Delta Distributors, Dallas - Executive Summary |
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"Delta Distributors, Inc. is committed to continued excellence, leadership, and stewardship in protecting the environment. Environmental protection is a primary management responsibility, as well as the responsibility of every employee. In keeping with this policy, our objective as a company is to reduce waste and achieve minimal adverse impact on air, water, and land through excellence in environmental control. We recognize that the responsibilities for safety, health and the environment are shared: 1. We accept the responsibility for leadership of the safety & health program, and for its effectiveness and improvement, and for providing the safeguards required to ensure safe conditions. 2. Our managers and supervisors are responsible for developing the proper attitudes toward safety, health and the environment in themselves and in those they supervise; and for ensuring that all operations are performed with the utmost regard for the safety and health of all personnel involved, includ ing themselves. 3. Our employees are responsible for wholehearted, genuine cooperation with all aspects of the safety and health program, including compliance with all rules and regulations, and for continuously practicing safety while performing their duties. Our environmental guidelines include the following: 1. Environmental protection is a line responsibility and an important measure of employee performance. In addition, every employee is responsible for environmental protection in the same manner as for safety. 2. Reducing or eliminating the generation of waste has been and continues to be a prime consideration in research, process design, and operations; and is viewed by management like safety, yield and loss prevention. 3. Source reduction / waste minimization (reuse and recycling) of materials has been and will continue to be given first consideration prior to classification and disposal of waste. The systemic program review and update shall include: 1. Periodic review of p rogram effectiveness. 2. Evaluation of new and modified waste management practices, and 3. Revision of the Plan when necessary. Our Dallas, TX chemical distributing facility has tank, tote, bag, and drum. It handles millions of pounds of chemicals / year. We have an Emergency Response Plan that assigns responsibilities for preventing hazardous releases. The following chemicals are listed in program 2: Ammonia (>20%), Hydrofluoric Acid (70%), Pentane In regard to Ammonia safety, this material is stored in drums and totes, outside, away from strong acids, strong alkalis, alkali metals, brass, copper, hypochlorites, and other incompatible materials. We have available self-contained breathing apparatus in case of an emergency spill or other release of liquid and vapor. The follwoing considerations are taken in the case of Ammonia: 1a. In a Worst Case Scenario (such as the bursting of a drum and releasing its contents), emergency services (such as the fire department) would be informed. Unnecessary personnel would leave the area to a distance of 0.10 miles. Other facilities would be informed within this distance, and appropriate personal protective equipment (including self-contained breathing apparatus) would be put on trained personnel, the spill would be contained by diking the spill area, and put into a salvage container for disposal. See our document ER 002 (Delta Emergency Response Plan). 1b. In an Alternate Case Scenario (such as a minor leak in a drum, releasing some of its contents), the same procedure as the Worst Case Scenario would be followed except evacuation would only be necessary to a distance of 0.10 miles. 2. There have been no accidents involving Ammonia within the last five years. 3. Delta will respond to all emergency spills involving Ammonia, and emergency services will be informed of the situation. Other issues involving Ammonia include: 1. An examination of the hazards associated with the handling and storage of Ammonia. These are covere d in our document S&H 034 (The Handling and Storage of Ammonia). The scales are calibrated every six months to make sure they are correct. If any deviation is noticed before six months have passed, the scales are immediately recalibrated. The calibration schedule is mentioned in our doucment LAB 015 (Schedule for the Calibration of Laboratory Equipment and Plant Scales). 2. Training is an ongoing requirement of plant employees. Regarding RMP Training, it is required of any employee assigned to a new task involving RMP chemicals. Refresher training is required every three years. See our document EPA 004 (Risk Management Plan for Hazardous Substances, page 13 of 74, Section 6.54 (Training)). 3. Regarding documentation of storage inspections, our document OPD 002 (Supervisors Daily Plant Inspection Procedures) gives the daily inspection procedure and an inspection form to document the inspections. These documents are retained for five years. The startup of the process of unloading, hand ling, storage, and loading of Ammonia shall require inspection of all equipment involved in the process. 4. The document S&H 034 (The Handling and Storage of Aqua Ammonia) outlines the process of unloading, handling, storage, and loading of Ammonia drums, and the safety precautions which are required. 5. The document EPA 004 (Risk Management Plan of Hazardous Substances) gives a description of the responsibilities of the Operations Manager and other personnel involved in RMP process in general. The document S&H 034 (The Handling and Storage of Aqua Ammonia) gives a description of the Operations Manager and the other personnel involved in the process of unloading, handling, storage, and loading of Ammonia drums. In regard to Hydrofluoric Acid safety, this material is stored in drums, outside, away from strong acids, strong alkalis, alkali metals, brass, hypochlorites, and other incompatible materials. We have available self-contained breathing apparatus in case of an emergency spill or other release of liquid and vapor. The following considerations are taken in the the case of Hydrofluoric Acid. 1a. In a Worst Case Scenario (such as the bursting of a drum and releasing its contents), emergency services (such as the fire department) would be informed. Unnecessary personnel would leave the area to a distance of 1.00 miles. Other facilities would be informed within this distance, and appropriate personal protective equipment (including self-contained breathing apparatus) would be put on trained personnel, the spill would be contained by diking the spill area, and put into a salvage container for disposal. See our document ER 002 (Delta Emergency Response Plan). 1b. In an Alternate Case Scenario (such as a minor leak in drum, releasing some of its contents), emergency services (such as the fire department) would be informed. Unnecessary personnel would leave the area to a distance of 0.20 miles. Other facilities would be informed within this distance, and appropri ate personal protective equipment (including self-contained breathing apparatus) would be put on trained personnel, the spill would be contained by diking the spill area, and put into a salvage container for disposal. See our document ER 002 (Delta Emergency Response Plan). 2. There have been no accidents involving Hydrofluoric Acid within the last five years. 3. Delta will respond to all emergency spills involving Hydrofluoric Acid, and emergency services will be informed of the situation. Other issues involving Hydrofluoric Acid include: 1. An examination of the hazards associated with the handling and storage of Hydrofluoric Acid. These are covered in our document S&H 017 (The Handling and Storage of Hydrofluoric Acid). The scales are calibrated every six months to make sure they are correct. If any deviation is noticed before six months have passed, the scales are immediately recalibrated. The calibration schedule is mentioned in our doucment LAB 015 (Schedule for the Calibrati on of Laboratory Equipment and Plant Scales). 2. Training is an ongoing requirement of plant employees. Regarding RMP Training, it is required of any employee assigned to a new task involving RMP chemicals. Refresher training is required every three years. See our document EPA 004 (Risk Management Plan for Hazardous Substances, page 13 of 74, Section 6.54 (Training)). 3. Regarding documentation of storage inspections, our document OPD 002 (Supervisors Daily Plant Inspection Procdedures) gives the daily inspection procedure and an inspection form to document the inspections. These documents are retained for five years. The startup of the process of unloading, handling, storage, and loading of Hydrofluoric Acid shall require inspection of all equipment involved in the process. 4. The document S&H 017 (The Handling and Storage of Hydrofluoric Acid) outlines the process of unloading, handling, storage, and loading of Hydrofluoric Acid drums, and the safety precautions which are required . 5. The document EPA 004 (Risk Management Plan of Hazardous Substances) gives a description of the responsibilities of the Operations Manager and other personnel involved in RMP process in general. The document S&H 017 (The Handling and Storage of Hydrofluoric Acid) gives a description of the Operations Manager and the other personnel involved in the process of unloading, handling, storage, and loading of Hydrofluoric Acid drums. In regard to Pentane safety, this material is brought into the facility in bulk and transfered to a blending tank to be mixed with another petroleum product. After the blend has been made, it is then transfered into drums and placed onto the loading dock to be picked up by a tranportation company within 12 hours. 1a. In a Worst Case Scenario (such as accidental release of all contents from the blend tank), emergency services (such as the fire department) would be informed. Unnecessary personnel would leave the area to a distance of 0.30 miles. Other facil ities would be informed within this distance, and appropriate personal protective equipment (including self-contained breathing apparatus) would be put on trained personnel, the spill would be contained by diking the spill area, and put into a salvage container for disposal. See our document ER 002 (Delta Emergency Response Plan). 1b. In an Alternate Case Scenario (such as a minor leak in drum, releasing some of its contents), emergency services (such as the fire department) would be informed. Unnecessary personnel would leave the area to a distance of 0.10 miles. Other facilities would be informed within this distance, and appropriate personal protective equipment (including self-contained breathing apparatus) would be put on trained personnel, the spill would be contained by diking the spill area, and put into a salvage container for disposal. See our document ER 002 (Delta Emergency Response Plan). 2. There have been no accidents involving Pentane within the last five years. 3. D elta will respond to all emergency spills involving Pentane, and emergency services will be informed of the situation. Other issues involving Pentane include: 1. An examination of the hazards associated with the handling and storage of Pentane. These are covered in our document S&H 037 (The Handling and Storage of Pentane). The scales are calibrated every six months to make sure they are correct. If any deviation is noticed before six months have passed, the scales are immediately recalibrated. The calibration schedule is mentioned in our doucment LAB 015 (Schedule for the Calibration of Laboratory Equipment and Plant Scales). 2. Training is an ongoing requirement of plant employees. Regarding RMP Training, it is required of any employee assigned to a new task involving RMP chemicals. Refresher training is required every three years. See our document EPA 004 (Risk Management Plan for Hazardous Substances, page 13 of 74, Section 6.54 (Training)). 3. Regarding documentation of storag e inspections, our document OPD 002 (Supervisors Daily Plant Inspection Procdedures) gives the daily inspection procedure and an inspection form to document the inspections. These documents are retained for five years. The startup of the process of unloading, handling, storage, and loading of Pentane shall require inspection of all equipment involved in the process. 4. The document S&H 037 (The Handling and Storage of Pentane) outlines the process of unloading, handling, storage, and loading of Pentane, and the safety precautions which are required. 5. The document EPA 004 (Risk Management Plan of Hazardous Substances) gives a description of the responsibilities of the Operations Manager and other personnel involved in RMP process in general. The document S&H 037 (The Handling and Storage of Pentane) gives a description of the Operations Manager and the other personnel involved in the process of unloading, handling, storage, and loading of Pentane. |