Morton Salt Company - Executive Summary |
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The Morton Salt facility in Newark, California, is required to develop and implement a Risk Management Program (RMP) for its storage of up to 110,880 pounds of propane in a single 30,000-gallon aboveground tank. The RMP is subject to Program 2 guidelines because the worst-case release scenario endpoint distance for the storage process exceeds the distance to the nearest public receptor, but the storage of propane does not meet the requirements for preparing a Process Safety Management (PSM) Plan under U.S. OSHA regulations. Morton Salt's RMP consists of the following principle components: an offsite consequence analysis based on computational modeling, procedures for accidental release reporting, a prevention program, and an emergency response program. Prior to the development of this RMP, Morton Salt addressed risk management concerns for the propane system in their Hazardous Materials Management Plan (HMMP). Therefore, accidental release reporting procedures, the emergency respo nse program, and many elements of the prevention program were already implemented at the facility at the time that the RMP was developed. The propane system was installed in 1990 and is designed to serve two functions, to refill propane powered forklifts used onsite, and as a backup fuel source for the facility's solar and vacuum salt dryer burners. The tank design and construction is certified by American Society of Mechanical Engineers (ASME) and the entire system was designed in accordance with all applicable provisions of California Administrative Code Title 8, Chapter 4, Subchapter 1 and National Fire Prevention Association (NFPA) LP-Gas Code 58. Several safety devices are installed on the system, including internal excess flow valves, pressure relief valves, manual shut-off valves, temperature and pressure gauges, and perimeter crashposts. All piping between equipment is routed underground. The facility's Environmental Coordinator is assigned overall responsibility for the development, implementation, and integration of the RMP elements. In addition, a management system is in place for implementing specific elements of the RMP. The facility has not had an accidental release of propane that resulted in on-site deaths, injuries, or significant property damage; or known offsite deaths, injuries, property damage, environmental damage, evacuations, or sheltering in place since the propane system was installed. The offsite consequence analysis involves developing and modeling a worst-case and an alternative theoretical release scenario to estimate the impact an accidental release may have on the public and environment in the surrounding area. The worst-case release assumes that the maximum amount of propane ever held at the facility is released into the atmosphere during pessimistic meteorological conditions. It is intended as a basis of comparison with other facilities, but it is not realistic to expect such a scenario to actually occur. The alterna tive scenario was selected based on the hazard review conducted for the facility and its accident history. For the alternative release scenario, more representative average daily atmospheric conditions, as recommended by EPA, are assumed. All release scenarios were modeled using RMP*Comp, modeling software developed for and distributed by EPA for use in preparing RMPs. The endpoint for flammable materials such as propane is 1 psi overpressure. The worst-case release is predicted to reach the endpoint at a distance of 0.39 miles from the facility. This distance is used to define the radius of a circle within which potential offsite impacts are assessed. Because the area immediately surrounding the facility is strictly industrial, there are no residences located within this radius, nor are there any public institutions, such as schools, churches or hospitals, or other sensitive public or environmental receptors located within this radius. Morton Salt's neighbor to the northeast, Cargill Salt, has a smaller size propane tank located approximately 100 yards from Morton Salt's, which may be affected by such a release. The selected alternative release scenario results from either failure of the tank's variable liquid level gauge or failure to follow correct tank filling procedures, leading to overfilling the tank. This causes overpressurization of the tank, and the pressure relief valves lift, venting propane to the atmosphere. Based on methods outlined in U.S. EPA's RMP guidance for Propane Storage Facilities, it is estimated that 2,819 pounds of propane would be released under such scenario. If this volume reaches a source of ignition, the estimated distance to endpoint is 0.07 miles, or 370 feet. No residents or public or environmental receptors are located within this radius. Cargill Salt's propane tank is within this distance and may be affected by such a release. Morton Salt's prevention program consists of several elements, including the collection of propane and process safety information, a hazard review of the facility, standard operating procedures for the propane system, procedures and certification for training all employees, maintenance procedures and scheduling, procedures for conducting incident investigations, and compliance review procedures for insuring that the provisions of the RMP are being implemented. All aspects of the prevention program cover both operations involving forklifts and the backup fuel system. Prior to the initiation of work involving propane that is to be completed by a contractor, the Environmental Coordinator will verify that the contractor has programs in place that address applicable portions of Morton Salt's prevention program, such as standard operating procedures and appropriate training for their employees. The Emergency Response Program as it applies to the propane system is outlined in two documents. The Emergency Master Plan describes the various types of emergencies and disasters t hat could occur at the facility, assigns responsibilities to meet these occurrences, and sets forth a plan of action for the effective utilization of personnel and/or equipment in order to minimize the number of personal injuries, reduce the amount of property damage, and return the facility to regular production. The Contingency Plan sets forth all hazardous material release response and reporting procedures and designates the Environmental Coordinator as responsible for overseeing all response actions involving propane. As part of the Emergency Response Program, employees are trained in fire fighting with portable fire extinguishers, first aid, evacuation, and administration. Emergency response and evacuation drills involving all facility personnel are conducted at least annually by the Employee Relations Manager. In addition, joint emergency response and evacuation drills will be coordinated and conducted annually with Cargill Salt in conjunction with the Newark Fire Departmen t to simulate a combined response to an accident involving a propane release from either Morton Salt's or Cargill Salt's propane equipment. The first such drill is scheduled for March 22, 1999. Cargill Salt is also preparing an RMP for their facility. Emergency notification procedures for each facility include information for contacting appropriate emergency response personnel at the other facility. Morton Salt's propane equipment complies with all current applicable state and federal regulations, and NFPA and ASME design codes. Based on this fact and the other findings of the Hazard Review conducted October 5, 1998, no improvements or additions to the facility's equipment are needed or recommended at this time to insure the public's safety. |