Kinder Morgan Liquid Terminals, LLC - Executive Summary
1. Accidental release prevention and emergency response policies: |
In this Kinder Morgan Liquid Terminals, LLC ("Kinder Morgan") distribution facility, we handle Vinyl Acetate Monomer ("VAM") which is considered hazardous by EPA. The same properties that makes VAM valuable as a commodity also makes it necessary to observe certain safety precautions in handling VAM 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 upon the manner in which we handle VAM combined with the safety devices inherent in the design of this facility combined with the safe handling procedures that we use and the training of our personnel.
Our emergency response program is based upon the EPA, Coast Guard, DOT, OSHA and LEPC requirements. The emergency response plan includes procedures for n
otification of the local fire authority and notification of any potentially affected neighbors.
2. The stationary source and regulated substances handled.
?The primary purpose of this facility is to temporarily store, break bulk, and distribute VAM to both retail and wholesale customers. VAM is used as a raw material for manufacturing polyvinyl resins such as those used in latex paints, paper coating, adhesives, textile finishing, and safety glass interlayers. VAM is received by barge and stored in two 12,000 barrel storage tanks. VAM is distributed to customers by pipeline. This facility has equipment for unloading ships, barges, rail cars and tank trucks. Access to the site is restricted to authorized facility employees, authorized management personnel and authorized contractors.
?The regulated substance handled at this distribution facility is VAM.
3. The worst-case release scenario and the alternative release scenario, including administrative controls and mitigation measu
res to limit the distances for each reported scenario.
?Worst-Case Scenario - As defined by the EPA, the worst case scenario consists of one, 12,000 barrel tank releasing its total capacity in ten minutes. VAM would then fill the secondary containment, earthen dike, where all safety systems would fail and a low wind speed exists. This unlikely scenario could affect industrial neighbors and near residential neighbors.
?Alternative Scenario. - A "more likely" scenario would include the same 12,000 barrel tank with a 1" hole due to a cracked weld. One half of the tank's contents of VAM would be released into the diked area at 854 pounds per minute. If the "alternative release scenario" were to occur, all spill prevention and safety measures would be enforced. The release could affect near industrial neighbors before dispersing enough to no longer pose a hazard.
4. The general accidental release prevention program and the specific prevention steps.
This facility complies with EPA
's Accidental Release Prevention Rule and with all applicable state codes and regulations. This facility was designed and constructed in accordance with applicable API and NFPA standards. All of our employees have been thoroughly trained in accordance with 40 CFR 68.
5. Five-year accident history.
There have been no releases of Vinyl Acetate Monomer (VAM) in the past five years that have had an adverse impact on the community. There was one incident at the Pasadena Terminal that meets the EPA Risk Management Program (RMP) reporting requirements with respect to injuries involving the release of VAM:
9/6/96 - Two operators were splashed with VAM, while unhooking a hose from a barge. The operators were not following the correct procedures regarding the use of proper Personal Protective Equipment (PPE), and as a result VAM contacted their faces. One operator was treated for a halo affect of the eyes. The halo affect was temporary, and the operator fully recovered. Approximately
10 gallons of VAM was released.
6. The emergency response program.
This facility's emergency response program is based upon the requirements of the Environmental Protection Agency, United States Coast Guard, Department of Transportation, Occupational Safety and Health Administration and Local Emergency Planning Commission. The emergency response plan includes procedures for notification of the local fire and police authorities and notification of any potentially affected neighbors. This plan has been submitted to and approved by the respective regulatory agencies and is reviewed on an annual basis. The facility is subject to regular annual inspections by each of the aforementioned governmental agencies.
Additionally, to ensure that employees are adequately trained and prepared to respond to emergencies, they receive training in Hazardous Waste Operations and Emergency Response (HAZWOPER), Emergency Action and Fire Prevention, Accidental Release Prevention, Environmental Awarene
ss, and Terminal Safety Systems. Employees also attend fire school at Texas A&M University and HAZWOPER refresher training annually, and monthly drills.
Finally, the facility prepares for emergencies by conducting monthly Emergency Response Team drills, quarterly notification drills, semi-annual equipment deployment drills, annual tabletop exercises, and participates in area-wide drills that are conducted by governmental agencies.
7. Planned changes to improve safety.
This facility was constructed in 1953 and is in compliance with applicable governmental and industry standards. No changes are planned to upgrade the facility. GATX has a commitment to continuous improvement of our safety program. As such, periodic reviews of the affected programs will be conducted.