Equilon Enterprises LLC - Executive Summary |
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A. Equilon Enterprises LLC is committed to the safety of its workers, the public and the environment. Its accidental release policy is an integrated approach, involving employee participation, management practices, written procedures and training. Equilon has created a comprehensive butane accident prevention program considering all aspects of process operation and maintenance. It has also developed a written emergency action plan and coordinated these efforts with local emergency responders (Detroit Fire Department). B. Equilon operates a petroleum terminal in Detroit, Michigan. A 60,000-gallon butane tank has been added to the site for the purpose of blending butane with petroleum products. The maximum amount of butane in the tank at any one time is 261,900 pounds. There are emergency shutdown systems and pressure relief valves on the tank. C. The offsite consequence analysis considers a worst-case and an alternative scenario involving a butane release and subsequent vapor cl oud explosion. The RMP rule says the explosion endpoint is 1 psia overpressure. EPA's RMP*Comp software was used to determine distances to explosion endpoint for each scenario. The worst-case scenario involves the failure of the 60,000-gallon tank holding approximately 261,900 lb. of butane. It assumes all of the butane is released and ignited. No passive mitigation is considered. RMP*Comp gives a 0.5-mile distance to explosion endpoint. This clearly extends offsite and there are public receptors within the distance to the endpoint. Equilon has many safeguards in place, which makes this scenario very unlikely, including an aggressive maintenance and inspection program, and computer-controlled emergency shut-down for all valves on the butane tank. The alternative scenario is suggested in the RMP guidance and is the only scenario considered to have any likelihood. It involves a hose rupture caused by a pull-away. A pull-away can occur if the driver fails to remove the hoses be tween the storage tank and the transfer vehicle before moving the vehicle. In this scenario, the failure involves a 25-foot length of unloading hose, 4" in diameter. The active mitigation devices are assumed to work as designed, limiting the release to the contents of the hose. The release leads to a vapor cloud explosion (1-psi endpoint). The quantity released is 79 pounds. The distance to endpoint is 106 feet (0.02 miles). The nearest property boundary is 10 feet from the tank, so the endpoint distance extends offsite. However, there are no public receptors within this distance. D. Equilon complies with the Risk Management Program and OSHA Process Safety Management rules. Taken together, the components of its prevention program are designed to ensure that: - Process equipment is in proper working order - Employees are trained in safety and are aware of correct operating procedures - Changes to the process or personnel do not result in accidents - The hazards of the process are identified and addressed In addition, Equilon incorporates the following National Fire Protection Association guidance: NFPA-58 (Liquified Petroleum Gas Code), NFPA-30 (Flammable and Combustible Liquids Code), and NFPA-20 (National Electrical Code). The ASME Boiler and Pressure Vessel Code is also followed. E. No significant accidental release of butane has occurred at this facility in the past five years. F. For the purposes of the RMP Rule emergency response provisions, Equilon can be considered a non-responding facility. Equilon has implemented an emergency action plan in accordance with the OSHA Standard 1910.120 which includes the procedures for evacuation, medical care, reporting, critical equipment operation, alarm systems, severe weather and handling small spills. In addition, Equilon is in contact with its LEPC and is included in the community emergency response plan prepared under EPCRA. Equilon has compiled a list of emergency contacts and coordinates emergency pl anning with the local fire department, since they would be the emergency responders. G. Equilon has ongoing commitment to all elements of its Risk Management Program and is always striving to improve safety at the site. However, there are no additional activities beyond the safety and prevention program underway at this time. |