South Coast Terminals, L.P. - Executive Summary
South Coast Terminals - Strang Road Facility (SCT - SRF) |
Risk Management Plan - Executive Summary
1. EXECUTIVE SUMMARY
South Coast Terminals - Strang Road Facility (SCT - SRF) was started up during December 1998 and January 1999. At the time this RMP was submitted to the EPA, the plant was/is not fully operational. SCT - SRF receives bulk chemicals owned by their customers and then SCT drums the material into 55-gallon or less drums and/or containers. SCT - SRF is committed to operating in a manner that is safe for their workers, the public, and the environment. As part of this commitment, SCT - SRF has established a system to help ensure safe operation of the processes at this facility. One of the requirements of the RMP rule is to submit a risk management plan (RMPlan) describing the risk management program at SCT - SRF. This document is intended to satisfy the RMPlan requirements of the RMP rule and to provide the public with a description of the risk management program at SCT
1.1 Accidental Release Prevention and Emergency Response Policies
SCT - SRF is committed to the safety of their workers, the public, and to the preservation of the environment, through the prevention of accidental releases of hazardous substances. SCT - SRF implements reasonable controls to prevent foreseeable releases of hazardous substances. In the event of a significant accidental release, trained Emergency Response personnel and/or 3rd party emergency response contractors will respond to control and contain such releases. SCT - SRF evaluates each situation, evacuates workers as necessary, and contacts the local fire department and/or third party emergency response personnel to control and contain the release and to prevent and/or reduce the consequences of the release.
1.2 SCT - SRF and Regulated Substances
SCT - SRF handles, Toluene 2,4-diisocyanate a listed RMP Toxic Chemical in sufficient quantities to be covered by the RMP rule:
7 Toluene 2,4-diisocyanate is receiv
ed by bulk tank car or tank truck and drummed into 55-gallon drums for customers. The products are not owned by SCT-SRF, but provides a service to customers. The 55-gallon drums are then loaded onto a truck and shipped off-site.
SCT - SRF handles two listed flammable materials in sufficient quantities to be covered by the RMP rule:
7 SCT-SRF also receives bulk isopentane and pentane; both are listed RMP Flammable materials. Again, the materials are drummed as a service for customers.
As a result of the use of regulated substances at SCT - SRF, the following processes are covered by the RMP rule:
Drumming/Containerizing (Bulk chemicals into 55 gallon containers or less) and Storage of containers/drums. All are regulated under Program 2 of the EPA RMP rule.
Pentane --- 100,000 lbs. containerized/ drummed at a time and up to 195,000 lbs. stored
Isopentane --- 100,000 lbs. containerized/ drummed at a time and up to 160,000 lbs. stored
Toluene 2,4 diisocynate --- 400,000 lbs. conta
inerized/ drummed at a time and up to 1,000,000 lbs. stored
1.3 Offsite Consequence Analysis
SCT - SRF performed an off-site consequence analysis (OCA) to estimate the potential for an accidental release of a regulated substance to affect the public or the environment. The OCA consists of evaluating both worst-case scenarios (WCSs) and alternative release scenarios (ARSs). SCT - SRF does not expect a worst case release scenario to ever occur. An ARS represents a release that might occur during the lifetime of a facility like SCT - SRF. ARSs help the LEPC improve the community emergency response plan. We have shared that information with the LEPC and other organizations involved in emergency response activities. It is also available to the public. If you are interested in this information, please contact our RMP Coordinator at (713) 672-2401.
The main objective of performing the OCA is to determine the distance at which certain effects might occur to the public because of an acciden
tal release (called the endpoint distance). The following effects could occur at the endpoint distance. At distances less than the endpoint distance, the effects should be greater; at distances greater than the endpoint distance, the effects would be less.
Worst-case Release Scenario for Toxic Substances
The worst-case release scenario for toxic substances is the release of an entire contents of a tank car (195,000 lbs.) at the rail spur on-site of Toluene 2,4-diisocyanate (TDI). NOTE: There are no bulk chemical storage tanks located on-site. As stated above, SCT - SRF does not expect a worst case release scenario to ever occur. The computer modeling program used was RMP*Comp Ver. 1.06. The scenario is based on the following: the product is a liquid with a temperature of 75 degrees F, and with no mitigation measures, urban surrounding (many obstacles - this facility is in an industrial complex area), weather information was obtained by utilizing RMP*Comp defaults. Although there
are mitigation measures, such as deluge systems, the model was done with no mitigation measures to determine a worst case scenario that would include water service interruptions. The result in a release of TDI was calculated to be an estimated distance to toxic endpoint of 0.2 miles. Since this facility is located in an industrial area, the toxic cloud formed by the release would reach offsite public and/or environmental receptors of other industries nearby. The closest company to the facility that is within the 0.2 miles is Van Leer Containers. The Van Leer plant is not yet operational, but is expected to be operational the fourth quarter of 1999.
Worst-case Release Scenario for Flammable Substances
The worst-case release scenario for flammable substances is the release of the entire contents of a tank car. As stated above, SCT - SRF does not expect a worst case release scenario to ever occur. Again, the computer modeling program used was RMP*Comp Ver. 1.06. The scenario is
based on the following: the product is a liquid, the release type is a vapor cloud explosion, and with no mitigation measures, urban surrounding (many obstacles - this facility is in an industrial complex area), weather information was obtained by utilizing RMP*Comp defaults. Although there are mitigation measures, such as deluge systems, the model was done with no mitigation measures to determine a worst case scenario that would include water service interruptions. The result in a release of a flammable (Isopentane was used) was calculated to be an estimated distance to 1 psi overpressure (endpoint) of 0.5 miles. Since this facility is located in an industrial area, the toxic cloud formed by the release would reach offsite public and/or environmental receptors of other industries nearby. The closest company to the facility that is within the 0.5 miles is Van Leer Containers. The Van Leer plant is not yet operational, but is expected to be operational the fourth quarter of 1999.
Alternative Release Scenario for Toxic Substances
The ARS for TDI could be a rupture of a four-inch diameter liquid unloading line from the railcar to the drum filling cabinets. This scenario assumes a release duration of 10 minutes, initial operational flow rate of 100 gallons/minute, operational pipe pressure of 60 psi, and release rate of 33,400 lbs./minute, no mitigation measures, liquid temperature of 75 degrees F, with an estimated distance to toxic endpoint of 0.2 miles. Weather information was obtained from the RMP*Comp defaults.
Alternative Release Scenario for Flammable Substances
The ARS for flammables (Isopentane was used) could be a rupture of a three-inch diameter liquid unloading line from the railcar to the drum filling cabinets. This scenario assumes a release duration of 10 minutes, initial operational flow rate of 100 gallons/minute, no mitigation measures, operational pipe pressure of 60 psi, and release rate of 16,200 lbs./minute, and the release type modele
d was a pool fire. The calculated estimated distance of heat radiation (endpoint) is 0.4 miles. Weather information was obtained from the RMP*Comp defaults.
1.4 Accidental Release Prevention Program and Chemical-specific Prevention Steps
The following is a summary of the general accident prevention program in place at the SCT - SRF plant.
SCT - SRF encourages employees to participate in all facets of accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team. Employees have access to information created as part of the SCT - SRF plant accident prevention program. In addition, SCT - SRF has a number of initiatives under way that addresses employee safety issues. These initiatives include a Safety Committee to promote both process and personal safety. The team typically has members from various areas and other SCT
plant locations, including operations, maintenance, engineering, administration, and plant management.
Process Safety Information
SCT - SRF keeps a variety of documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design basis/configuration information.
Chemical-specific information, including exposure hazards and emergency response/exposure treatment considerations, is provided in material safety data sheets (MSDSs). For specific process areas, SCT - SRF has documented safety-related limits for specific process parameters (e.g., temperature, filling rates, compatibility, etc.) in PHA documentation. SCT - SRF ensures that the process is maintained within these limits by using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g. automated and manual shutdown
Process Hazard Analysis
SCT - SRF has established programs to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.
The PHA team findings and/or action items are forwarded to appropriate personnel. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. The final resolution of each finding is documented and retained.
These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and retained. Once again, the team findings are forwarded to appropriate personnel for consideration, and the final resolution of the findings is documented and retained.
SCT - SRF mai
ntains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, and (5) normal shutdown. These procedures can be used as a reference by experienced operators and provide a basis for consistent training of new operators. Procedures are periodically reviewed and annually certified as current and accurate. NOTE: At the time the EPA RMP was submitted, operating procedures were being written and revised for flammable materials.
To complement the written procedures for process operations, SCT - SRF has implemented a company-training program for employees involved in operating a process. New employees receive basic training in SCT - SRF plant operations if they are not already familiar with such operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrat
e (e.g. through skill demonstration) having adequate knowledge to perform the duties and task in a safe manner on their own, they can work independently.
SCT - SRF uses contractors to supplement its work force during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, SCT - SRF has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform SCT - SRF plant personnel of any hazards that they find during their work.
SCT - SRF has practices and procedures to maintain piping systems, vent systems, controls, and emergency shutdown systems in a safe operating condition. The basic aspects of this program include:
(1) conducting training, (2)
developing written procedures, (3) performing inspections, (4) correcting identified deficiencies, and (5) applying quality assurance measures.
Inspections and tests are performed to help ensure that equipment functions as intended, and to verify that equipment is within acceptable limits. If a deficiency is identified, employees or contractors (as appropriate) will correct the deficiency before placing the equipment back into service (if possible.)
Safe Work Practices
SCT - SRF has safe work practices in place to help ensure worker and process safety. Examples of these include (1) control of the entry/presence/exit of support personnel, (2) a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e. hot work), and (5) a permit and procedure to ensure that adequate prec
autions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely.
SCT - SRF investigates incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the facts and develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops recommendations to prevent a recurrence, and forwards these results to the HSE Department for filing recommendations are tracked until they are complete.
Compliance audits will be conducted at least every 3 years. Both hourly and management personnel may participate as audit team members and possibly a third-party consultant may be
hired to assist in the audit. The audit team develops findings that are forwarded to SCT General Manager, Operations Manager, and EHS Site Manager for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained.
Chemical-specific Prevention Steps
The processes at SCT - SRF have hazards that must be managed to ensure continued safe operation. The prevention program summarized previously is applied to all Program 2 EPA RMP -covered processes at SCT - SRF. Collectively these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failures and (2) human errors.
In addition to the accident prevention program activities, SCT - SRF has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of (mitigate)
a release. The following types of safety features are used in various processes:
7 There are alarms (visual and audible) built into the automated drum filling line and cabinets. There are also manual and automatic shut-offs.
7 Employees are within close proximity to any operations associated with taking bulk chemicals and drumming them into 55-gallon or less drums/containers.
7 Drumming cabinets vent to an oxidizer and/or carbon canisters to capture episodic releases and minimize vapors.
7 Manual and automated shutdown systems for specific process parameters (e.g. high level, high temperature, blower shutdown, etc.)
7 Curbing, diking, and/or spill pans to contain liquid releases
7 Power supply will hold 5-10 minutes of memory in automated operations. After 10 minutes, equipment will have to be re-set before restarting the operations.
7 Fire suppression and extinguishing systems
7 Personal protective equipment (
e.g., protective clothing, self-contained breathing apparatus)
1.5 Five-Year Accident History
No releases of TDI have occurred from SCT - SRF in the last five years that have resulted in deaths, injuries, or significant property damage on site, or known deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage off site.
1.6 Emergency Response Program
SCT - SRF coordinates emergency response procedures with the local fire department and LEPC. The EHS Site Manager and Environmental Technician are liaisons for communicating and attending meetings and drills on behalf of SCT - SRF and the LEPC and Fire Department. SCT - SRF workers will respond to minor events that do not have the potential for significant effect (e.g., small fires or small leaks). In the event of a larger fire or release, workers evacuate the area and contact the local fire department.
SCT - SRF has established a written emergency response plan that has been communicated to loc
al emergency response officials.
1.7 Planned Changes to Improve Safety
SCT - SRF strives to improve the safety of SCT - SRF processes through periodic safety reviews, the incident investigation program, and a program soliciting safety suggestions from the workers.
7 Update, finalized and implement operating and maintenance procedures, as the plant becomes fully operational.
7 Finalize design and install additional containment at the rail spurs.
7 Revisions to personnel training programs, including improving on emergency response training programs.