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St. Gabriel Offsite Warehouse

Parent Companies:
Greif
EPA Facility ID:
100000213663
Other ID:
Facility DUNS:
0
Parent Company DUNS:
8176364

Location:

Address:
4200 Geigy Access Rd
St. Gabriel, LA 70776
County:
IBERVILLE
Lat / Long:
30.245, -91.084 (Get map)
Method:
Unknown
Description:
Plant Entrance (General)
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:

Owner/Operator:

Name:
Delta St. Gabriel
Phone:
(504) 374-6000
Address:
3950 Highway 30 South
St. Gabriel, LA 70776
Foreign Address:

Person responsible for RMP implementation:

Name:
Christi Nelson
Title:
Plant Manager

Emergency contact:

Name:
Bobby Gibbs
Title:
Operations Manager
Phone:
(225) 642-3910
24-hour phone:
(504) 329-2296
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(225) 642-2577
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Full-Time Equivalent Employees:
2
Covered by OSHA PSM:
No
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Inspecting Agency:
Never had one
Using Predictive Filing:
No

Processes:

Warehousing TDI
RMP ID:
1000023957
CBI claimed:
No
Program Level:
2
NAICS:
Other Chemical and Allied Products Merchant Wholesalers (42469)
Chemical name
CAS#
Quantity (lbs.)
CBI
Toluene 2,4-diisocyanate [Benzene, 2,4-diisocyanato-1-methyl-]
584-84-9
300,000
No
Toluene 2,6-diisocyanate [Benzene, 1,3-diisocyanato-2-methyl-]
91-08-7
300,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Delta Comapnies Group
Address:
10352 River Road
St. Rose, LA 70087
Foreign Address:

Phone:
(505) 467-1399

Latest RMP Submission:

Date:
May 23, 2011
Type:
First-time submission
Reason:
Registered:
No
RMP ID:
1000019600

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 TDI)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Rural
Passive mitigation
considered:
  • pooling
not considered:
  • Dikes
  • Enclosures
  • 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 TDI)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Rural
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Sprinkler systems
not considered:
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in Warehousing TDI)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Rural
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Sprinkler systems
not considered:
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown

4. Flammables: Worst-case

None

5. Flammables: Alternative release

None

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

No Prevention Program level 3

8. Prevention Program level 2

Warehousing TDI, Other Chemical and Allied Products Merchant Wholesalers (42469)
Prevention Program ID:
1000016349
Safety Review Date
Nov. 30, 2010, since latest RMP submission
PHA Update Date
, since latest RMP submission
Safety Regulations
  • OSHA (Ammonia)
Hazards Identified
  • Toxic Release
Process Controls
  • None
Mitigation Systems
  • Sprinkler System
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classroom
Competency Testing
  • None
Procedure Review Date
Dec. 15, 2010, since latest RMP submission
Training Review Date
Jan. 12, 2011, since latest RMP submission
Maintenance Review Date
Nov. 30, 2010, since latest RMP submission
Maintenance Inspection Date
Jan. 14, 2011, 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:
Jan. 12, 2011
Local Response Agency:
Local Response Agency Phone:
(225) 687-5140
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

1.0 EXECUTIVE SUMMARY AND CERTIFICATION

1.1 SITE INFORMATION
The main operation of Delta St. Gabriel is contract chemical packaging, warehousing and distribution. The facility was completed and began operation in 2010. The facility is located at 4200 Geigy Access Rd, St. Gabriel, Louisiana 70776.

1.2 ACIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICES
Delta St. Gabriel Off-site Warehouse is committed to employee, public and environmental safety. This commitment is inherent to comprehensive accidental release prevention program that covers areas such as design, instillation, operating procedures, maintenance and employee training on facility processes. It is Delta's policy to implement appropriate controls to reduce and prevent the release of regulated substances. Delta has trained personnel on site to assist in emergency release response.

1.3 THE STATIONARY SOURCE AND THE REGULATED SUBSTANCE HANDLED
Delta St. Gabriel Off-site Warehouse primary activity is the warehousing and distribution of chemicals. The regulated substance handled by the facility is listed below. Delta St. Gabriel Off-site Warehouse receives the regulated substances in 55-gallon drums for storage. Inventory is dependent upon customer orders and the regulated substance may not always be present onsite.

Chemical CAS No.
Toxic Substances:
Toluene 2,4 Diisocyanate 584-84-9
Toluene 2,6 Diisocyanate 91-08-7

1.4 THE WORST CASE RELEASE SCENARIOS AND THE ALTERNATIVE RELEASE SCENARIOS
Delta St. Gabriel Off-site Warehouse is the operator of a stationary source that has more than the threshold quantity of a regulated substance in storage, as determined under 40 CFR 68.115 and therefore is subject to 40 CFR Part 68 - Chemical Accident Prevention Provisions. Delta St. Gabriel Off-site Warehouse is a Program 2 level facility.
To evaluate the worst case and alternative scenarios, EPA's RMP*Comp program was used to evaluate off-site consequences. RMP*Comp is based on the look-up tables and equ
ations provided by the EPA in the RMP Offsite Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenarios.

The worst-case scenarios for the two toxic chemicals involve the dropping of four drums and release of their entire content inside the warehouse (est. 220 gallons). The alternative release scenarios involve the puncture of a drum and release of its entire contents inside the warehouse (est. 55 gallons). Neither one of these scenarios is likely to result in the actual loss of the entire amount of the regulated substances from the vessel because of onsite personnel and other mitigation techniques, but for the worst case and alternative case scenarios these situations were used as potential possibilities that could have offsite consequences, as required by 40 CFR 68.25 and 40 CFR 68.28.

1.5 THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND THE CHEMICAL-SPECIFIC PREVENTION STEPS
Delta St. Gabriel Off-site Warehouse has taken the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR Part 68. The packaging and warehouse process at the facility is not subject to the OSHA PSM standard under 29 CFR 1910.119. Delta St. Gabriel is subject to EPCRA Section 313 notification requirements. The following sections briefly describe elements of the release prevention program that is in place at the stationary source.

Process Safety Information
Delta St. Gabriel Off-site Warehouse maintains a record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with the process. There is no transfer of TDI at the facility, only storage.

Process Hazard Review
This facility conducts process hazard reviews to ensure that hazards associated with the process are identified and controlled efficiently. The checklist and what if methods are used to carry out the process hazard analyses. The process hazard analysis is undertaken by a team of qualifie
d personnel with expertise in facility engineering and storage and distribution operations. Changes in the operations such as adding TDI to the storage and distribution mix will cause Delta to reevaluate the process using the prescribed hazard analysis and what if scenarios. Any findings related to the reevaluation will be addressed in a timely manner.

Operating Procedures
For the purposes of safely conducting activities within the covered process, Delta St. Gabriel Off-site Warehouse maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency operations, normal shutdown and startup after maintenance. The information is regularly reviewed and is readily accessible to operators involved in the process.

Training
Delta St. Gabriel Off-site Warehouse has a training program in place to ensure that employees are competent in the operating procedures associated with those processes. New employees receive training before starting work. Operating procedures are reviewed annually and more frequently as needed.

Mechanical Integrity
Delta St. Gabriel Off-site Warehouse carries out documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks include among others; fire system, forklift maintenance and equipment used to ship drums. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices and or contracted out to service companies. Personnel receive specialized on the job training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a timely manner.

Management of Change
Written procedures are in place at Delta St. Gabriel Off-site Warehouse to manage changes in chemicals being packaged, technology, equipment and procedures. Operators and maintenance personnel and service contractors whose job tasks are affected by a
change or modification of process conditions are made aware of the changes.

Pre-startup Reviews
Pre-startup safety reviews related to new processes and modifications in existing processes are conducted as needed. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment in operation.

Compliance Audits
Delta St. Gabriel Off-site Warehouse conducts compliance audits to determine whether the provisions set out under the RMP rule are being implemented. These audits will be carried out at least every 3 years and any corrective actions as a result of the audits will be undertaken promptly.

Incident Investigation
Delta St. Gabriel Off-site Warehouse promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the root cause of the incident as well as any corrective actions to prevent the incident from recurring. Reports are retained in the web based CMS system.

Employee Participation
Delta St. Gabriel Off-site Warehouse believes that incident prevention is a team effort and involves employees in the incident prevention process. Delta employees have access to the information created as part of facility's implementation of the RMP rule, including information resulting from process hazard analyses.

Contractors
On occasion, the company hires contractors to conduct specialized maintenance and construction activities. Delta St. Gabriel Off-site Warehouse has a policy of informing the contactors of known potential hazards related to the contactor's works. Contractors are also informed of emergency procedures should an accidental release of a regulated substance occur.

1.6 FIVE-YEAR ACCIDENT HISTORY
There has been no release of RMP chemicals at the Delta St. Gabriel Off-site Warehouse site over the past 5 years.

1.7 EMERGENCY RESPONSE PLAN
Delta
St. Gabriel Off-site Warehouse has a written emergency response plan for responding to accidental releases of hazardous materials. The plan covers the aspects of emergency response including adequate first aid and medical treatment, evacuations, notifications of local emergency response agencies and the public, as well as post-incident return to work procedure.

The plan is updated regularly to reflect relevant changes taking place within the process that would require a modified emergency response.

1.8 PLANNED CHANGES TO IMPROVE SAFTY
There are no planned changes to the Delta St. Gabriel Off-site Warehouse with the exception of adding TDI to the chemical storage and distribution list and developing and implementing an RMP Plan for the facility. Delta has a continuous improvement policy in place that includes safety improvement.