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Evans Harvey Corporation, L.L.C.

Parent Companies:
Evans Industries, Inc.
EPA Facility ID:
100000147977
Other ID:
LAR000022517
Facility DUNS:
8158289
Parent Company DUNS:
174781922

Location:

Address:
1601 4th Street
Harvey, LA 70058
County:
JEFFERSON
Lat / Long:
29.900, -90.067 (Get map)
Method:
Interpolation - Photo
Description:
Administrative Building
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Evans Harvey Corporation, L.L.C.
Phone:
(504) 374-6000
Address:
1255 Peters Road
Harvey, LA 70058
Foreign Address:

Person responsible for RMP implementation:

Name:
Frank DiVincenti
Title:
Environmental Manager

Emergency contact:

Name:
Lyle Foret
Title:
VP Packaging and Director HS&E
Phone:
(504) 374-6081
24-hour phone:
(504) 416-8385
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Jefferson Parish Emerg Mgmt
Full-Time Equivalent Employees:
4
Covered by OSHA PSM:
No
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
Yes
Last Safety Inspection Date:
Nov. 15, 2003
Inspecting Agency:
Fire Department
Using Predictive Filing:
Yes

Processes:

Warehousing
RMP ID:
51229
CBI claimed:
No
Program Level:
2
NAICS:
Other Warehousing and Storage (49319)
Chemical name
CAS#
Quantity (lbs.)
CBI
Isopropylamine [2-Propanamine]
75-31-0
530,000
No
Ethylenediamine [1,2-Ethanediamine]
107-15-3
710,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
June 21, 2004
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
No
RMP ID:
35539

Deregistration:

Date:
Effective Date:
Reason:
Source terminated operations
Other Reason:

2. Toxics: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Warehousing)
CBI claimed:
No
Percent weight:
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
60.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • Enclosures
not considered:
  • Dikes
  • Berms
  • Drains
  • Sumps

3. Toxics: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Warehousing)
CBI claimed:
No
Percent weight:
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Enclosures
not considered:
  • Dikes
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in Warehousing)
CBI claimed:
No
Percent weight:
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown

4. Flammables: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Warehousing)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Blast walls

5. Flammables: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Warehousing)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Excess flow valve

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

No Prevention Program level 3

8. Prevention Program level 2

Warehousing, Other Warehousing and Storage (49319)
Prevention Program ID:
19643
Safety Review Date
Dec. 4, 1998, since latest RMP submission
PHA Update Date
, since latest RMP submission
Safety Regulations
  • NFPA 58
  • OSHA (Ammonia)
Hazards Identified
  • Toxic Release
  • Fire
  • Explosion
  • Hurricanes
Process Controls
  • Grounding Equipment
Mitigation Systems
  • Sprinkler System
  • Dikes
  • Fire Walls
Monitoring Systems
  • Process Area
Changes since PHA
  • Reduced Inventory
  • Increased Inventory
Training Type
  • Classroom
  • On the Job
Competency Testing
  • Demonstration
  • Observation
Procedure Review Date
April 1, 1999, since latest RMP submission
Training Review Date
April 1, 1999, since latest RMP submission
Maintenance Review Date
April 15, 2004, since latest RMP submission
Maintenance Inspection Date
April 15, 2004, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Management of Change Review Date
Pre-startup Review Date
Compliance Audit Date
None
Compliance Audit Change Completion Date
None
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Hot Work Review Date
Contractor Safety Review Date
, since latest RMP submission
Contractor Safety Eval. Date
, since latest RMP submission

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
Aug. 4, 1998
Local Response Agency:
Local Response Agency Phone:
(504) 364-3762
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

RISK MANAGEMENT PROGRAM (RMP)
EXECUTIVE SUMMARY
Evans Harvey Corporation, L.L.C.
1601 4th Street
Harvey, Louisiana 70058

ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES

We at Evans Harvey Corporation, L.L.C. (Evans Harvey) are committed to employee, public and environmental safety. This commitment is inherent to our comprehensive accidental release prevention program which covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. If such a release does occur, our trained emergency response personnel are at hand to control and mitigate the effects of the release.

DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES

The Evans Harvey facility's primary activity is the warehousing of chemicals. Evans Harvey warehouses up to 2 RMP-regulated substances at our facility. These substances are listed below. Evans Harvey receives the regulated substances in bulk and stores the products. Drummed products are either warehoused or shipped, depending on customer specifications. The inventories of RMP-regulated substances at the facility are dependent upon customer orders, and not all regulated substances are present on site at a given time. The following summarizes (1) the RMP-regulated toxic and flammable substances that may exceed the RMP threshold quantity at the facility, (2) the Chemical Abstract Service (CAS) numbers associated with the regulated substances, and (3) the maximum quantities of RMP-regulated substances that may be at the facility:

RMP Toxic Substance CAS No. Maximum Quantity (pounds)

Ethylenediamine 107-15-3 710,000

RMP Flammable Substance

Isopropylamine 75-31-0 530,000

OFFSITE CONSEQUENCE ANALYSIS

Evans Harvey is the operator of a stationary source that has
more than the threshold quantity of RMP-regulated substances in a process and is, therefore, subject to the RMP rule (40 CFR 68). The RMP-regulated process at the Evans Harvey facility is subject to the Program 2 requirements of the RMP rule. The Program Level 2 requirements apply because the worst-case scenario for the process reaches nearby public receptors (e.g., industrial neighbors) and the process is (1) not subject to OSHA's process safety management (PSM) standard (29 CFR 1910.119) and (2) not associated with any of the high risk North American Industry Classification System (NAICS) codes listed in the RMP rule.

The RMP rule requires that an offsite consequence analysis be performed for hypothetical releases of RMP-regulated substances at the facility. For Program 2 processes, the RMP rule requires that one worst-case release scenario be presented in the risk management plan for each hazard class (i.e., one toxic scenario and one flammable scenario). The RMP rule also requires that more likely release scenarios, referred to as alternative release scenarios, be presented in the risk management plan. One alternative release scenario must be presented for each RMP-regulated toxic substance at the facility, and one alternative release scenario must be presented for the RMP-regulated flammable substances collectively.

In performing the offsite consequence analysis of the worst-case and alternative release scenarios, Evans Harvey used EPA's RMP*Comp software. RMP*Comp is based on the look-up tables and equations provided in EPA's "Risk Management Program Guidance for Offsite Consequence Analysis."

Worst-case Release Scenarios

For the RMP-regulated toxic substances, the worst-case scenario is a release of 403 pounds (one drum) of a liquid ethylenediamine inside a warehouse building. The released liquid forms an evaporating pool. The toxic vapor cloud generated by the evaporating pool is expected to reach offsite locations.

For the RMP-regulated flammab
le substances, the worst-case scenario is a release of 305 pounds (one drum) of isopropylamine inside a warehouse building. The released material ignites, resulting in a vapor cloud explosion. The pressure wave resulting from the explosion is expected to reach offsite locations.

Alternative Release Scenarios

For the RMP-regulated toxic substances, only one alternative release scenario is required to be reported in the risk management plan. The alternative release scenario for ethylenediamine is a release of 200 pounds of liquid from a drum over a 5-minute period (the time required for the operator to orient the drum to stop the leak). The released liquid forms an evaporating pool inside the warehouse building. The toxic vapor cloud generated by the evaporating pool is not expected to reach offsite locations.

For the RMP-regulated flammable substances, only one alternative release scenario is required to be reported in the risk management plan. A spill of 610 pounds (two drums) of isopropylamine in the warehouse building is selected as the alternative release scenario. The liquid pool formed by the release ignites, resulting in a pool fire. The thermal radiation generated by the pool fire is not expected to reach offsite locations.

GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND THE CHEMICAL-SPECIFIC PREVENTION STEPS

Evans Harvey has taken the necessary steps to comply with the accidental release prevention requirements of the RMP rule (40 CFR 68). The repackaging and warehouse processes at our facility are subject to EPCRA Section 302 notification requirements. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source.

Safety Information

Evans Harvey maintains a record of safety information that describes the chemical hazards, operating parameters, and equipment designs associated with all processes.

Hazard Review

Our facility conducts comprehensive studies to ensure that ha
zards associated with our processes are identified and controlled efficiently. The checklist method is used to carry out our process hazard reviews. The studies are undertaken by a team of personnel with experience in engineering and process operations and are revalidated on a regular basis or when there is a change in the process. Any findings related to the hazard review are addressed in a timely manner.

Operating Procedures

For the purposes of safely conducting activities within our covered processes, Evans Harvey maintains written standard operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown, and startup after maintenance. The information is regularly reviewed and is readily accessible to operators involved in the processes.

Training

Evans Harvey has a training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with those processes. New employees receive training and are tested for competency before starting work. Refresher training is provided on a regular basis and more frequently as needed.

Maintenance

Evans Harvey carries out documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes pressure valves, hoses and piping systems, relief and vent systems, emergency shutdown systems, controls, and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a timely manner.

Compliance Audits

Evans Harvey will conduct audits on a regular basis to ensure that the facility remains in compliance with the RMP rule requirements. These audits will be carried o
ut at least every 3 years, and any corrective actions required as a result of the audits will be undertaken promptly.

Incident Investigation

Evans Harvey promptly investigates any incident that has resulted, or could reasonably have resulted, in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years.

FIVE-YEAR ACCIDENT HISTORY

There have been no onsite or offsite releases in the past 5 years at the Evans Harvey facility that are required to be reported in the risk management plan.

EMERGENCY PLANNING AND RESPONSE

Evans Harvey has a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response, including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident return to work procedures.

To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response.

PLANNED CHANGES TO IMPROVE SAFETY

Since the implementation of the various elements of our accidental release prevention program, there have been no developments or findings that indicate the immediate need to improve safety at our facility. We have a continuous improvement policy in place that includes safety issues.