Unilever Chicago Consolidated Distribution Center - Executive Summary

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The accidental release prevention and emergency response policies at your facility: This facility complies with OSHA 29CFR1910.38 requirements, and it is our policy to adhere to all applicable federal, state, and local laws. If an emergency were to occur, the Unilever Warehouse 107 would coordinate with the Chicago Fire Department and other agencies in Cook County should they be requested to respond to an emergency. 
A description of your facility and the regulated substances handled. This facility warehouses consumer aerosol products containing a mixture of the following regulated substances under 112(r) stored above the threshold quantity:  
* Propane  
* Butane  
* Isobutane  
* Methyl Ether  
* Difluoroethane  
The worst-case release scenario. The worst-case scenario is failure of one 14-ounce aerosol container (this contains 0.30 pounds of propellant). The worst-case scenario would affect a radius of 0.005 miles, which does not affect any off-site receptors.  Due to 
limitations of RMP*Submit, the input parameters were 1 pound and 0.01 miles. 
The general accidental release prevention program and chemical-specific prevention steps. This facility complies with EPA's accident prevention rule and all applicable state and local codes and regulations.  
Five-year accident history. No accidents involving the aerosol products stored at this facility have caused deaths, injuries, property or environmental damage, evacuations, or shelterings-in-place at this facility. 
The emergency response program. If an emergency were to occur, the Warehouse 107 facility would coordinate with the Chicago Fire Department.   
Planned changes to improve safety. None. 
1.0 Overview of Risk Management Program 
Unilever Chicago Consolidated Distribution Center has assembled this program notebook to document methods for meeting Risk Management Program (RMP) requirements from the Clean Air Act Section 112(r).  The program is divided into these sections.  
1.0    Overview of Risk 
Management Program    1 
2.0    Applicability of Risk Management Program    1 
3.0    Management of Risk Management Program    3 
4.0    Program Data    4 
4.1.    Executive Summary    4 
4.2.    Registration    5 
4.3.    Offsite Consequence Analysis    7 
4.4.    Five-Year Accident History    8 
4.5.    Emergency Response    8 
4.6.    Certifications    8 
2.0 Applicability of Risk Management Program 
The Clean Air Act (CAA) Amendments of 1990 amend Section 112 and add paragraph (r).  The intent of Section 112(r) is to prevent accidental releases to the air and mitigate the consequences of such releases by focusing prevention measures on chemicals that pose the greatest risk to the public and the environment. 
Section 112(r)(7) of the CAA Amendments mandates that the Environmental Protection Agency (EPA) promulgate regulations and develop guidance to prevent, detect, and respond to accidental releases.  In response, the Final Rule and Notice for the Risk Management Program was issued on June 20, 1996 and is found at Title 40, Part 68 of the Code  
of Federal Regulations (40 CFR 68). Stationary sources with processes that contain more than a threshold quantity of a regulated substance are covered by these regulations and must develop a Risk Management Program.  The program must be described in a Risk Management Plan (RMP), which, in turn, must be registered with the EPA, submitted to state and local authorities, and made available to the public.  
An owner or operator of a stationary source that has more than a threshold quantity of a regulated substance in a process, must comply with the Accidental Release Prevention Requirements found at 40 CFR 68 by no later than the latest of the following dates: 
7 June 21, 1999; 
7 Three years after the date on which a regulated substance is first listed under 40 CFR 68.130; or 
7 The date on which a regulated substance is first present above a threshold quantity in a process. 
Unilever Chicago Consolidated Distribution Center (Unilever) stores aerosol products in their Chicago, Illinois ware 
house containing a mixture of the following regulated substances under 112(r) stored above the threshold quantity:  
7 Propane (CAS No. 74-98-6) 
7 Butane (CAS No. 106-97-8) 
7 Isobutane (CAS No. 75-28-5) 
7 Methyl Ether (CAS No. 115-10-6) 
7 Difluoroethane (152a) (CAS No. 75-37-6) 
The largest container has been calculated to be 14 ounces. The storage of these constitutes one process. 
Processes are divided into three categories (or 'Programs') based on the following: 
7 Potential for offsite consequences associated with a worst-case accidental release; 
7 Accident history; or 
7 Compliance with the prevention requirements under the Occupational Safety and Health Administration's (OSHA)  
Modeling of the worst-case accidental release from a single 14-ounce vessel indicates that no offsite receptors could be affected.  As a result, the facility qualifies for Program 1.  In addition, the facility is not subject to the OSHA Process Safety Management Standard (no Highly Hazardous Chemicals are  
stored), so the facility does not qualify for Program 3. 
All facilities regardless of Program level must report the following to EPA: 
7 Executive Summary 
7 Registration 
7 Offsite Consequence Analysis - Worst-case 
7 Five-Year Accident History 
7 Emergency Response Program 
7 Certification 
7 Updates 
The Program 1 RMP includes a Worst-case Analysis for the process as well as coordination with the local responders.  
This document contains guidance and documentation for managing the RMP compliance program. 
3.0 Management of Risk Management Program 
Unilever has assigned the following qualified position: 
Manager of Distribution 
responsibility for the development, implementation, and integration of the Risk Management 
Program (RMP) elements as required in 40 CFR 68.15(b). 
This documentation must be updated when personnel or position changes are made.  The site person named above is responsible for keeping this management document updated.  The management program document was updated o 
6/14/99 - Mike Glazik 
 4.0 Program Data 
This section of the program notebook outlines data types, sources, and examples for on-going submittals of the Risk Management Plan that describes the facility's risk management program. The RMP consists of a brief executive summary and a set of data.  The following areas will be reviewed: 
7 Executive Summary 
7 Registration 
7 Offsite Consequence Analysis - Worst-case 
7 Five-Year Accident History 
7 Certifications 
EPA has developed an electronic submission system for filing the RMP.  The software called RMP*Submit, is available from EPA's Internet website at http://www.epa.gov/ceppo.  The software provides all the necessary instructions to complete the RMP.  The completed electronic RMP is submitted to EPA by copying it onto a 3=-inch diskette and mailing the diskette to EPA. 
The bulk of the RMP is filling in names, addresses, and numbers, and checking boxes. After completing the previous chapters of this notebook, most of the information  
required to complete the RMP has already been gathered. 
4.1. Executive Summary 
The eight subject headings per 40 CFR 68.155 are contained in the executive summary for the Unilever Chicago Consolidated Distribution Center. A sample of the executive summary is contained in the RMP*Submit file for the facility.  To edit the executive summary, install RMP*Submit from the CEPPO webpage.  The datafiles for RMP*Submit are SRMPDATA.LDB and SRMPDATA.MDB on the facility data diskette.  These files must be copied into the installation directory for RMP*Submit. 
The owner of updates to the RMP will maintain the executive summary with each resubmittal of the RMP to EPA.  The following table indicates the revision history of the executive summary. 
Executive Summary Revision History 
Date    Owner    Filename    Reason for change 
6/14/99    Dames & Moore     SRMPDATA.MDB    Original submittal for RMP 
4.2. Registration 
The registration data consists of facility information such as location, SIC 
/NAICS codes, process description, program ownership, and emergency contact information.  The matrix of requirements, their sources, and revision date follows: 
Registration Data Matrix 
Data Element    Source    Revision Date 
Facility name, street, city, county, state, zip code    Manager of Distribution     6/14/99 
Facility latitude, and longitude, methods    LANDVIEW III and MARPLOT (Digital Mapping); Facility Plans for specific locations of storage tanks     
Facility Dun and Bradstreet number    Corporate Environmental     4/7/99 
Name and Dun and Bradstreet number of the corporate parent company;    Corporate Environmental     4/7/99 
Name, telephone number, and mailing address of the owner or operator;    Manager of Distribution    6/14/99 
Name and title of the person or position with overall responsibility for RMP elements and implementation;    Manager of Distribution    6/14/99 
Name, title, telephone number, and 24-hour telephone number of the emergency contact;    Manager of Distribution    6/14/99 
For each covered process, 
the name and CAS number of each regulated substance held above the threshold quantity in the process, the maximum quantity of each regulated substance or mixture in the process (in pounds) to two significant digits, the NAICS code, and the Program level of the process;    NAICS codes can be cross-referenced against SIC codes at http://www.census.gov/epcd/www/naicstab.htm; 
Process calculations: 14-ounce aerosol can contains approximately 0.30 pounds of propellant. There are 12 cans per case, and 84 cases per pallet.  This warehouse holds 600 pallets. 
The program level is dependent on the accident history and worst case scenario as described in Section 2.0 - Applicability. 
CAS Numbers are found in 40 CFR 68, Appendix A.  See Section 2.0.     
Facility EPA identifier;    Not assigned until RMP received.    NA 
Number of full-time employees     188 - Multiply Part-time Employee Numbers by the fraction of 40-hour week or 52-week year for FTE.     
Whether the stationary source is subject to: 
7 29 CFR 1910. 
7 40 CFR part 355; 
7 or has a CAA Title V operating permit;    Manager of Distribution     6/14/99 
Date of the last safety inspection of the stationary source by a Federal, state, or local government agency and the identity of the inspecting entity.    Manager of Distribution    6/14/99 
4.3. Offsite Consequence Analysis 
Dames & Moore performed the worst case scenario.  Parameters for the worst-case scenario included: 
7 The single largest vessel was calculated at 14 ounces and assumed total loss of contents. 
7 The material was liquefied under pressure. 
7 RMP*Comp was used to model the required Vapor Cloud Explosion.  Ten percent of the loss is assumed to participate in the explosion per 40 CFR 68.25(e).  Other modeling assumptions in RMP*Comp are presented in the modeling output below. 
RMP*Comp Worst-Case Scenario Modeling Output 
RMP*Comp Ver. 1.06 
Results of Consequence Analysis 
Chemical: Isobutane [Propane, 2-methyl] 
CAS #: 75-28-5 
Category: Flammable Gas 
Scenario: Worst-case 
ied under pressure 
Quantity Released: 0.301 pounds 
Release Type: Vapor Cloud Explosion 
Estimated Distance to 1 psi overpressure: .005 miles (.009 kilometers) 
--------Assumptions About This Scenario--------- 
Wind Speed: 1.5 meters/second (3.4 miles/hour) 
Stability Class: F 
Air Temperature: 77 degrees F (25 degrees C) 
RMP*Comp utilizes the same calculations as the EPA Look-up Tables for RMPs (see RMP Offsite Consequence Analysis Guidance, EPA, May 24, 1996).  
The worst-case release scenario was plotted from the warehouse using MARPLOT. This program is available at www.rtk.net. 
4.4. Five-Year Accident History 
This facility has had no accidental releases since the development of the site as a warehouse. 
The five-year accident history forms can be developed from Chapter 3: Five-Year Accident History of Risk Management Program Guidance for Warehouses. However, familiarity with the definitions in the accident history will simplify repo 
rting, including impacts, environmental damage, contributing factors, and changes introduced as a result of the incident.  Definitions are found in Chapter 3. 
If no releases or near misses occur during the five years previous to the RMP renewal, select "No Accidents" in the database entry form. 
4.5. Emergency Response 
The facility has coordinated with the Chicago Fire Department and Mr. Mike Glazik with Unilever HPC - USA has indicated that the facility has coordinated.  Below is the primary emergency contact for the fire department: 
Name:     Mike Glazik    Title:    Manager of Distribution 
Phone:    (773) 292-7441    24-hour phone:    (773) 292-7442 
The facility has indicated that it is a generator of hazardous waste.  For the RMP, it has been assumed that the site is a "conditionally exempt" small quantity generator, not requiring a Emergency Response / Contingency Plan under RCRA.
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