MarkWest Hydrocarbon, Inc. - Siloam Facility - Executive Summary |
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Risk Management Plan Executive Summary MarkWest Hydrocarbon, Inc. - Siloam Facility 1. Accidental Release Prevention and Emergency Response Policies The MarkWest Hydrocarbon, Inc. (MarkWest) - Siloam facility located in South Shore, Kentucky is strongly committed to employee, public, and environmental safety. This commitment is inherent to a comprehensive accidental release prevention program that covers such areas as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is the policy of MarkWest to implement appropriate controls to prevent the possible release of regulated substances. Unforeseeably, if such a release does occur, MarkWest is completely coordinated with the Greenup County, Kentucky and Scioto County, Ohio Local Emergency Planning Committees (LEPCs) which provide emergency response personnel to control and mitigate the effects of the release. 2. The Stationary Source and the Regulated Subst ance Handled The primary function of the MarkWest facility encompasses processing, storage, and wholesale distribution of various liquified petroleum gases (LPGs). The following LPGs are present at the facility: propane, normal butane, isobutane, natural gasoline (pentanes and hexanes), and mixed feed natural gas liquids (a combination of all the previously mentioned LPGs commonly referred to as Y-grade). All of these substances are regulated due to their flammable and explosive nature. The facility receives the mixed feed Y-grade from pipeline, tank truck, and rail car. The Y-grade is stored in above ground vessels and then processed at the facility into propane, normal butane, isobutane, and natural gasoline. These products are stored in both above ground vessels and also, in the case of propane and normal butane, in underground caverns. These products are then distributed from the facility by tank truck, rail car, and, in the case of normal butane, isobutane, and natural ga soline, by barge. The facility contains a total of 30 above ground vessels and 2 underground storage caverns. Table 1 summarizes the storage capacities of each of the vessels and caverns and also the type of product stored in each. Table 2 summarizes the vessels and storage capacities for propane, normal butane, isobutane, natural gasoline, and Y-grade, respectively. TABLE 1 TOTAL STORAGE CAPACITIES MarkWest Hydrocarbon, Inc. Siloam Facility South Shore, Kentucky Product Stored Tank ID Capacity (gallons) Propane Normal Butane Isobutane Natural Gasoline Natural Gas Liquids SV-100 60,000 X SV-101 18,000 X SV-102 18,000 X SV-103 30,000 X SV-104 30,000 X SV-200 57,707 X X SV-201 57,744 X SV-202 57,671 X SV-203 57,754 X SV-204 59,582 X SV-205 59,672 X SV-300 32,133 X SV-301 32,221 X SV-400 15,155 X SV-401 26,950 X SV-402 30,000 X SV-403 42,151 X SV-404 42,151 X SV-405 42,151 X SV-406 210,000 X SV-407 210 ,000 X X SV-500 30,618 X SV-501 259,723 X SV-502 442,780 X SV-503 30,000 X SV-504 30,000 X SV-505 30,000 X SV-506 30,000 X SV-600 42,151 X SV-601 42,151 X Propane X Cavern 8,000,000 Butane X Cavern 3,000,000 TABLE 2 PRODUCT SUMMARIES MarkWest Hydrocarbon, Inc. Siloam Facility South Shore, Kentucky PROPANE NORMAL BUTANE Capacity Tank ID (gallons) (pounds) SV-204 59,582 250,244 Capacity SV-205 59,672 250,622 Tank ID (gallons) (pounds) SV-200* 57,707 242,369 SV-300 32,133 157,452 SV-201 57,744 242,525 SV-301 32,122 157,398 SV-202 57,671 242,218 SV-600 42,151 206,540 SV-203 57,754 242,567 SV-601 42,151 206,540 Propane Butane Cavern 8,200,000 34,440,000 Cavern 3,000,000 14,700,000 Total 8,550,130 35,910,546 Total 3,148,557 15,427,929 ISOBUTANE NATURAL GASOLINE Capacity Capacity Tank ID (gallons) (pounds) Tank ID (gallons) (pounds) SV-400 15,155 74,260 SV-50 0 30,618 171,461 SV-401 26,950 126,665 SV-501 259,723 1,454,449 SV-402 30,000 141,000 SV-502 442,780 2,479,568 SV-403 42,151 198,110 SV-407 210,000 1,176,000 SV-404 42,151 198,110 SV-503 30,000 168,000 SV-405 42,151 198,110 SV-504 30,000 168,000 SV-406 210,000 987,000 SV-505 30,000 168,000 SV-407 210,000 987,000 SV-506 30,000 168,000 Total 618,558 2,910,255 Total 1,063,121 5,953,478 Y-GRADE Capacity Tank ID (gallons) (pounds) SV-104 30,000 144,000 SV-103 30,000 144,000 SV-102 18,000 86,400 SV-101 18,000 86,400 SV-100 60,000 288,000 Total 156,000 748,800 * SV-200 used as storage of natural gas liquids when needed. The total quantity of product stored in each of the above ground vessels is administratively controlled to ensure that the vessels are not filled above 90% of full capacity. Additionally, pressure relief devices are installed on the vessels to provide added assurance that the vessels ar e not overfilled. These controls are in place to prevent over-pressurization which could cause structural damage to the vessels and lead to a release. Based on the administrative controls described above, the maximum product inventories are provided below: 1. The maximum inventory of propane at the facility is: 35,763,491 pounds (lbs.). 2. The maximum inventory of normal butane at the facility is: 15,355,136 lbs. 3. The maximum inventory of isobutane at the facility is: 2,619,229 lbs. 4. The maximum inventory of natural gasoline at the facility is: 5,358,130 lbs. 5. The maximum inventory of Y-grade at the facility is: 673,920 lbs. 3. The Worst Case Release Scenario and Alternative Release Scenario, including administrative controls and mitigation measures in place to limit the distance for each reported scenario The parameters of the offsite consequence analyses for this MarkWest facility were based on the requirements set forth in the RMP rules outlined in 40 CFR 68.25 (e), Wo rst-case release scenario-flammables and 40 CFR 68.28, Alternative release scenario analysis. The worst case and alternative case radii of effect were determined utilizing RMP*Comp software provided by the EPA. The following describes details of the chosen scenarios. The worst case scenario for Program 3 flammable substances as a class involves a catastrophic release from the underground propane storage cavern. The scenario involves the release of the entire quantity of the cavern, approximately 8.2 million gallons (34.44 million pounds) of propane. 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 (wind speed of 3.4 miles per hour), the maximum distance of 2.63 miles is obtained corresponding to an endpoint of 1 pound per square inch (psi) overpressure. Utilizing Landview III and Marplot software, the worst case sc enario radius of 2.63 miles is illustrated in the graphic file "siloamwc.jpg" (electronic version) and in the attached map (provided in non-electronic versions only). Major industrial facilities located within this radius include North American Refractories, New Boston Coke, and OSCO Industries. Residential areas located within the radius include South Shore, Kentucky, New Boston, Ohio, and portions of Portsmouth and Sciotoville, Ohio. Based on Landview III 1990 census data utilizing the block group proration method, 2,544 households and 6,353 people are located within the 2.63 mile radius. Finally, eight schools are located within the 2.63 mile radius: Mckinley Middle, Highland Elementary, Wilson Elementary, Oak Street Elementary, Glenwood High, Stanton Elementary, Mckell Middle, and Mckell Elementary. The alternative release scenario submitted for Program 3 flammable substances involves a release from one of the vessels in the propane storage process. Vessel SV-200 was arbitrar ily selected for use in this scenario. The scenario involves the release of the entire quantity of the vessel, approximately 51,936 gallons (218,132 lbs) of propane (this quantity is 90% of the entire available capacity of the vessel). 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 the vapor cloud explosion. Under neutral weather conditions (wind speed of 6.7 miles per hour), the maximum distance of 0.3 miles is obtained corresponding to an endpoint of 1 psi overpressure. The alternative case scenario radius of 0.3 miles is illustrated in the attached map (provided in non-electronic versions only). No major industrial or residential areas are located within this radius. No schools are located in this area. The radius of effect of this alternative release scenario would remain within the boundaries of MarkWest-owned property. 4. The General Accident Release Prevention Prog ram and the Chemical-Specific Prevention Steps MarkWest has taken all the necessary steps to comply with accidental release prevention requirements sets out under 40 CFR Part 68 of the EPA regulations. The propane, normal butane, isobutane, natural gasoline, and NGL storage and distribution processes at MarkWest are subject to the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) standard under 29 CFR 1910.119. The following briefly describes the elements of the release prevention program in place at the MarkWest stationary source. Process Safety Information MarkWest maintains a detailed record of written safety information that describes the chemical hazards, operating parameters, and equipment designs associated with all processes. Process Hazard Analysis MarkWest conducts comprehensive studies to ensure that the hazards associated with the processes at the facility are identified and controlled efficiently. The "What If?" methodology is used to carry out these analyses. The studies are undertaken by a team of qualified personnel in engineering and process operations and are revalidated at regular intervals. Any findings related to the hazard analyses are addressed in a timely manner. Operating Procedures For the purpose of safely conducting activities within covered processes, MarkWest maintains written operating procedures. These procedures address various modes of operation such as initial start up, normal operations, temporary operations, emergency shutdown, normal shutdown, and startup after turn around. The information is regularly reviewed and is readily accessible to operators involved with the process. Training MarkWest has a comprehensive training program in place to ensure that the employees operating processes are completely competent in the operating procedures associated with the processes. New employees receive basic training in process operations followed by on-the-job supervision until they a re deemed competent to work independently. Refresher training is provided as needed. Mechanical Integrity The integrity of mechanical operations at MarkWest is ensured through documented maintenance checks on process equipment. Process equipment examined by these checks include among others: pressurized storage vessels, piping systems, relief and vent systems, emergency shutdown systems, controls, and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. 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 MarkWest to manage changes in process chemicals, technology, equipment, and procedures. Process operators, maintenance personnel, or any other employees whose job tasks are affected by a modification in process conditions are promp tly made aware of and are trained on the specifics of the modification. Pre-Startup Reviews Pre-startup safety reviews related to new processes and to modifications in established processes are conducted as required. 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 MarkWest conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out every three years as required by RMP regulations (40 CFR 68.58) and any corrections required as a result of the audits are undertaken in a safe and timely manner. Incident Investigation MarkWest 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 needed to prevent the release from reoccurring. All reports are retained for a period of five years. Employee Participation MarkWest believes that successful PSM and accident prevention programs require a team effort. Company employees are encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, MarkWest employees have access to all information created as part of the facility's implementation of the RMP program, in particular, information relating to and resulting from process hazard analyses. Contractors Periodically, MarkWest hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of the safety performance of the contractor is undertaken. MarkWest has a strict policy of informing contractors of known potential hazards relating to the contractor's work and the associated processes. Contractors are also informe d of all procedures for emergency response should an accidental release of a regulated substance occur. 5. Five Year Accident History MarkWest has had an excellent record of preventing accidental releases over the last five years. Due to stringent release prevention policies, there have been no accidental releases during this period. 6. Emergency Action Plan A written emergency action plan to deal with accidental releases of regulated substances is retained at the MarkWest facility. The plan includes all aspects of emergency response including medical treatment, evacuations, and notification of local emergency response agencies and the public. 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 processes that would require a modified emergency response. The Scioto County, Ohio and the Greenup County, Kentucky LEPC's are the local emerge ncy response agencies with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety One major development has resulted from the implementation of the various elements of this accidental release program: modification of the tank car loading area. This modification will improve safety at the facility. This change is expected to occur by December 1999. 8. Conclusion MarkWest Hydrocarbon, Inc. has taken all necessary measures required by EPA and OSHA regulations to ensure the continued safe operations of the MarkWest - Siloam facility. The Risk Management Plan provided herein summarizes the active release prevention program that is currently in place at the facility. This risk management program illustrates MarkWest's commitment to employee, public, and environmental safety. In the unforeseeable event that a release does occur, MarkWest's emergency action plan combined with the assistance of the Scioto County, Ohio and the Greenup County, Kentucky LEPC's provide assurance that such an event will be successfully and safely mitigated. RISK MANAGEMENT PLAN MarkWest Hydrocarbon, Inc. Siloam Facility Route 23 South Shore - Greenup County, Kentucky May 26, 1999 Prepared by: Reviewed by: MARKWEST HYDROCARBON, INC. MARKWEST HYDROCARBON, INC. John Centofanti Ron Smith Area Environmental Specialist Plant Manager TABLE OF CONTENTS A. EXECUTIVE SUMMARY 1 1. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES .. 1 2. STATIONARY SOURCE AND REGULATED SUBSTANCE HANDLED . 1 3. WORST CASE AND ALTENATIVE RELEASE SCENARIOS 4 4. ACCIDENT RELEASE PREVENTION PROGRAM 5 a. PROCESS SAFETY INFORMATION 5 b. PROCESS HAZARD ANALYSIS 6 c. OPERATING PROCEDURES 6 d. TRAINING 6 e. MECHANICAL INTEGRITY 6 f. MANAGEMENT OF CHANGE 6 g. PRE-START UP REVIEWS 7 h. COMPLIANCE AUDITS 7 i. INCIDENT INVESTIGATION 7 j. EMPLOYEE PARTICIPATION 7 k. C ONTRACTORS 7 5. FIVE YEAR ACCIDENT HISTORY 8 6. EMERGENCY ACTION PLAN 8 7. PLANNED CHANGES TO IMPROVE SAFETY 8 8. CONCLUSION 8 RISK MANAGEMENT PLAN DATA ELEMENTS ATTACHMENT A MAPS AND RMP COMP DATA ATTACHMENT B Attachment A RISK MANAGEMENT PLAN DATA ELEMENTS Attachment B MAPS AND RMP COMP DATA Page 8 |