Hidalgo Terminal - Executive Summary
Coastal States Crude Gathering Company |
RMP Executive Summary
1. Accidental Release Prevention and Emergency Response Policies
Coastal States Crude Gathering Company is strongly committed to employee, public and environmental safety. This commitment is demonstrated 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.
2. The Stationary Source and the Regulated Substances Handled
Our facility's primary activities encompass the loading of propane and butane product. We have 2 regulated substances present at our facility. These substances include butane and propane which are loaded into trucks and sold as commercial and residential fuels.
3. The Worst Case Release Scenario(s) and the Alternative Release Scena
rio(s), including administrative controls and mitigation measures to limit the distances for each reported scenario
To perform the required off-site consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations. The following paragraphs provide details of the chosen scenarios.
The worst case release scenario submitted for Program 2 flammable substances as a class involves a catastrophic release from our truck product loading facility. In this scenario 253,618 lb. of Propane is released. The release quantity has included 100% of the maximum capacity of the source by a system of administrative controls. 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, the calculated distance of 0.51 miles is obtained corresponding to an endpoint of 1 psi overpressure.
An additional worst case
release scenario for Program 2 flammables, involving a catastrophic release from our truck product loading facility, is also included in the RMP. In this scenario 126,809 lb. of Butane is released. The release quantity has been limited to 100% of the maximum capacity of the source by a system of administrative controls. 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, the calculated distance of 0.40 miles is obtained corresponding to an endpoint of 1 psi overpressure.
The alternative release scenario submitted for Program 2 flammable substances involves a release from our truck product loading facility. The release is assumed to result in a Vapor Cloud Explosion. The scenario involves the release of 1,512 lb. of Propane released in approximately 30 seconds. This time element is the conservative estimation of time
an operator would incur in recognizing the problem and initiating an emergency shutdown (ESD). Passive mitigation controls such as fire monitors and gas detection are taken into account to calculate the scenario. Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 psi overpressure is 0.06 miles.
4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out 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
Hidalgo Terminal maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes.
Process Hazard Analysis
Our facility conducts comprehensive studies to ensure that
hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is a "What-If Checklist". The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of 3 years. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 03/20/2000.
For the purposes of safely conducting activities within our covered processes, Hidalgo Terminal maintains written operating 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 processes.
Hidalgo Terminal has a training program in place to ensu
re that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every 3 years and more frequently as needed.
Hidalgo Terminal carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; 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. 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 Hidalgo Terminal to manage changes in process chemicals, technology, equipment and procedures. The most recent rev
iew/revision of maintenance procedures was performed on 03/20/2000. 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-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Hidalgo Terminal. The most recent review was performed on 3/10/2000. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation.
Hidalgo Terminal conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent compliance audit was conducted on 03/20/2000. These audits are carried out at least every 3 years and any corrective actions required a
s a result of the audits are undertaken in a safe and prompt manner.
Hidalgo Terminal promptly 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 to prevent the release from reoccurring. All reports are retained for a minimum of 5 years.
Hidalgo Terminal truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular.
On occasion, our company hires contractors to conduct speciali
zed maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Hidalgo Terminal has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur.
5. Five-year Accident History
Hidalgo Terminal is a new installation with stringent release prevention policies. To date, no accidents or hazardous releases have occurred.
6. Emergency Response Plan
Hidalgo Terminal carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas.
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 our processes that would require a modified emergency response.
Hidalgo County Fire Department is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified.
7. Planned Changes to Improve Safety
No new developments for improving safety at this time. The Coastal States Crude Gathering Company is continually evaluating the needs of its employees and improving safety. All information and recommendations related to environmental, health and safety have been incorporated during the design, construction and training phases.