Delta Terminal Services, Inc. - Executive Summary |
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26907 LDEQ Facility ID Number The United States Environmental Protection Agency (USEPA) developed the Risk Management Program (RMP) rule (40 CFR 68) to assist facilities in preventing accidental releases of highly toxic or flammable chemicals. The RMP established three levels of requirements for the program. Programs 1 and 2 are for facilities that pose less risk to the environment and therefore have reduced compliance requirements. Program 1 is designed for "no impact" facilities and has the fewest requirements, while Program 3 is the most stringent of the three levels. The program level for each facility is determined by: Use of regulated substances in threshold quantity Impact of an off-site public receptor (e.g., residence, school, park) North American Industrial Classification System (NAICS) code Five-year accident history OHSA PSM (29 CFR 1910.119) applicability. This facility is regulated under Program 2 requirements under 40 CFR 68.10 because: It stores toluene 2, 4-diisocyanate and chloroform in excess of the threshold quantities A release from this facility could impact an offsite public Receptor (residence) It does not operate under a NAICS code specified in the rule It is not subject to OSHA PSM because PSM does not apply to flammable liquids stored in atmospheric tanks which are kept below their normal boiling point without benefit of chilling or refrigeration [29 CFR 1926.64(a)(1)(ii)(B)].). 40 CFR Part 68 Subpart G applies to an owner or operator of a stationary source that has more than a threshold quantity of a regulated substance in a process, as determined under 40 CFR 68.115 Delta Terminal Services stores more than the threshold quantity of toluene 2, 4-diisocyanate (10,000) and chloroform (20,000 pounds). Therefore, Delta Terminal Services is required to submit a Risk Management Plan (RMP) as defined in 40 CFR 68.150 by June 20, 1999 . The Delta Terminal is committed to operating in a safe and compliant manner. Employees involved in operating the TDI and chloroform storage facility are thoroughly trained to identify and understand the hazards posed by this the transfer process. Process safety and emergency response materials are kept on site and periodically reviewed. Information includes information pertaining to the hazards of TDI and chloroform, process technology, process equipment, and emergency response procedures. The stationary source is the Delta Terminal Services toluene 2, 4-diisocyanate and chloroform storage facility. The largest TDI process group (e.g., largest storage tank or group of interconnected tanks) has a storage capacity of 1,050,000 gallons (10,678,000 pounds). The total TDI stationary storage capacity is 33,000,000 pounds. The facility also has 1,400,000 gallons (18,000,000 pounds) of chloroform in a single tank. The total chloroform stationary storage capacity is 18,000,000 pounds . The facility is required to complete one worst-case release scenario per hazardous substance handled [68.165(a)(2)] to determine program applicability. Delta Terminal has chosen to use the DEGADIS+ and Chloroform Evaporating Pool Model [as described in the article " The Evaporation of Volatile Liquids" (Hazardous Materials vol 15, pg 343-364] release models to determine offsite impacts. For this facility, a worst-case release would occur in the event that the largest TDI and chloroform storage tanks would rupture and the entire contents would be released to the atmosphere through evaporation. Both spills were modeled as continuous release because it would require more than 60 minutes to evaporate the contents of the tank. In the case of TDI, the evaporation would take more than 3,700 hours. The worst-case scenario requires a ground-level release height (0 feet). Results of Worst-Case TDI Release Scenario Input of the preceding data into the DEGADIS+ release model, the resul ts indicate a worst-case impact of 0.17 miles for the facility. The rule defines the toxic endpoint of toluene 2, 4-diisocyanate to be 7 mg/m3. The offsite population within a 0.17 mile radius of the facility is 25 based on the 1990 US Census data. While there are no residence with the affected radius, there are several businesses located within the potential impact area. Results of Worst-Case Chloroform Release Scenario The Chloroform Evaporating Pool Model summary for chloroform results in a worst-case impact of 0.69 (rounded) miles for the facility. The rule defines the toxic endpoint of Chloroform 490 mg/m3. The residential population within a 0.69 mile radius of the facility is 2,000 (rounded) based on the 1990 US Census data. The facility is required to complete one alternate release scenario per regulated chemical per 40 CFR Part 68.165(a)(2). The alternative release scenario considered is in accordance with the guidelines provided in 40 CFR 68.22 and 68.28. The alt ernative scenarios chosen for this facility involves a release because of a spill during transfer operations. While this scenario is still unlikely because the operators are present during transfer operations, it is more likely than the worst-case as required by 40 CFR 68.28(b)(i). Because personnel are always present at the facility during transfer, Delta Terminal personnel will respond within 10 minutes. However, the release rate was calculated as continuous evaporation from a 2,500 gallon spill. Results of TDI Alternative Release Scenario There are 0 people located within 0.0 miles from the facility. Results of Chloroform Alternative Release Scenario The Chloroform Evaporating Pool Model indicates an alternate case impact of 0.28 miles for the facility. The residential population within this radius is 240 based on 1990 census data. The facility maintains written process safety information to enable employees involved in handling TDI and chloroform to identify and unders tand the hazards posed by this process. Written information includes physical properties of TDI and chloroform, health risks associated with TDI and chloroform exposure, and material safety data sheets. In addition, the facility has conducted and/or implemented the following: hazards review standard operating procedures training program maintenance program compliance audits incident investigation Delta Terminal Services facilities which store toluene 2, 4-diisocyanate and chloroform have no recordable accidents within the past five years. Recommendations for safety improvements were identified in the hazard review which was completed April 20, 1999. Recommendations were identified for two categories: Standard Operating Procedures, and Training. Safety improvements will be investigated concerning their impacts on other systems and/or procedures prior to implementation. Additio nal recommendations may be made upon review of any accidents and/or when the hazard review is updated every five years. |