September, 2013Memphis, TN

Environmental, Health & Safety Committee Meeting

Introductions

• Name• Company Affiliation• Job Title or

Responsibilities• Home Office

• Networking Objective for the Week

April 10, 2013Memphis, TN

Environmental Issues

“Can we stop talking about environmental regulations killing jobs, please?”

“We have a moral obligation to leave our children a planet that’s not polluted or damaged…”

“Cutting carbon pollution will help keep our air and water clean and protect our kids…”

“Climate change represents one of the major challenges of the 21st century”

“While no single step can reverse the effects of climate change, we have a moral obligation to act on behalf of future generations.”

“(W)e can and will meet this challenge in a way that advances our economy, our environment, and public health all at the same time.”

The President’s plan would:• Cut carbon emissions in America• “Prepare” the United States for the “impacts” of Climate Change• Lead International efforts to “address” Global Climate Change

President Obama’s Climate Action Plan to Cut Carbon Pollution

Taking Action for Our Kids

FOR IMMEDIATE RELEASEAugust 26, 2013

EPA Releases New Climate Change Video Series

The series supports President Obama’s Climate Action Plan and highlights benefits of reducing energy consumption

WASHINGTON – The U.S. Environmental Protection Agency (EPA) today released a new series of short public service videos on climate change. The videos cover a range of topics related to climate change, including its causes and impacts, actions Americans can take to reduce their impact, and the benefits to the economy of addressing climate change. The new video series supports the President’s Climate Action Plan by encouraging American families to reduce the amount of energy they consume, cutting down on their utility bills and protecting people’s health.

A warming climate can adversely impact water supplies, agriculture, power and transportation systems as well as health and safety of Americans and the nation’s economy. These videos show that there are simple things that all Americans can do to help.

Learn more on climate change: http://www.epa.gov/climatechange

FOR IMMEDIATE RELEASEAugust 26, 2013

EPA Launches Online Green Sports Resource Directory

WASHINGTON — The U. S. Environmental Protection agency (EPA) is unveiling a new online Green Sports Resource Directory that can help teams, venues, and leagues save money and reduce carbon pollution through increased energy efficiency, a key part of President Obama's Climate Action Plan. Additionally, the new directory contains information that can help teams reduce waste and gain recognition for their programs that reduce the environmental impact of their events.

“EPA is committed to helping teams and sports venues green their operations, and engage fans,” said Deputy Administrator Perciasepe. This week’s Summit includes a number of EPA speakers as well as leaders from across the sports community who recognize the potential for real environmental benefits from greening sports events and venues, and the potential for teams to inspire fans to adopt greener practices in their daily lives.

EPA compiled a Green "Scoreboard" that highlights a number of winning efforts across numerous sports leagues and some statistics on the environmental and saving benefits. The Scoreboard is available on the Green Sports Resource Directory.

FOR IMMEDIATE RELEASESeptember 5, 2013

EPA Launches New Online Mapping Tool for Environmental Impact Statements

WASHINGTON – Today, the Environmental Protection Agency (EPA) launched an interactive web-based mapping tool that provides the public with access and information on Environmental Impact Statements (EIS) filed with EPA for major projects proposed on federal lands and other proposed federal actions. When visiting the website, users can  click on any state for a list of EISs, , including information about the potential environmental, social and economic impacts of these projects.

“This interactive tool makes it easier for the public to be informed about the environment around them,” said Cynthia Giles, assistant administrator for EPA’s Office of Enforcement and Compliance Assurance, which oversees NEPA compliance. “Major projects and decisions have the potential to affect the environment where you work and live. I encourage everyone to check out the tool, stay informed and lend your voice.”

The user can click on a state in the map and is provided with comment letters submitted by the EPA on Environmental Impact Statements within the last 60 days. The tool also provides users with the information they need to identify projects with open comment periods, including how to submit comments.

EPA’s Office of Enforcement and Compliance Assurance has recently launched the “Next Generation Compliance” initiative, designed to modernize its approach and drive improved compliance to reduce pollution.

To use EPA’s EIS Mapper, visit http://eismapper.epa.gov/.

Email subject line: Teleconference with Industry on EPA’s Carbon Pollution Standards for Existing Power Plants

As a follow-up to “Building a Common Understanding:  The Clean Air Act and Upcoming Carbon Pollution Guidelines for Existing Power Plants,” EPA is holding a call to answer questions about how section 111 of the Clean Air Act works and other clarifying questions about the presentation.

Date: September 12, 2013

Time: 2:30-3:30pm EDT

Call-in information: (888) 273-3506; conference ID: 47847582

There is no need to register for the call but an operator will be gathering the names and affiliations of participants, so please call in five minutes early to ensure that you’re connected before the call starts.

Please email Jean Walker at walker.jean@epa.gov if you have questions.

Climate Deniers’ Award

The

Building

Regulatory

Tsunami

June 3, 2013

Heated Tank Emissions Modeling Workshop

50 100

150

200

250

300

350

400

450

0.00001

0.00010

0.00100

0.01000

0.10000

1.00000

10.00000

Asphalt & Cutback/Emulsified AsphaltTemperature - Vapor Pressure Curves

AsphaltExponential (Asphalt)

Temp. (oF)

VP

(ps

i)

EPA has released its

SPCC Guidance for Regional Inspectors

http://www.epa.gov/emergencies/content/spcc/spcc_guidance.htm

EPA SPCC Stakeholder Webinar Sessions

Session 1 Thursday, September 12, 2013

2:00 p.m. - 3:30 p.m. EDT

�https://spccoutreach1.eventbrite.com/

Session 2 Wednesday, September 18, 2013

10:00 a.m. - 11:30 a.m. EDT

�https://spccoutreach2.eventbrite.com/

Session 3 Wednesday, September 18, 2013

1:00 p.m. - 2:30 p.m. EDT

�https://spccoutreach3.eventbrite.com/

Session 4 Thursday, September 19, 2013

10:00 a.m. - 11:30 a.m. EDT

�https://spccoutreach4.eventbrite.com/

Session 5 Thursday, September 19, 2013

1:00 p.m. - 2:30 p.m. EDT

�https://spccoutreach5.eventbrite.com/

May 24 API Comments on e-Manifest to its Waste & Remediation Group

• API offers the following seven comments regarding the e-Manifest system:• EPA’s process for developing the e-Manifest rule does not allow for adequate public

input and, at a minimum, EPA should release a draft rule for public comment.• E-Manifest information should be made publicly available in a way that balances the

need for public transparency with legitimate concerns about confidential business information (CBI).

• EPA should strongly encourage states to eliminate requirements for manifests to be sent to state agencies and associated manifest fees.

• EPA should ensure that redundancies or conflicts between the EPA e-Manifest system and state manifesting requirements are reduced or eliminated.

• Enforcement using the e-Manifest system should be undertaken in a manner that does not undermine the system.

• EPA needs to coordinate with DOT on how users of the e-Manifest system can meet DOT requirements at the same time.

• Hard copy recordkeeping and biennial reporting are unnecessary under an e-Manifest system.

The Ethanol Requirements

YE 2008 YE 2009 YE 2010 YE 2011 YE 2012 YE 2013 YE 2014120

122

124

126

128

130

132

134

136

138

140

6%

7%

8%

9%

10%

11%

12%

13%

14%

Net

% o

f G

aso

lin

e S

up

ply

An

nu

al G

aso

lin

e S

up

ply

(b

illi

on

gal

lon

s)

Annual Domestic Gasoline Supply (billions of gallons)

10% "Blend Wall"

Annual RFS Mandate

(as % of Supply)Actual Ethanol Consumed

(as % of Supply)

D6 ETHANOL RINS ARGUS 2012 Aug 2013 (E) Future

$ pe

r R

IN

Meeting EPA’s Cellulosic Ethanol Demands

YE 2009 YE 2010 YE 2011 YE 2012 YE 2013 YE 20140.01

0.1

1

10

100

1000

10000

Cellulosic Ethanol Mandates and Production

Mil

lio

ns

of

Gal

lon

s

Energy Independence & Security Act (2007)

EPA's Annually Revised Cellulosic Requirement

ProjectedProduction(INEOS Bio,8 mgal nameplate)

ActualProduction

(Western Biomass,Chapter 11 10/31/12)

Global

SXL

Gulf IrvingExxonMobil

CITGO

September, 2013Memphis, TN

E.O. on Chemical Facility Safety and Security

“Waterfront Protection Ordinance”South Portland, Maine

ILTA EHS Committee

Memphis, TN

September 12, 2013

Implementation of Clean Air Act Section 185 in Texas

CAA 185 Requirements & Federal Regulations•Clean Air Act Section 185 [42 U.S.C. §

7511d]

•National Ambient Air Quality Standards ▫1991 NAAQS (56 FR 56694)▫1997 NAAQS (62 FR 38856) ▫2008 NAAQS (73 FR 16436)

CAA185 Implementation in Texas:Houston-Galveston-Brazoria Ozone Region

TCEQ 185 Assessment Program:Collecting Facility Baseline Emissions Data

•Baseline Year = 2007•Emissions Sources

▫Normal Operations▫Maintenance Activities▫Startups and Shutdowns

•Baseline Emissions Data Due 9/19

TCEQ 185 Assessment Program:Establishing a Baseline

Facility Emissions Data

Baseline = Permitted Emissions

Baseline = Actual Emissions

2007 Baseline Emissions

2007 Baseline Emissions

2007 Permit

Limit

OR

TCEQ 185 Assessment Program:Determining Fee Obligations

Facility Emissions

Major SourceObligation

Baseline AmountBased on 2007 Emissions Data

Penalty Basis80% Baseline

Annual Reported Emissions

Obligation = ZERO

TCEQ 185 Assessment Program:Penalty Fees

•First Fee Assessments Based on 2012 Emissions

• Initial Fee = $9,230/ton of excess emissions

Major Source Obligation = 8 tonsEst. Total Penalty = $73,840Baseline = 30 tons

Based on 2007 Baseline Emissions Data

Penalty Basis 80% Baseline = 24

tons

2012 Emissions = 32 tons

EXAMPLE:

TCEQ 185 Assessment Program:Fee Obligation Offsets

Area-Wide Obligation▫ Texas Emission Reduction

Plan (TERP)▫ Low-Income Vehicle

Repair Assistance, Retrofit, and Accelerated Vehicle Repair Program (LIRAP)

▫ Local Initiative Project (LIP)

Major Source Obligation▫ Mass Emissions Cap &

Trade (MECT)▫ Highly-reactive VOC

Emissions Cap & Trade (HECT)

Attainment of 1997 NAAQS

TCEQ 185 Assessment Program:Schedule

• September 19, 2013: Baseline Calculations Due• March 31, 2014: 2013 Emissions Data Due• December 2, 2014: TCEQ Mails 185 Fee Invoices• January 2, 2015: Initial Penalty Fees Due

What Are You Doing To Comply?

GD-GACT Semi-Annual Report Template Revision

• Template Modifications:– Alternative Table for Equipment Leak Inspections– Separate CMS Performance Summary Report

Templates for CEMs, Temperature Probes & Records, Flare Systems and Alternative Monitoring

– New Excess Emissions & CMS Performance Report Template

• TOS #23 Version 2.0 Expected October 2013

Document Retention Working Group Update

Record Type Subcategory Record TitleBasis for Retention

Retention Schedule

Record Custodian(s)

Storage Location

Envionmental Air Compliance Certification Records 5 years

Environmental Air Butane Maintenance Records Permanent

Environmental Air Emissions Reports 5 years

Health Employee Hearing (Audiometric Test Records) Active

Health Employee Hearing (Noise Exposure) 2 years

Health Employee Hearing Protection Requirements Active

Safety Contractor Contractor Certificate of Insurance ActiveSafety Contractor Contractor Equipment Use Agreement 2 yearsSafety Contractor Contractor Facility Access Agreement 2 years

Safety FireNFPA 25/ Automatic Sprinkler System Inspections

29 CFR 1910.159 (c)(2)

3 years

Security MTSA Facility Security Plan (FSP) - Keep most recent USCG-approved copy and all amendments.

Active

Security MTSA FSP Annual Audit Checklist 2 years

Security PHMSA PHMSA Security Plan Active

GeneralEmployee

Training

Training (HSEQ) Certificates – Create a specific folder for the following: (1) DOT (TDG in Canada); (2) HAZWOPER; and (3) Security -USCG. Maintain records in each employee’s individual training folder. Provide training certificates to employees at time of employment termination.

Duration of Employment

GeneralEmployee

Training

Training (HSEQ) Records (Sign-in Sheets, Course Materials, Monthly Emails) 3 years

Records Index - SAMPLEEnvironmental, Health & Safety, and Security Records Index

Lunch in theChelsea Room

We’ll resume promptly at 1 p.m.

April 10, 2013Memphis, TN

Health and Safety

ILTA Terminal Member Quality Investigation and Ongoing Corrective Action

Broken Welds on Gangway Carriage Assembly May 10, 2013

Initial “Confined Space Entry & Rescue Training” Certificate

Subsequent Confined Space & Rescue Training Certificate Submitted

20

03

20

04

20

05

20

06

20

07

20

08

20

09

20

10

20

11

20

12

20

13

0.00

1.00

2.00

3.00

4.00

5.00

6.00

7.00

8.00

0

5

10

15

20

25

30

35

40

45

50

ILTA Annual Safety Award Participation and Performance Data

Average TRIR

No. Participants

Ter

min

al I

nd

ust

ry T

RIR

Nu

mb

er o

f P

arti

cip

atin

g C

om

pan

ies

Measuring Contractor Safety ILTA 2013 Safety Survey Data

a b c d e f g h i j k l m n o p q r s t u v w x y z aa bb cc dd ee0

5

10

15

20

25

0

200

400

600

800

1000

1200

1400

1600

Number of Contractor Incidents

Number of Recordable Incidents

Number of Employees (rt. axis)

Reporting Company (Sorted by Total No. Recordable Incidents)

Nu

mb

er o

f R

epo

rted

In

cid

ents

Nu

mb

er o

f F

TE

Em

plo

yees

per

Rep

ort

ing

Co

mp

any

OSHA Final Rule:Fall Protection for

Walking-Working Surfaces

Installation Challenges and Solutions for Terminals

ILTA EH&S Committee MeetingMemphis, TNSeptember 11, 2013

Insulating Flanges on Marine Hose Towers

Hot Work Policy & No. 6 Oil Transfers

What limitations on hot work are appropriate while transferring No. 6 Fuel Oil into a tank where hot work is proceeding in another tank in the same tank field?

Are our gas monitors properly indicating the potential for explosive atmospheres, especially for No. 6 Fuel Oil?

Hot Work Policy & No. 6 Oil Transfers

Safety Standard No. 6Hot Work will not be permitted in tank fields where tanks are receiving flammable or combustible liquids.

Hot Work PermittingOSHA does not allow hot work in a hazardous atmosphere, and defines a hazardous atmosphere to be one where the measurements are > 10% of the LEL. (Colonial uses 5%)

Findings

Inconsistent LEL Readings

Monitor calibration issues

Meter Reference Value Questions

LEL Anomalies

High LEL Readings during transfer

……………………………………….

Remaining Issues

Vapor Space

MixerHeating coils

Tank FieldDike

Tank FieldDike

Gas Detection Meters Owned by Colonial

Biosystems - Cannonball 32 meters on handMaintained at Safety DeptManually CalibratedEach ~10 yrs old

Honeywell - PHD61 Meter on handMaintained at Liquid OpsAutomatic CalibrationUnit ~1 yr old

Multi-Gas MetersH2S, CO, LEL, O2

Single-Gas MetersVOCs Only

Minirae 3000 1 meter on handMaintained at Safety DeptManually CalibratedUnit ~3 yrs old

Sperian PHD61 meter on handMaintained at Safety DeptManually CalibratedUnit ~3 yrs old

BW Tech – GasAlertClipMSA - AltairSeveral meters on hand2 at Liquid Ops/ 4 at Boiler RmManually testedUnits last 24 months

H2S Monitors

Hydrocarbon Readings Collected from Tank 18 Roof Vent(taken while product was being heated and mixed)

% of Meter LEL (calibrated to Methane)

PPM Conversion (equivalent for multi-gas meters)

7 24

4 7

3,500 12,000

2,000 3,500

700 2,500

300 750

LEL Calibration Colonial multi-gas meters are calibrated using identical canisters containing 2.5% Methane

Colonial single-gas meters are calibrated using the same canister containing 100 ppm isobutylene.

LEL PPMv

Methanol 6.0 60,000

Methane 5.0 50,000

Ethanol 3.3 33,000

Cyclohexane 1.3 13,000

Gasoline 1.1 11,000

Cyclohexanone 1.0 10,000

Diesel 0.6 6,000#6 Fuel Oil 0.5 5,000

Reading on the meter (% of

Methane's LEL)

PPMv Equivalent

10 - 5,0009 - 4,5008 - 4,0007 - 3,500

6 - 3,000 { Methanol

5 - 2,500 { Methane

4 - 2,000 { Ethanol3 - 1,5002 - 1,000

{ 650 ppm Cyclohexane

550 ppm Gasoline

1 - 500 { Cyclohexanone

0.3 { Diesel

0.25 250 #6 Oil

0 - 0

Colonial Action Levels for each chemical based on their LELs (No Hot Work above 5% of LEL)

LEL of products we handle

Meter Calibration

Action Level based on 5% of LELLower Explosive Limit

LOWER EXPLOSIVE LIMIT ACTION LEVELS

METER READING (% of Methane's LEL)

PPM Equivalent % LEL PPM

Methane 5.0- 50,000 5- 2,500 ppm Methane

1- 500

250 ppm #6 Fuel Oil#6 Fuel Oil 0.5- 5,000

0- 0

% of LEL ReadingsPPMv readings

(equivalent for multi-gas meters)

7 24

4 7

3,500 12,000

2,000 3,500

700 2,500

300 750

The LEL of #6 oil is 0.5% or 5,000 ppmv

The red lines indicate the ~LEL for #6 Oil

The green lines indicate the Action Levels for #6 Oil

Observations

Meter Issues

1. Our meters are calibrated to methane with no adjustment to account for No. 6 Fuel Oil being measured rather than methane.

2. An LEL for fuel oil at 0.5% relative to an LEL for gasoline at 1.1% is difficult to understand.

3. There is significant variability in the measurements with the same meter and between different meters.

Observations

Hot Work Issues

Current readings show that our tank vapor space could be above the LEL at times, not only above the action level; e.g.

When our meter shows a reading of 10, it may be indicating a hydrocarbon content equal to the fuel oil LEL -- not 10% of the fuel oil LEL.

Path Forward: Questions

Monitoring1. What brands of monitors are being used by our

industry?

2. What gas is typically used for calibration?

3. Are adjustments made from the LEL of the calibration gas to the petroleum product of concern?

4. What is the expected variability of different meters?

Path Forward: Questions

Hot Work Proceduresa. What hot work restrictions should be in place

while transferring No. 6 Fuel Oil into a tank (in the same tank field)?

b. Is the effect of heating and mixing considered when limiting hot work while transferring?

c. Is the effect of H2S level in the No. 6 Oil considered when limiting hot work while transferring?

d. Are there any specifications on No. 6 Fuel Oil that might indicate the need for more stringent limitations?

Looking for

FRA Emergency Order 28 Lac-Mégantic, Quebec

FRC and NFPA 70 E: Survey Questions

1. If you handle flammable liquids, does your company have a policy requiring the use of FRC clothing (meeting the NFPA 2112 standards)?

If FRC is required,

2. Is it required for ALL personnel in the terminal, or only for those personnel directly involved in handling flammable liquids?

3. Does your policy require that it also meet the NFPA 70E arc flash standards; i.e., is the same clothing used by operator/loaders as well as electricians?

4. Are heat-related illnesses ever an issue at your sites when FRC (and chemical PPE) is worn, e.g. in temperatures in excess of 90oF? If so, what measures do you take to prevent over-heating?

Some measures being taken to prevent over-heating when wearing FRC:

• We establish rest schedules based upon the tasks to be performed and ambient temperatures.  

• We provide for several breaks and provide bottled water on all of our docks• We haven’t had issues yet, but are concerned about this and we allow multiple

hydration breaks on hot days.• We were experiencing an increase in heat related illness at terminals

requiring FRC. Last summer we implemented new relief measures:– Some terminals have since adopted NFPA 2112 rated FRC T-shirts;– others have significantly increased availability of water and offer breakrooms with popsicles; – still others have installed fans where significant heavy labor is constant; – or a combination of all of the above.

It has since become less of an issue.• Contract workers, especially during tank cleaning, have strict break schedules;

some companies use a heat stress indicator on site.• We are ordering new light weight shirts being offered by our supplier.

2012 NFPA 70E Standard for Electrical Safety

Arc Flash - Labels and Compliance

BREAK

Implications of Union Participation

during OSHA Inspections

Mr. Michael Taylor

Partner

Washington D.C. Region Office

Natural Gas Tank Trucksat Terminal Facilities

Mr. J. Alexander

President

Mansfield Energy Co.

EH&S Committee Business

We will resume tomorrow morning at 08:30 in this room.Continental breakfast will be available in the Chelsea Room at 8.