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New Orleans TRANSFLO Terminal

Parent Companies:
TRANSFLO Terminal Services, Inc.
EPA Facility ID:
100000207803
Other ID:
Facility DUNS:
0
Parent Company DUNS:
466610

Location:

Address:
6666 Old Gentilly Rd.
New Orleans, LA 70126
County:
ORLEANS
Lat / Long:
30.009, -90.010 (Get map)
Method:
Address Matching - Other
Description:
Administrative Building
Horizonal accuracy:
1 m
Horizontal reference datum:
World Geodetic System of 1984
Source map scale:

Owner/Operator:

Name:
TRANSFLO Terminal Services, Inc.
Phone:
(904) 359-1323
Address:
500 Water Street
J-975
Jacksonville, FL 32202
Foreign Address:

Person responsible for RMP implementation:

Name:
Jan Barnes
Title:
Director- HS&E and Quality

Emergency contact:

Name:
Terminal Manager
Title:
Terminal Manager
Phone:
(504) 244-4393
24-hour phone:
(866) 872-6735
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(504) 244-4393
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Orleans Parish LEPC
Full-Time Equivalent Employees:
5
Covered by OSHA PSM:
Yes
EPCRA section 302:
No
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Oct. 5, 2012
Inspecting Agency:
US DOT-FRA Haz Mat Inspector
Using Predictive Filing:
No

Processes:

LPG product transfer
RMP ID:
1000057053
CBI claimed:
No
Program Level:
3
NAICS:
Support Activities for Rail Transportation (48821)
Chemical name
CAS#
Quantity (lbs.)
CBI
Butane
106-97-8
180,000
No
Propylene [1-Propene]
115-07-1
180,000
No
Propane
74-98-6
180,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Greg Rhoads & Associates, Inc.
Address:
10950 San Jose Blvd Suite 60
Box 194
Jacksonville, FL 32223
Foreign Address:

Phone:
(904) 880-3111

Latest RMP Submission:

Date:
Aug. 4, 2014
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000045895

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

None

3. Toxics: Alternative release

None

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 LPG product transfer)
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 LPG product transfer)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • Emergency shut off valves with thermal links.
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

LPG product transfer, Support Activities for Rail Transportation (48821)
Prevention Program ID:
1000047587
Safety Review Date
July 16, 2014, since latest RMP submission
PHA Update Date
July 16, 2014, since latest RMP submission
PHA Techniques
  • What if
  • What if/Checklist
Hazards Identified
  • None
Process Controls
  • Relief Valves
  • Check Valves
  • Manual Shutoffs
  • Automatic Shutoffs
  • Grounding Equipment
  • Excess Flow Device
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Written Test
  • Demonstration
  • Observation
Procedure Review Date
July 16, 2014, since latest RMP submission
Training Review Date
July 16, 2014, since latest RMP submission
Maintenance Review Date
July 16, 2014, since latest RMP submission
Maintenance Inspection Date
July 16, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
July 31, 2014
Management of Change Review Date
July 16, 2014
Pre-startup Review Date
July 1, 2009
Compliance Audit Date
April 20, 2012
Compliance Audit Change Completion Date
Sept. 28, 2012
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
May 12, 2014
Hot Work Review Date
May 12, 2014
Contractor Safety Review Date
July 15, 2014, since latest RMP submission
Contractor Safety Eval. Date
July 15, 2014, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

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:
April 22, 2014
Local Response Agency:
Local Response Agency Phone:
(504) 658-4700
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
No
Subject To - OPA:
No
Subject To - State EPCRA:
No
Subject To - Other:

Executive Summary

Executive Summary (40 CFR 68.155)



Background Data



In accordance with Title 40 of the Code of Federal Regulations, chapter 68 (40 CFR 68) promulgated by the Federal Environmental Administration (EPA), TRANSFLO Terminal Services, Inc. has prepared this Risk Management Plan (RMP) for operations involving Liquefied Petroleum Gas (LPG) at their New Orleans, LA facility. The TTSI terminal provides transloading services of bulk products between rail and truck transportation modes. The New Orleans TRANSFLO terminal has been in operation since 1990. The terminal is located at 6666 Old Gentily Road, New Orleans, LA.



Accidental Release Prevention and Emergency Response Policy



TRANSFLO is committed to protecting the health and safety of its employees, contract operators, the surrounding community and the environment; therefore it is TRANSFLO policy to maintain compliance with 40 CFR 68.



Stationary Sources and Regulated Substances



TRANSFLO will handle liquefied petroleum gas (LPG) products at this terminal, transloading product from railroad tank cars into highway cargo trailers in quantities in excess of 8,000 gallons per cargo trailer which will exceed the 10,000 pound threshold quantity listed in 40 CFR 68, Appendix A.



Worst Case Scenario



As required by 40 CFR 68 Subpart B, TRANSFLO has evaluated a worst-case release scenario for LPG products using the parameters specified by the EPA. TRANSFLOAA?s worst-case release scenario is the rupture of a single railroad tank car with subsequent product release over a 10-minute period. In developing the release parameters of the worst-case scenario, TRANSFLO has not considered any passive mitigation measures. Using the EPAs RMP*Comp software program, it was determined that the distance to the toxic endpoint in this scenario has the potential to result in a release with offsite consequences. The worst-case release scenario was developed following EPA regulations and is considered to have an extremely low pr
obability of occurrence.



Alternative Release Scenario



TRANSFLO also evaluated several other release scenarios considered to have a higher level probability of occurrence (although a very low probability) based upon a review of over 10 years of incident data from chemical transloading operations. This 10 year period included the safe handling of over 500,000 rail to truck chemical transloads. After a careful review of both the worst-case and alternative release scenarios, TRANSFLO has decided to include one alternative release scenario into the RMP document.



The alternative release scenario identified by TRANSFLO is the failure of a product transfer hose. In developing the parameters of Alternative Release Scenario 1, TRANSFLO considered the average response time of terminal personnel to control the release and safely shut the transfer unit down. Using the EPA RMP*Comp software program and EPA RMP offsite Consequence Analysis Guidance Document, the distance to the flammable endpoint in the alternative release scenario has the potential to result in minor site consequences at a distance much less than the worst-case scenario and would largely be limited to terminal property itself.



Accidental Release Prevention Program



To prevent and mitigate accidental releases of LPG products, TRANSFLO has implemented several precautionary measures:



1- TRANSFLO has developed standard operating procedures (SOP'S) for the Transloading of LPG products from railcar to highway cargo tank for use by trained and qualified personnel.

2- TRANSFLO encourages contract operator employees to voice concerns, offer suggestions and contribute to procedures, policies and processes involving this product. Employees are expected to follow established procedures until employee driven process changes are implemented, training conducted and communicated to all affected persons.

3-TRANSFLO conducts operational audits and inspections to insure compliance with established operati
ng procedures, maintenance of transfer equipment and facility physical systems.

4-A documented inspection and maintenance program for the transfer unit, railcars and cargo tanks used for this operation is in place and will be maintained for the life of this operation. These processes include preventative maintenance of the transfer unit to maintain on-board safety and control systems.



The transfer unit has been designed and constructed to meet or exceed the requirements outlined in the National Fire Protection Association (NFPA) Liquefied Petroleum Gas (LPG) Code (2008 ed.). A review of the National Fire Code finds this operation is in compliance with all requirements of the code. This process and related equipment is also in conformance with the National Electrical Code (NEC) for hazardous location classification.



TRANSFLO maintains contact with the local emergency responders as part of the terminals emergency action plan (EAP). In addition, the following agencies inspect the TRANSFLO terminal on a regular basis:



U.S. Department of Transportation- Federal Railroad Administration- Hazardous Materials Inspectors



New Orleans Fire Department









Five- Year Accident History



There are no accidents or releases to report since inception of this process.



Emergency Response Program



TRANSFLO and the contract operator have documented emergency response plans and procedures in place at this facility to respond to and safety mitigates any release or accident involving LPG products. Included in the emergency response plan are measures to be taken internally by TRANSFLO contract operators to control the release, if possible, and to make initial notification to local responders and to TRANSFLO headquarters.



Operator personnel at the terminal are trained to the Hazardous Materials Operations level as outlined in 29 CFR 1910.120 Hazardous Waste Operations and Emergency Response. These employees may also perform activities under the specialist
employee definition as defined by 1910.120. These personnel receive annual training on activation of the facility emergency action plan, their roles in an emergency and accident notification procedures.



To assure that the local municipal response agencies are familiar with TRANSFLO emergency response procedures and copies of the Emergency Action plan (EAP) have been shared with and reviewed by local responders. In the event of a significant release of LPG products that involve off site populations, these populations will be notified through the LEPC.



Planned Changes to Improve Safety



TRANSFLO and its contract operators have implemented a continuous training program for employees and preventative maintenance procedures for the transfer unit to ensure a high level of safety performance and regulatory compliance.





RMP Resubmittal- 08012014-GAR