Matlack Bulk Intermodal Services (dba) MBIS - Executive Summary |
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General Executive Summary for Matlack Bulk Intermodal Services MBIS 1. Accidental Release Prevention and Emergency Response Policies We at MBIS are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as 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. This site is a transfer facility located in Fairport Harbor, Ohio. This operation is dedicated to the storage of chemicals in rail cars and its transferring into tank trucks for regional distribution. 2. The Stationary Source and the Regulated Substances Handled We have one regulated substance present at our facility. This substance is Hydrofluoric Acid, 70% Solution. The maximum inventory of Hydrofluoric Acid, 70 Solution at our facility can be 680 ,000 pounds. This product is transported to MBIS in rail cars. These rail cars tanks are carbon steel pressure vessels protected with a rubber lining. The lining is a special formulation of elastomer to protect the carbon steel wall of the tank from direct contact with hydrofluoric acid and to help maintain the purity of the product. These vessels meet or exceed Department of Transportation (DOT 49 CFR 178) specifications for shipping HF70% and are widely accepted by the HF industry. 3. The Worst Case Release Scenario and the Alternative Release Scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario. To perform the required offsite consequence analysis for our facility, we have used RMP*Comp. The following paragraphs provide details of the chosen scenarios. Worse case scenario will be the loss of the entire contents of a rail car of hydrofluoric acid, 70% solution. The scenario was simulated as a liquid release and vap orization. The duration of the release and the atmospheric conditions used to determine the distance to the toxic endpoint were those recommended by EPA. The total weight of this loss would be 180,000 pounds of HF70%. This scenario would reach outside public receptors. The number of public receptors was estimated using Landview III, Environmental Mapping Software. The operations at this transloading facility are carried outdoors. There is no passive mitigation such as enclosures or dikes. Alternative release scenario will be the release of liquid hydrofluoric acid and vaporization during acid transfer operations from a rail car into a tank truck. The scenario would be a transfer hose failure. The hose would be 2 inches diameter and 30 feet long. The transfer flow rate for the acid from the railcar into the tank truck is approximately 150 gallons per minute. The release duration would be 2 minutes. Quantity of hydrofluoric acid 70% solution released on this scenario would be 3,200 poun ds. This scenario would have offsite consequences. No passive mitigation is available. An emergency shut off valve is installed and it will be considered active mitigation. The estimation of public receptors was done using Landview III, Environmental Mapping Software. 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 MBIS 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 conducted a comprehensive study to ensure that hazards associated with our process were identified and controlled effi ciently. The methodology used to carry out these analyses were checklist method and HAZOP. The studies were undertaken by a team of qualified personnel with expertise in engineering and process operations and will be revalidated at a regular interval of three years. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 06/01/1999. Operating Procedures For the purposes of safely conducting activities within our covered processes, MBIS 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. Training MBIS has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every year and more frequently as needed. Mechanical Integrity MBIS carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; chemical transfer hoses, manual operated shut off valves, emergency remote operated shutoff valves, piping systems, rupture disks 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. Compliance Audits MBIS 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 conduc ted on 06/14/1999. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation MBIS promptly would investigate any incident that could result in, or could reasonably result in a catastrophic release of a regulated substance. These investigations would be done to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports would be retained for a minimum of 5 years. Employee Participation MBIS 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 analy ses in particular. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. MBIS 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 MBIS has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan MBIS will notify the local emergency responders when there is a need for assistance during an emergency situation. We believe that the size of our operation does not allow to have a full size emergency response team. Therefo re we will focus on employee safety and adopt a policy as non-responding facility. MBIS will provide all necessary support and information regarding quantities and characteristics of our regulated substances to the Lake County LEPC to help plan the response to an emergency at this facility. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. The construction of a berm around the transloading is on of the major steps we want to take to improve safety at our facility. This change is expected to be implemented by 09/01/1999. |