GATX Argo Terminal - Executive Summary

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Introduction 
 
Facilities that use or store more than 15,000 lbs. of vinyl acetate or cyclohexylamine are required to prepare and submit to US EPA a Risk Management Program (RMP).  The RMP consists of several elements, including an evaluation of potential accident scenarios and a comprehensive program to prevent accidental releases of regulated chemicals.  
 
The RMP summarizes the management, administrative, procedural, and technological controls that work together to minimize the risk to the community of hazardous chemical releases.  The RMP includes the following information: 
 
7 Introduction; 
7 Facility identification and regulated substances covered processes; 
7 Policies to protect health, environment, and safety; 
7 Hazard Assessment; 
7 Prevention Program; 
7 Five-Year Accident History; 
7 Emergency Response Plan; and 
7 Planned Changes to improve safety 
 
Facility Identification and Regulated Substances 
 
The GATX Argo Terminal is a Public "For-hire" Bulk Liquid Storage Terminal, approxim 
ately 145 acres in area located approximately 15 miles southwest of the City of Chicago.  GATX Terminals Corporation has owned and operated the Argo Terminal since its inception in 1951.  The Terminal is bounded by the Chicago Sanitary and Ship Canal to the West, Corn Products Corporation to the north, Archer Avenue to the East, and the Shell Oil Terminal and the Van Waters & Rogers Distribution Facility to the South. Bedford Park Fire Station Number 1 has been constructed at the entrance to the Argo Terminal.  The Terminal provides tank storage for liquid chemicals, petroleum and food grade products and raw materials owned by others on a "contract" basis.  Presently 228 permitted aboveground storage tanks are available for storage and distribution of customer products, or for support activities.  Materials are received at the Terminal by tank trucks, rail cars and barge.   
 
Of the 228 permitted aboveground storage tanks, three tanks and associated equipment are covered by the RMP regu 
lation.  These tanks are Tank 5-15 (storage of vinyl acetate), Tank UC-24 (storage of vinyl acetate), and Tank C-11 (storage of cyclohexylamine). 
 
Policies to Protect Health, Safety and the Environment 
 
Risk management and safety are important concerns at GATX.  This RMP formalizes and documents these activities.  GATX is committed to conducting its operations in a safe and responsible manner and to reducing risks to human health and the environment. 
 
Prevention Program  
 
An Accidental Release Prevention Program is in place to minimize the risk of hazardous chemical releases in accordance with the EPA Risk Management Program requirements (40 CFR 68). This prevention program covers those processes that handle regulated substances above the threshold amount.  The prevention program provides a structured approach to preventing accidents. Some of the specific activities in the prevention program include: 
 
7 Process safety information is accessible at all times. 
7 A hazard review was conduc 
ted as part of the preparations for RMP compliance. 
7 Written operating procedures are used for training and guiding the work of operators. 
7 Training is provided to all employees that operate the system. 
7 A program is in place to properly maintain the system and equipment. 
7 Incidents are investigated and actions are taken as part of a continuous improvement effort. 
7 Routine audits are conducted to assure that safe practices are being followed. 
 
The processes at the facility subject to the Risk Management Program are designed with extensive safeguards to protect against the accidental release of a hazardous material. Examples of safety equipment in place include pressure relief devices, and foam fire suppressant systems for the tanks. 
 
In addition, process operators receive extensive training in the safe operation of the process, and are required to follow detailed operating procedures to help ensure safety.  GATX also has implemented a comprehensive maintenance program to monitor t 
he physical condition of process equipment, and replace or repair equipment before it fails. 
 
In the unlikely event of a spill or release involving a hazardous material, GATX has developed an emergency response plan providing procedures to be followed to minimize the potential impacts of a fire from the facility. In the event of a release, GATX will call the Bedford Park Fire Department located at the facility boundary. 
 
Hazard Evaluation 
 
Under the EPA regulations, GATX is required to evaluate the potential consequences of a worst case release and various alternate release scenarios.  The following paragraphs provide a description of the worst case and alternate scenarios for the GATX Argo Terminal.  
 
The RMP regulations define a worst-case release as "the release of the largest quantity of a regulated substance from a vessel or process line failure that results in the greatest distance to an endpoint defined in Sections 68.22 (a)" (40 CFR 68.3). The worst-case release scenario for t 
oxic liquids assumes that the total quantity in a vessel is spilled instantaneously onto a flat non-absorbing surface to form a pool.  Passive mitigation systems, such as secondary containment, are taken into account in the consequence analysis.  The release rate to air is estimated as the rate of evaporation from the pool of spilled toxic liquid.   Thus, for the GATX Argo Terminal it is assumed that 188,000-gallons (1,500,000 lbs.) of vinyl acetate is released instantaneously to the surrounding secondary containment area. The evaporation rate was then determined using CHARM to determine the distance to endpoint.  The distance to endpoint extends beyond the property boundary. 
 
Although GATX recognizes the maximum potential impacts resulting from a release of vinyl acetate and/or cyclohexylamine, it believes this scenario to be unlikely.  GATX has implemented extensive safeguards and procedures to prevent such a release. 
 
An alternative release scenario (ARS) represents an event that is 
more probable than the worst-case scenario.  The Chemical Accident Prevention Program requires the facility to analyze at least one alternate release scenarios for each toxic substance at a facility.   
 
At GATX Argo Terminal, Tanks 5-15 and UC-24 store vinyl acetate while Tank C-11 stores cyclohexylamine.  Radian chose to evaluate an alternate release involving a hose rupture while pumping to a tank truck. This scenario involves a rupture of the transfer hose loading rack to the truck, allowing the chemical to pump and spill for 5 minutes. The pumping rate is assumed to be 400 gallons per minute for tank 5-15 and 300 gallons per minute for Tank C-11 and UC-24.  Because the pumping capacity of Tank 5-15 is greater than the pumping capacity of UC-24 and since both store vinyl acetate, Radian chose to evaluate the alternate release from Tank 5-15 for vinyl acetate and Tank C-11 for cyclohexylamine.  The hose associated with these tanks are assumed to be 30 feet long and four inches in di 
ameter.  Radian then used the CHARM model to determine the distance to the toxic endpoint for these tanks.  The distance to endpoint extends beyond the property boundary. 
 
Five-Year Accident History 
 
The RMP regulations require facilities to compile a five-year accident history. This is defined as "all accidental releases from covered processes that resulted in deaths, injuries, or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage" (40 CFR 68.42).  
 
On October 29, 1996 at 2334, GATX Argo Terminal experienced a release of vinyl acetate, a listed RMP chemical.  During a severe thunderstorm, heavy winds knocked a piece of equipment from the roof of a nearby tank, resulting in a ruptured pipe on Tank 5-16 which at the time was used to store vinyl acetate.  An estimated 9,000 gallons of vinyl acetate was released to the secondary containment area.  Because of the severe weather, the secondary c 
ontainment drains had intentionally been left open to prevent flooding of the containment area.  As a result, approximately 3,700 gallons (29,000 lbs.) of vinyl acetate was discharged to the Metropolitan Water Reclamation District (MDRD) sanitary sewer system. No material was discharged to a waterway or over land. The discharge did not result in any on site or offsite deaths or injuries, evacuations, or sheltering in place. MWRD has not advised GATX of any problems at their treatment facility that resulted from this release.  
 
Following this release, GATX Argo Terminal implemented  enhanced tank inspection procedures and also a policy to ensure all equipment on tanks is properly secured.  GATX has not had any accidents that meet the above criteria since this date.   
 
Emergency Response Plan 
 
The RMP regulations require that "response actions be coordinated with local emergency planning and response agencies" (40 CFR 68.12(b)(3)).   Emergency response activities at GATX Argo Terminal ar 
e coordinated with the Cook County LEPC and Bedford Park Fire Department. 
 
In the event additional assistance is required, Bedford Park Fire Department will be notified.  In the event release quantities exceed reportable quantities, GATX Argo Terminal will notify the appropriate agencies. 
 
Planned Changes to Improve Safety 
 
Safety and Emergency Preparedness is a part of the GATX activities.  Exposure risks to employees and the public have been minimized through ongoing inspections and regulatory requirements.  At this time, no further improvements have been identified. 
 
Chemical-Specific Safety 
 
Chemical-Specific Safety procedures are maintained in the Process Safety Management manual maintained at the Union Carbide building and in the Accidental Release Prevention manual maintained in the Environmental, Health and Safety Coordinator's office.
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