Schaefferstown Facility - Executive Summary
KOCH HYDROCARBON COMPANY |
THE RISK MANAGEMENT PLAN (RMPlan)
Introduction and Policies
Under the Koch Environmental Excellence Program (KEEP) at Koch Industries, Inc., we are committed to being associated with unmatched environmental performance as measured by our employees, customers, regulators, and the public. Our KEEP management philosophy goals are achieved by the personal commitments of our employees and contractors, and by open communication with our employees, customers, neighbors, and with regulators. The accidental release prevention and emergency response programs we have at our facilities are part of the high standards we strive for through KEEP. Our high standards are achieved by operating in compliance with all required environmental permits and regulations, by operating and maintaining our assets in such a manner that any unpermitted release will be unintentional and acknowledged as unaccepta
ble, by remedying any shortcomings found during regular audits of our facilities, and by reporting promptly to regulators any shortcomings found during the course of our audits as required by law.
The Schaefferstown Facility is one of many propane terminal and storage facilities operated by Koch Hydrocarbon Company (Koch). Propane and Ethyl Mercaptan are the only flammable substances regulated under the Risk Management Program (RMP) that are present at the Schaefferstown Facility. There are no toxic substances present at the site. The facility is classified as Program Level 3 under the regulation. At the facility, we receive propane via pipeline and tanker trucks. The received propane is dehydrated and stored in pressure vessels. From these pressure vessels, propane can be loaded directly into tanker trucks for distribution or sent to cryogenic storage tanks for storage. For cryogenic storage, propane is cooled in a refrigeration system and sent to two cryogenic tanks for stora
ge at -44o F and less than 14 inches of water column. The purpose of this Risk Management Plan (RMPlan) is to provide information about our propane operations at the facility, our programs to prevent accidental chemical releases, our emergency response plans in case an accidental release should occur, our 5 year accident history, and our planned changes to improve safety at the facility.
Worst Case and Alternative Release Scenarios
As specified by the U. S. Environmental Protection Agency (EPA) RMP Regulations, our worst case release scenario for flammables would be the loss of all of the propane in our largest vessel causing a vapor cloud explosion. In the case of the Schaefferstown Facility, this would involve our 10,300,000 gallon cryogenic propane tank. Such a scenario is highly unlikely, however, using the EPA Offsite Consequence Analysis (OCA) methods, the distance that the resulting vapor cloud explosion could cause an overpressure of 1 psi would be approximately 2.8 miles
. An overpressure of 1 psi is EPA's threshold for measurable impacts. Although we have numerous controls to prevent such releases (high level alarms, emergency shutdown and others) and to manage their consequences, no credit for any controls or mitigation measures was taken into account when evaluating this scenario. The alternative release scenario, characterized as a more likely scenario that would involve offsite damage, is calculated to reach approximately 0.3 miles (1,600 feet) from the release point. This distance calculation is also based on the EPA OCA methods which are known to overpredict any potential release from such a scenario. Once again no credit for any controls or mitigation measures was taken into account when evaluating this alternative release scenario. We selected the alternative release scenario based on a power outage at the facility and release of propane vapor from the cryo tank relief valve. The relief valve ensures that the entire tank does not ruptur
e and only a controllable release results. We have active mitigation measures in place to greatly reduce the chance that such an event could ever occur. Most important of these is a flare system which would burn off the propane vapor. Only when the capacity of the flare is exceeded would there be a release of vapor to the atmosphere. The presence of active mitigation measures serves to either prevent this scenario from occurring or minimize its impact if it does occur. . We have discussed these potential oleum releases with our employees and with local emergency response officials in Lebanon County, thereby further reducing the possibility of any impact on the public.
The Schaefferstown Facility has been operating under the strict guidelines of the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) Program since 1992. Our ongoing analysis of the potential hazards of our process, detailed training of our employees, and consta
nt emphasis on safety have helped us avoid any serious accidents over the last 5 years. Part of this program has also involved identifying and taking steps to avoid potential accidental chemical releases. A few examples of the additional prevention features implemented at this facility include:
7 We provided emergency shutdown devices at thirteen locations throughout the facility in order to shutdown the entire facility during emergency situations.
7 We provided high and high high level alarms on all our storage tanks and bullets in order to prevent overfilling.
7 We installed a fire water system at the facility which is designed to cool the tanks in the event of a fire.
7 We installed a hydrocarbon gas detection system consisting of 48 gas detectors located throughout the facility. The hydrocarbon gas detection system will sound an alarm at low gas concentrations and will trigger emergency shutdown system at high gas concentrations.
7 We installed a fire detection system consistin
g of six fire-eyes which will trigger emergency shutdown system when activated.
7 We provided reverse check valves on hot bullets to prevent overfill and excess flow valves to stop flow in the event of a pipeline rupture or break.
7 We provided an emergency generator at the facility in order to operate the process control system and the fire protection system even during power failure.
These safeguards as well as the vigilance of our trained employees have helped us operate safely at this facility since we acquired it in 1992.
Five Year Accident History
No incident having resulting in offsite impacts or onsite injuries from a propane release has occurred at the Schaefferstown Facility within the last five years. Although we take pride in that record, we also place daily emphasis on our prevention and safety programs to ensure this record continues.
Emergency Response Program
Any emergency response necessary for the Schaefferstown Facility is coordinated with the Sch
aefferstown Fire Department, the Lebanon County Police Department, the Lebanon County Emergency Management Agency, and the Lebanon County Emergency Medical Services and as appropriate with the Pennsylvania State Highway Patrol, the Texas Eastern Pipeline, and Buckeye Pipeline. The Schaefferstown Facility Manager is responsible for coordinating all emergency actions. A specific Emergency Response Plan for the facility is in place and that plan has been coordinated with local officials, along with evacuation procedures, regular drilling, and training. Our Emergency Response Program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations.
Planned Changes to Improve Safety
Diligent compliance with our RMP Prevention Program forms the framework on which we will continue to improve the level of safety at the Schaefferstown Facility. Some of the key components of the safety improvements we expect
to achieve are as follows:
7 The Management of Change provisions ensure that we consider the potential safety and health impacts of any change we make to process chemicals, technology, equipment or procedures.
7 The Process Hazard Analysis (PHA) provisions serve as a tool to ensure continual evaluation of potential hazards, thereby leading to continual improvements in our safety standards.
7 The Mechanical Integrity provisions ensure that process equipment and instrumentation are designed, constructed, installed and maintained to minimize the risk of hazardous releases, thereby serving as an integral part of our safety program.
7 Internal and third party compliance audits will ensure we maintain and increase our level of safety protection.
7 An ongoing dialogue with the Lebanon County Emergency Management Director or his designate will ensure a constant state of readiness to respond to any potential emergencies, as well as a means to implement improvements as the need develops. In t
his way, we shall bolster our strong commitment to the safety of our workers and the community.
We encourage all interested citizens or community organizations to contact the Lebanon County Emergency Management Director for the latest information on emergency response for the county. We plan to diligently integrate our response capabilities and personnel with those of the county on an ongoing basis.