Industries, Inc. Plant #25 has had an excellent record of preventing accidental releases. Due to our stringent release prevention policies, there has been no accidental release during the previous 5 years. 6. Emergency Response Plan Trinity Industries, Inc. Plant #25 maintains a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medica l treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident investigation. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. 7. Planned Changes to Improve Safety Trinity Industries recognizes that maintaining and improving plant safety is a continual process. Consequently, our safety programs are strictly enforced and are regularly reviewed for opportunities to improve plant safety. |