Martin Gas Sales, Inc. - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

Martin Gas Sales, Inc. 
Rail Terminal 
Mont Belvieu, Texas 
Accidental release prevention and emergency response policies  
At the Martin Gas Sales, Inc. Rail Terminal facility, we handle propylene, which is considered a hazardous flammable gas by U.S. Environmental Protection Agency (EPA).  It is necessary to observe certain safety precautions in handling propylene 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 propylene 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 Gas Sales, Inc. are strongly committed to employee, public, and environmental safety.  This commitment is demonstrat 
ed 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.  Unforeseeably, if such a release does occur, we are completely coordinated with Mutual Aid Mont Belvieu which provides highly trained emergency response personnel to control and mitigate the effects of the release.  
Facility description and regulated substances handled  
The Martin Gas Sales, Inc. Mont Belvieu Rail Terminal facility stores propylene in two 30,000-gallon storage tanks.  The maximum amount of propylene stored at the facility is administratively limited to 80% of the facility capacity.  Propylene is delivered to the Rail Terminal facility via rail cars and is transferred from the facility via pipeline.  The pipeline runs between the Martin Rail Terminal fa 
cility and a Diamond Shamrock gas processing facility.  The largest rail car typically unloaded at the Rail Terminal facility has a maximum capacity of 34,000 gallons.  Access to the site is restricted to authorized facility employees, authorized management personnel, and authorized contractors.  
The regulated substance handled at our Rail Terminal facility is propylene.  The maximum quantity of propylene that can be stored at this facility is 400,000 pounds.  
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 our 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 release s 
cenario 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 Gas Sales, Inc. has incorporated a company policy that limits the maximum filling capacity of all propylene storage tanks to 80% at 60:F.  Therefore, our worst-case release scenario would result in a release of 140,000 pounds of propylene from a 34,000-gallon rail car. 
To evaluate the worst-case release scenario, we have utilized RMP*Comp, the EPA recommended software.  Based on 140,000 pounds of propylene released, the distance the affects of a vapor cloud explosion is expected to have no serious harm to the general public is 0.4-mile from the location of the rail car. 
The EPA states an alternative release scenario as a release that is more likely to occur than the worst-case scenario an 
d 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. The release would be limited to the amount of propylene in the transfer line, the loading rack manifold, and the iron piping between the rail car and the storage tanks.  Excess flow valves at the storage tank and rail car function to stop the flow of propylene out of the storage tank and rail car.  Therefore, the propylene released would be limited to 8,200 pounds of propylene, the amount in the transfer hose and iron piping. 
The scenario assumes the entire quantity of propylene in the transfer hose and iron piping is released.  RMP*Comp estimates the distance endpoint for the release of 8,200 pounds of propylene as 0.1-mile.  The hazard endpoint extends offsite. 
The general accidental release prevention program and the specific prevention steps 
Rail Terminal 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 Gas Sales, Inc. maintains a detailed record of safety information that describes the chemical hazards, operating parameters, and equipment designs associated with the propylene process. 
   Process Hazard Analysis 
Our facility conducts comprehensive studies to ensure that the hazards associated with our propylene process are identified and controlled efficiently.  The methodology used to carry out these analyses is a "What if" checklist.  The studies are under 
taken 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 propylene process, Martin Gas Sales, 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 process. 
Martin Gas Sales, Inc. has a comprehensive training program to ensure employees are competent in the operations and procedures associated with the propylene process.  
   Mechanical Integrity 
The Rail Terminal facility carries out highly documented maintenance checks on process equipment to  
ensure proper operations.  Process equipment examined by these checks include; pressure vessels, storage tanks, 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.  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 Gas Sales, 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 Gas Sales, Inc.  The reviews are condu 
cted to confirm that construction, equipment, operating, and maintenance procedures are suitable for safe startup prior to placing equipment into operations. 
    Compliance Audit 
The Rail Terminal facility 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 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 Gas Sales, Inc. promptly investigates any incident that resulted in, or could reasonably result in a catastrophic release of propylene.  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 Gas Sales, 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.   
Occasionally, Martin Gas Sales, 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 process.  Contractors are also informed of all the procedures for emergency response should an accidental release of a propylene occur. 
Five-year accident history 
The Martin Gas Sales, Inc. Rail Terminal facility has had 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 propylene 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 Rail Terminal facility has a written emergency response program, in accordance with OSHA standard 29 CFR 1910.119.  Additionally, the state and local authorities have been provided the emergency planning and community right-to-know information as required under SARA Title III (EPCRA). The program includes all aspects 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 Rail Terminal facility.  Periodic evaluations are preformed to assess  the maintenance of safe conditions.  There are no additional specific propylene safety recommendations for implementation at this time.
Click to return to beginning