VOPAK TERMINAL GALENA PARK INC. - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMEREGNCY RESPONSE POLICIES Vopak Terminal Galena Park Inc. is committed to operating and maintasining our proccesses in a safe and responsible maner. We use combination of accidental release prevention and emergency response planning programs to help ensure the safety of our employees, the public and protection of the environment. This document provides a brief overview of the comprehensive risk management activities we have edesigened and implemented. This includes the following. A description of our facility and uses of EPA's RMP regulated substances at our facility. A summary of the results of our assessment of the potential offsite consequences from accidental chemical releases. An overview of our accidental release prevention programs. A five year history of accidental releases for substances regulated by EPA's RMP rule. An overview of our emergency response program. An overview of planned improvements at the facility to help prevent accidenta l chemical releases and therefore adversely affecting our employees, the public and the environment. STATIONARY SOURCE AND REGULATED SUBSTANCES VopaK Terminal Galena Park Inc. is a for-hire liquid storage terminal and drumming warehouse facility. Chemicals and refined petroleum products represent the majority of the chemicals stored, drummed, handled and transported in this facility. Chemicals are received into and transported from the facility via ship, barge, tank truck and tank car. At this time the facility plans to drum and store one EPA RMP regulated chemical (Ethylenediamine, CAS # 107-15-3). Additions: None KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule requires that we provide information about the worst-case scenario(s) and alternative scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures that limit the exposure distances for the scenarios. Worst- case release scenario - regulated toxic substance The worst-case release scenario for a regulated toxic substance is the failure of a 4 inch block valve at the railcar loadind spot at the drumming warehouse. The total volume (30,000 gallons) is released to the ground. The scenario assumes a 60 minute release time with worst-case weather conditions. The distance to the toxic endpoint according to the EPA guidelines is 1.1 miles, before dispersing enough to no longer pose a hazard to the public. Although controls and mitigation measures are in place to prevent such a ctatstrophe, no credit for passive mitigation was taken into accounnt when formulating this worst-case scenario. Alternative release scenario - regulated toxic substance The alternative release scenario for a regulated toxic substance involves the development of 0.25 inch hole in a flexible transfer hose after unloading 10 percent of the volume (therefore less 3,000 gallons). The remaining volume (27,000 gallons) is lost to the ground in a contained area. The leak is found and the operation is shutdown in 5 minutes. The distance to the the toxic endpoint accordinng to EPA guidelines is 0.1 miles, before dispersing enough to no longer pose a hazard to the public. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL SPECEFIC PRVEVNTION STEPS We take a systematic, proactive approach to the prevention of accidental releases of hazardous substances. Our management system addresses each each key feature of a successful prevention program. The program includes the following. Process safety information Process hazard analysis Operarting procedures Training Mechanical integrity Management of change Pre-startup review Compliance audits Incident investigation Employee participation Hot work permitting These individual elements of our prevention program are utilized to prevent accidental chemical releases. Our company and our employees are committed to the standards that these management systems establ ish for the way we do business. With our specific accountabilities and controls to ensure that we are meeting our own high standards for accidental chemical release prevention. FIVE YEAR ACCIDENT HISTORY There have been no releases in the past five years of any EPA RMP regulated substances. EMERGENCY RESPONSE PROGRAM We maintain various contingency plans which address federal, state and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting our employees, the public and the environment during emergencies. Furthermore, we coordinate our plans with the community emergency response plan. We are using this information to help ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. Our accidental release prevention programs and our contingency planning efforts help us to effectively manage the hazards that are presented to our e mployees, the public and the environment. PLANNED CHANGES TO IMPROVE SAFETY The following is alist of improvements that are proposed to be implemented at the facility to help prevent and/or to help better respond to accidental releases. |