G.S. Robins and Company (01 Lombard) - Executive Summary |
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G.S. ROBINS AND COMPANY G.S. Robins and Company is a St. Louis-based chemical distribution company with branch locations throughout the Midwest. The branch located in St. Louis is located within a short distance of the Home Office. G.S. Robins has specialized in serving the unique chemical needs of the Midwest. The Lombard branch is involved with chemical storage and transportation. Employees at the branch location work with the chemical containers, but do not open any of the containers. G.S. Robins and Company is a long time member of the National Association of Chemical Distributors (NACD). Through the NACD G.S. Robins has committed and pledged to constantly improve the management and handling of chemicals by following the "Responsible Distribution Process(RDP)". RDP is a system that promotes continuous improvement in the health, safety, and environmental performance of all member companies. G.S. Robin's implementation of the RDP includes a commitment to comply with relevant environmental health and safety regulations. The senior management at G.S. Robins has formally accepted these guiding principles. RDP includes guiding principles for all aspects of environmental health and safety. These include: communication with emergency response officials, operating our facilities in a safe manner, respond to community concerns about chemicals, and to make health, safety and the environment a priority. In order to verify that G.S. Robins has complied with the guidling principles of RDP, the NACD conducts a third party verification. The on-site verification is conducted by a third party. The third party audits G.S. Robins every three years. The primary activities at the Lombard branch consist of the following: drum and tote storage, material loading and unloading, and transporation. The Lombard facility of G.S. Robins has four of the 140 chemicals identified by the EPA above the threshold quantity. These chemicals are: chlorine, formaldehyde, hydrofluo ric acid, and aqua ammonia. The worst-case scenario for the Lombard facility of G.S. Robins involves formaldehyde. Formaldehyde is stored on-site in three different types of containers. These containers are: 2,500 lb. tote, 500 lb. drum, and 4 gallon containers. The worst-case scenario demonstrates all of the formaldehyde on-site being released at one time. The maximum amount on-site is 15,000 lbs. The scenario would be either a fire or explosion causing a complete release of all material at one time. The scenario has an offsite impact radius of 4.6 miles(estimated distance to Toxic Endpoint). The modeling was done using the EPA COMP program. The likelihood of this scenario taking place is remote. The formaldehyde is stored inside the warehouse building. G.S. Robins does not have the maximum amount of inventory on-site at all times. Currently, G.S. Robins and Company is investigating methods to reduce the amount of inventory on hand. The alternative scenarios at G.S. Robi ns-Decatur consist of problems that are more likely to happen. As a chemical distributor, we move a large quantity of chemicals. During the moving ro storage of a chemical, there is always the chance that a container could begin leaking. The leaking could be caused by several factors. There factors include: overfilling, jostling during transporation, or just a leak. G.S. Robins employees are all trained on safe material handling and how to properly handle spills and leaks. All chemicals reported are stored in the outdoor chemical storage area. The following are the alternative scenarios at G.S. Robins-Decatur. These alternative scenarios were completed on the EPA COMP modeling program. ALTERNATIVE SCENARIOS FOR INDOOR/WAREHOUSE CHEMICAL STORAGE All scenarios below were based on being released in an enclosed space, in direct contact with outside air. The Alternative Scenarios represent incidents that are more likely to occur than the worst-case scenario. G.S. Robins moves a l arge amount of material through the facility each year. The types of incidents that are likely to occur are: drum leaks, tote leaks, and leaks in tote valves. Release of aqua ammonia from a 2,200 lb. tote / Leak in the tote / Toxic Endpoint = <0.1 miles Release of aqua ammonia from a pallet of drums / Leak/spill of all drums on the pallet / Toxic Endpoint = <0.1 miles Release of formaldehyde from a 2,500 lb. tote / Leak in the tote / Toxic Endpoint = 0.7 miles Release of formaldehyde from a 500 lb. drum / Leak in the drum / Toxic Endpoint = 0.3 miles Release of hydrofluoric acid from a 157 lb. drum / Leak in the drum / Toxic Endpoint = 0.2 miles Release of hydrofluoric acid from a 500 lb. drum / Leak in the drum / Toxic Endpoint = 0.2 miles Release of hydrofluoric acid, total amount in storage / Fire or explosion / Toxic Endpoint = 1.6 miles Release of chlorine from a 2,000 lb. cylinder / Leak in the cylinder / Toxic Endpoint = 0.2 miles Release of chlorine from a 150 lb . cylinder / Leak in the cylinder / Toxic Endpoint = 0.1 miles FIVE YEAR ACCIDENT HISTORY G.S. Robins and Company - Decatur has had no reportable accidental releases in the past five years. EMERGENCY RESPONSE PROGRAM The G.S. Robins and Company Emergency Action Plan consists of guidance for evacuation, fires, spills, tornadoes and bombthreats. In addition, the plan contains information on emergency contacts, plant layouts, and emergency reporting requirements. G.S. Robins and Company is an active member of St. Louis City Local Emergency Planning Committee. A representative of G.S. Robins attends all of the monthly meetings. The LEPC meeting provide G.S. Robins with the opportunity to learn more about emergency response and to share the information about our facilities with the city. Open communication with the city LEPC, fire departments, and other emergency response entities is an important component of our emergency response program. Each year, G.S. Robins invites the St. Lou is Fire Department to attend facility tours. CHANGES TO IMPROVE SAFETY G.S. Robins and Company has learned important information about safety and the environment. This has been learned both by participation in the RDP program and completing the RMP requirements. Improvement is an on-going process. The completion of the RMP program has lead to several process that are being re-evaluated. Process hazard analysis' are being reviewed and updated. Our emergency action plan is being reviewed and updated for all facilities. And G.S. Robins is evaluating the inventories of chemicals stored and possible alternatives. |