Delta Deluxe, L.L.C., dba Delta Chemical Services - Executive Summary

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Delta Deluxe, L.L.C., dba Delta Chemical Services, purchased approximately 9 acres of land from the Lubrizol Corp. in 1997 to construct a chemical packaging, warehousing, and logistics facility in Deer Park, Texas.   The facility was completed in late 1998, and chemical packaging operations began in October, 1998.  The facility is located at 334 Tidal Road, Deer Park, TX.  The mailing address is: 
   Delta Chemical Services 
   P.O. Box 1314 
   Deer Park, TX  77536 
Delta Chemical Services provides custom packaging, warehousing and logistics services to a wide variety of customers.  Customers are typically large chemical or oil companies that manufacture product in bulk quantities.  The bulk product is shipped to DCS in rail cars or tank trucks, and repackaged into drums, intermediate bulk containers (totes) or other packages.  The repackaged material is then stored in specially-designed chemical storage w 
arehouses and shipped out as directed by the customer.   Delta Chemical Services does not manufacture any materials, nor does the company own the material handled or stored on site 
The primary objective in designing the DCS facility was to create a safe and healthy workplace for the employees that has minimal impact on the community and the environment.  To this end, the company installed a number of physical safety features in the facility.  These include: 
A. 43,000 gallon concrete catch basin under the rail track in the facility; 
B. Six inch concrete curbing around the tank truck unloading area; 
C. Dry disconnect hoses with fail-close valves to prevent product from flowing from the bulk container in case of a power outage or equipment failure; 
D. Six inch concrete curbing around the entire perimeter of the warehouse; 
E. Concrete and asphalt roads and parking areas to prevent possible spills from contacting the ground 
F. Three vehicle access gates on Tida 
l Road to prevent unauthorized individuals from entering the site; 
G. Closed-captioned TV cameras located throughout the facility to remotely monitor process operations and other sensitive areas; 
H. Emergency valve to prevent storm water, fire water or product released in an emergency situation from leaving the site; 
I. High-volume water and foam fire fighting system in the product unloading area to put out fires and prevent vapors from travelling off site; 
J. Foam-water fire fighting system in the product transfer and warehouse areas designed to approximately two times the required standard; 
K. High efficiency thermal destruction of vapors generated from packaging of certain hazardous materials; 
L. 100% enclosed booths for repackaging material into drums, etc.; 
M. Separate laboratory and office ventilation systems to prevent lab exhaust from entering the office or production areas; and 
N. Emergency alarm system monitored 24 hours per day, 7 days per week by neighboring company. 
In add 
ition to physical facility elements to protect employees and the community, the company has implemented a variety of management systems to train employees and ensure the community is protected.  Some of these include: 
A. Pre-employment testing of employees to verify reading, math, and mechanical skills; 
B. Random drug and alcohol testing; 
C. In-depth pre-employment safety and operations training program; 
D. Continuing safety and environmental awareness training conducted both on computer and by instructors; 
E. Incident investigation system which identifies near-miss mishaps and root causes of each incident; 
F. Continuous Improvement Process for identifying potential areas for improvement throughout the facility; 
G. Management involvement in community affairs, including the Local Emergency Planning Committee, East Harris County Manufacturers' Association, and the Deer Park Citizens Advisory Committee; and 
H. Coordination of emergency response planning with neighboring facilities.   
Delta Chemical Services does not currently handle any RMP-regulated products on site.  We do, however, anticipate handling one of the regulated materials, Toluene Diisocyanate (mixed isomers) within the next six to twelve months.  For that reason, DCS has chosen to predictively file a Risk Management Plan with the EPA for TDI. 
It is anticipated that TDI product will enter the facility in jumbo rail cars carrying approximately 150,000 pounds of the material.  The rail cars will be spotted on the DCS track with the concrete containment and the product will be off-loaded into drums.  Those drums will most likely be stored in the warehouse for less than 60 days.  The drums will then be shipped out either in tractor-trailers for domestic shipments or in 20 or 40 foot shipping containers for export.  The product will most likely be handled for more than one customer. 
Toluene Diisocyanate is a colorless to pale yellow liquid with a high flash point and  
which does not vaporize easily.  The material is produced by reacting toluene diamine with phosgene, and is used as a building block for making urethane foam products, foam for furniture and bedding, insulation, and paints and coatings, including those used on cars and light trucks.  The material is typically shipped in rail cars, tank trucks, and drums; and is seldom, if ever, transported by pipeline.  In low concentrations, TDI could cause nose, throat and lung irritation which could result in discomfort or limited breathing difficulty.  Medical attention is rarely required for low concentrations.  In higher concentrations and with prolonged exposure, TDI can cause severe irritation of the nose, throat, lungs, eyes and skin.  This can cause irritation of the nose and throat with a cough; irritated, red, watery eyes; and/or a mild to severe irritation of the skin with reddening and possibly a rash.  In higher concentrations, medical attention may be recommended.  Overexposure to TDI i 
s rare, as the material does not easily vaporize, even if it is spilled and/or vapors are released. 
There have been no reportable chemical releases on site since the facility began operations. 
Delta Chemical Services is an RMP Program Level One facility.  The modeling conducted for this program indicates that there are no off-site impacts from our worst-case release scenario.  Second, the facility has had no releases of any regulated substance with actual or potential off-site impacts.  Finally, the company is not currently regulated by the OSHA Process Safety Management (1910.119) regulations.  For those reasons, the facility is designated as Program 1. 
Using guidance provided in the EPA's "Offsite Consequence Analysis Guidance Document", DCS determined that a worst-case release of TDI, according to RMP guidelines, would be the release of the entire contents of a jumbo rail car of the material.  This would re 
sult in the loss of approximately 150,000 pounds of TDI into the concrete rail car containment basin.  Again using EPA guidance, the calculated area of release would be approximately 0.06 miles.  A release to that distance would not reach any off-site receptors. 
Although the release scenario utilized for the RM Plan involves the release of the entire contents of a rail car, this scenario is extremely unrealistic.  There are numerous safety features in the facility which would prevent an incident such as this from occurring.  These include: 
* Dry disconnect connections between transfer hose and bulk container which prevent material from escaping, even if the valves on either side fail; 
* Fail-close valves directly behind the dry disconnect connections which prevent product from entering facility transfer lines in case of a failure of the bulk transport or facility transfer lines; 
* Emergency shut down buttons for each transfer pump located at operating stations throughout the unloading 
* Remote monitoring of the unload area in the office with emergency shut down from the monitoring location; 
* Monitoring of unload area and transfer process by trained personnel during the entire product transfer process; and 
* Inspection procedure for all incoming bulk transports. 
There are no public receptors nor environmental receptors within the area of influence of the calculated worst-case scenario.  The nearest public receptors to the DCS facility are the Lubrizol Fire House to the northwest, the Lubrizol process facility across Tidal Road to the west, and the Lubrizol main office building directly south of DCS.  None of these are located within the 0.06 mile radius of the potential worst-case scenario. 
The nearest environmental receptor to the facility is the San Jacinto Monument and park.  This park is located approximately 5 miles northeast of the facility on Battleground Road. 
Although it was not required by th 
e EPA, DCS performed an analysis of a potential alternate release scenario.  For this scenario, we examined the potential impact of a rupture of the tank truck unloading hose.  EPA guidance for Alternate Release Scenarios allows companies to take credit in the modeling process for existing safety systems in their analysis of this scenario.  Using this guideline, DCS assumed that both the active and passive safety systems in the facility worked during the release, and that the operator was able to rapidly isolate the release using the emergency shutdown system (emergency button in the unloading area).  This resulted in a loss of approximately 1226 pounds of TDI through the rupture in the unloading hose with an estimated endpoint of 0.06 miles.   Although the total release quantity is significantly less than that of the Worst Case Scenario (1226 lbs. ARS vs. 150,000 lbs. WCS), the endpoint distance is identified as the same (0.06 miles) because the EPA tables used do not have any lower d 
istances listed. 
Prior to operations start-up, all DCS operations employees completed a four-week safety and operations training course.  This course consisted of basic safety training, initial operations training, and detailed emergency response training.  All employees received 40 hours of emergency response training from the Texas A&M Engineering Extension Service and 2 days of fire fighting training from another outside contractor.  Emergency response training targeted on actual potential scenarios in facilities such as ours and concentrated on "hands-on" instruction. 
In addition to the training program, Delta Chemical Services has coordinated its emergency response program with neighboring Lubrizol Corp.  Lubrizol owns all adjacent land to DCS, and has a significant amount of emergency response resources.  The facility's fire and ambulance vehicles are stationed on adjoining property and there is no barrier to prevent the immediate access of these 
vehicles onto the DCS property.  Additionally, DCS and Lubrizol have planned at least annual joint emergency drills to be held at DCS.  Finally, DCS is currently working towards membership in the Channel Industries Mutual Aid organization, which provides mutual emergency response assistance between industries in the Houston Ship Channel area.   The company is also an active member of the Deer Park LEPC, and has communicated its emergency response plan to that organization. 
On July 1, DCS will be implementing a new Behavior Based Safety program known as "Team Up...Time Out for Safety".  The program is designed to encourage employee involvement in the facility's safety program and to allow employees to make changes and improvements rapidly and with little intervention.  Additionally, we are instituting a modified Process Hazard Analysis in the new business review cycle.  This PHA will involve operations, safety, engineering, and management staff s 
itting down prior to handling any new material and reviewing all steps involved in safely handling that product.  Employee safety procedures and methods will be paramount in these discussions, as well as the design of material-specific emergency response procedures for the new products.  Additionally, DCS is in negotiations with Channel Industries Mutual Aid to join that organization for emergency response protection.  Finally, Delta Chemical Services is currently working towards the OSHA VPP Star Worksite certification.  If awarded this certification, DCS would be the first company with fewer than 40 employees in the program and would be the only new facility in the program. 
Delta Chemical Services sees the EPA's Risk Management Program as an opportunity to communicate about our facility with the public.  Although the company does not currently handle any RMP products, we elected to file an RMPlan predictively, using a product we anticipate handling in the upcoming year. 
The management of Delta Petroleum Co., the parent company of Delta Chemical Services, is committed to providing and maintaining a safe and healthy workplace for employees, neighboring facilities, and the community of Deer Park.  To that end, the company has designed and constructed a state of the art facility with multiple layers of protection for employees and the community.  The company has committed to providing the surrounding community with information regarding the company's safety performance and commitment to the environment, and the RM Plan is one way to do this.    
Based on the criteria in 40 CFR 68.10, the distance to the specified endpoint for the worst-case accidental release scenario for the following process is less than the distance to the nearest public receptor: [chemical packaging and warehousing].  Within the past five years, the process has had no accidental release that caused offsite impact provided in the risk management program rule (40 CFR 
68.10(b)(1)).  No additional measures are necessary to prevent offsite impacts from acidental releases.  In the event of fire, explosion, or a release of a regulated substance from the process, entry within the distance to the specified endpoints may pose a danger to public emergency responders.  Therefore, public emergency responders should not enter this area except as arranged with the emergency contact indicated in the RMP.  The undersigned certified that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate, and complete. 
Signed by Mushahid Khan*, DCS General Manager, on June 17, 1999. 
*  The Certification with original signature is included with this RMP submittal. 
Delta Chemical Services, Deer Park Texas                                       Risk Management Plan         
DCS Executive Summary        Page 5 of 1
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