Jacobson Warehouse Company, Inc. - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

Jacobson Warehouse Company, Inc. ("JWC"), complies with applicable federal, state and local regulations regarding the storage of hazardous materials.  In addition, all warehouse personnal are trained in emergency response actions, as required by the OSHA regulation, 1910.120.  JWC also has a contract with a national mitigator (CURA) to provide onsite assistance in the event of a significant spill 
 
This facility is a 115,000 square foot warehouse in which a variety of chemical products are stored, including toluene-2,4,-diisocyanate and toluene 2,6-diisocyanate in amounts in excess of the Threshold Quantities for Extremely Hazardous Chemicals. 
 
The worst-case scenario submitted in the RMP was for the release of one 55-gallon drum containing 80% toluene 2,4-diisocyanate under the conditions described in the EPA Risk Management Guidance for Warehouses.  Under this scenario, the toxic endpoint of <0.1 mile does not include any residential or environmental receptors.  However, other industr 
ial and warehousing facilities are within this radius.  The RMP Submit software does not permit values for rate of release below 0.2 lb/min.  However, the release rate for toluene 2,4-diisocyanate is 0.0032 lb/min.  The passive containment system in the warehouse was not considered in this worst-case scenario. 
 
The alternative case scenarios submitted in the RMP were for the release of one 55-gallon drum containing 80% toluene 2,4,-diisocyanate and for the release of one 55-gallon drum containing 20% toluene 2,6-diisocyanate under the alternative conditions described in the EPA Risk Management Guide for Warehouses (Stability Class D; Wind Speed 3.0 m/s).   Under each of these alternative scenarios, the toxic endpoints are <0.1 mile.  These radii do not include any residential or environmental receptors.  However, other industrial and warehousing facilities are within 0.1 mile.  The RMP Submit software does not permit values for rate of release below 0.1 lb/min.  However, the release ra 
te for toluene 2,4-diisocyanate is 0.0032 lb/min and for toluene 2,6-diisocyanate is 0.0095 lb/min.  The passive containment system in the warehouse was not considered in these alternative scenarios. 
 
This facility complies with the EPA RMP regulations and all other applicable federal, state, and local reuqirements.  Procedures have been implemented for hazard evaluation, emergency response, and employee training.  In addition, the facility has a containment system which features sealed floors sloping away from all openings for primary containment.  The inside primary containment provides a 246,000-gallon capacity and the outside secondary containment provides a 113,118-gallon capacity, and has special rubber liner. 
 
In the past five years, no accidental release has occurred. 
 
JWC has implemented an emergency response plan which contains the following elements:  Emergency Contacts; Written Program Availability, Review, and Updates; Pre-Emergency Planning and Coordination with Outside P 
arties; Personnel Roles, Lines of Authority, Training, and Communication; Emergency Recognition and Prevention; Safe Distances and Places of Refuge; Site Security and Control; Evacuation Routes and Procedures; Decontamination; Emergency Medical Treatment; Emergency Alerting and Response Procedures; Critique of Response and Follow-Up; Emergency Response Plan Review; Training Requirements; and Signs and Symptoms of Anticipated Emergencies. 
 
The emergency response plan is updated at least annually whenever a new product, process, or personnel change occurs that could affect the procedures and information contain therein.  Employee training is conducted prior to assignment to tasks requiring emergency response techniques and at least annually thereafter. 
 
There are no planned changes to the safety program.
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