LBC PetroUnited/ Bayport Terminal - Executive Summary |
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LBC PetroUnited Inc. Bayport Terminal, Seabrook, Texas ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At LBC PetroUnited Inc. we are committed to operating and maintaining our terminal in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees, our neighbors, and protection of the environment. This document provides a brief overview of the comprehensive risk management activities at LBC PetroUnited Inc. including: A description of our facility and the storage and transfer of regulated chemicals. A summary of our potiential offsite consequences from accidental releases from regulated chemicals. An overview of our accidental release prevention program. A five year accidental release history for regulated chemicals. An overview of our emergency response program. An overview of planned and implemented improvements to help prevent accidental releases of hazardous chemicals. STATIONARY SOURCE AND REGULATED CHEMICALS LBC PetroUnited Inc. is a public bulk liquid storage and transfer facility. We are not a manufacturing or processing plant. Chemicals, oils, and petroleum products are stored and transferred via tank trucks, rail cars, barges, and ships. There is a number of regulated toxic and flammable chemicals which we are permitted (facility air permit based on health effects) to store but do not presently have on site. Therefore we are using predictive filing to include some regulated chemicals that are not on site but could be in the future. Presently there are two toxic and two flammable chemicals on site. The toxic chemicals are Propylene Oxide and Vinyl Acetate Monomer. The flammable chemicals are Isopentane and Isobutylene which are both covered by OSHA's Process Safety Management regulations. OFFSITE CONSEQUENCE ANALYSIS SCENARIOS The worse-case scenario for the toxic chemicals is Acrylonitrile (predictive filing / not on site) and the worse-case scenario for the flammable chemicals is isopentane. The alternate release scenarios for the remaining toxic chemicals are for Propylene Oxide, Vinyl Acetate Monomer, Allyl Alcohol, Chloroform, Cyclohexylamine, Ethylenediamine and Titanium Tetrachloride. All worse-case scenarios are releases from a storage tank. The potiential offsite consequences resulted in effecting public receptors and a environmental receptor. The distances are limited by the fact that all of our storage tanks are in diked areas, personnel inspect the diked areas throughout each shift and storage tanks are never filled to their maximum capacity. All alternate release scenarios are releases due to a hose failure. The potential off-site consequences resulted in effecting our industrial neighbors but not any environmental receptors. The distances are limited by the fact that all transfer operations take place inside a contained area and operators are in attendance to secure and mitigate a rele ase. We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM Our accidental release prevention program ia a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management system addresses each of the key features of successful prevention programs including: Process safety information Process hazard analysis Operating Procedures Training Mechanical Integrity Pre-startup review Compliance audits Incident investigation Employee participation Hot work permit Contractors Our company and our employees are committed to the standard that these management systems set for the way we do business and those accountabilities that ensure we are meeting our own high standards for accident prevention. FIVE YEAR ACCIDENT HISTORY FOR REGULATED CHEMICALS Based on the RMP rule we have not experienced a regul ated chemical release in the past five years. However we did experience a minor release of a regulated chemical but with no onsite or offsite effects. We keep records for all significant accidental chemical releases that occur at our terminal. EMERGENCY RESPONSE PROGRAM Our emergency response plan is an integrated contingency plan, which consolidates various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting employees, the public, and the environment during emergency situations. We coordinate our plan with the Bay Area LEPC community response plan. PLANNED AND IMPLEMENTED CHANGES TO IMPROVE SAFETY The following is a list of planned and implemented improvements to minimize accidental releases thus improving safety: revised standard operating procedures, set minimum standards for equipment used in the storage and transfer of chemicals, revised maintenance procedures, r evised tank truck and rail car preload inspection criteria, and improved training programs. |