Inland Star Distribution Centers - Executive Summary |
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Inland Star Distribution Center, Inc. (Inland Star) owns and operates an agricultural and industrial chemical distribution center in Fresno, Fresno County, California (Facility). Inland Star is committed to the prevention and minimization of accidental releases of potentially hazardous chemicals it is the policy of the Facility to adhere to all applicable federal, state, and local regulations. As such, Inland Star maintains an on-site HAZWOPER certified emergency response team, has installed high density sprinkler and foam extinguishing systems and has graded the site to drain to containment tanks in order to prevent releases. To meet their commitment to prevention, Inland Star has implemented a comprehensive EPA Risk Management Plan (RMP) to address regulatory requirements from Section 112(r) of the Clean Air Act (CAA). Based on the regulatory requirements and on Facility operations, a Program Level 2 Prevention Program has been prepared for Facility operations. The Facility stor es agricultural and industrial chemicals for distribution to chemical manufacturers, dealers and distributors. Several of these chemicals could potentially pose a health hazard to Facility staff and off-site populations in the event of an accidental release of stored material. The chemicals stored in the warehouse process at the Facility, that are in sufficient quantity to be regulated under EPA RMP regulations (40 CFR, Part 68) are: - 68,800 pounds of ethylene oxide (CAS No. 75-21-8) - 7,914 pounds of butane (CAS No. 106-97-8) - 13,247 pounds of isobutane (CAS No. 75-28-5) - 9,755 pounds of propane (CAS No. 74-98-6) Butane and Propane were included in this RMP as the stored quantities are within 20% of the threshold planning quantities. This RMP includes a review of potential hazards associated with the storage and handling of the regulated chemicals at the Facility, operational procedures, maintenance procedures, and employee training. Periodic safety reviews are communicated to employees to reduce the possibility of an accidental release. To minimize the hazards presented by an accidental release to Facility staff or the public, Inland Star has prepared an emergency response plan that coordinates the actions of Facility staff with local emergency responders. The Facility's emergency response program is based upon the EPA Emergency Planning and Community Right to Know Act Regulations, federal and state OSHA Emergency Action Plan and HAZWOPER regulations, (California Business Plan regulations) the industry's Pre-Fire Planning program, and internal procedures. This information has been provided to the Local Emergency Planning Committee and to local emergency response agencies. Facility staff indicate that there have been no accidental release of ethylene oxide (CAS No. 75-21-8) or any of the flammable products, butane (CAS No. 106-97-8), isobutane (CAS No. 75-28-5), and propane (CAS No. 74-98-6), at the Facility within the last five years. However, as re quired under the CAA, Inland Star has evaluated the worst-case toxic and flammable release scenarios using parameters described in 40 CFR 68.25. An alternative case toxic and flammable release scenario was evaluated using parameters described in 40 CFR 68.28. These analyses indicated that in the event of a catastrophic release, ethylene oxide and flammable gas (butane) could migrate off the Facility site and potentially pose a threat to the surrounding community. Butane was selected for the flammable substance release as it is present in the greatest concentration in one product and the offsite impacts extend further than the other flammable substances. Toxic Endpoint concentrations (TEs) for the regulated chemicals from the EPA regulations were used for the ethylene oxide evaluation. These scenarios are summarized below. Worst-Case Toxic Release Scenario - The largest container of the product ethylene oxide, containing 400 pounds of oxirane, fails releasing the entire contents a nd emitting vapors into the atmosphere within an enclosed space, in direct contact with outside air (through doors). The ambient air temperature is 25 degrees Celsius with an atmospheric stability class F and wind speed of 1.5 meters per second. The release rate of regulated product is 22 pounds per minute for a duration of 10 minutes, as a result of mitigation measures. Based on the U.S. EPA RMP Comp, Version 1.6 model, the ethylene oxide may exceed the TE as far as 0.4 miles downwind of the source. Alternative-Case Toxic Release Scenario - The largest container of the product ethylene oxide, containing 400 pounds of oxirane, fails releasing the entire contents and emitting vapors into the atmosphere within an enclosed space, in direct contact with outside air (through doors). The ambient air temperature is 25 degrees Celsius with an atmospheric stability class D and wind speed of 3 meters per second. The release rate of regulated product is 22 pounds per minute for a duration o f 10 minutes, as a result of mitigation measures. Based on the U.S. EPA RMP Comp, Version 1.6 model, the ethylene oxide may exceed the TE as far as 0.1 miles downwind of the source. Worst-Case Flammable Release Scenario - One pallet weighing 648 pounds of GLOWMASTER "Gold Fuel" (68% butane) is dropped from the forklift during loading and unloading activities and creates a vapor cloud explosion releasing 441 pounds of butane. The ambient air temperature is 25 degrees Celsius with an atmospheric stability class F and wind speed of 1.5 meters per second. Based on the U.S. EPA RMP Comp, Version 1.6 model, the estimated distance to 1 pound per square inch (psi) overpressure is approximately 0.06 miles downwind of the source. Alternative-Case Flammable Release Scenario - One case weighing 6 pounds of GLOWMASTER "Gold Fuel" (68% butane) is dropped from the forklift during loading and unloading activities and creates a vapor cloud explostion releasing 4.08 pounds of butane. The ambient a ir temperature is 25 degrees Celsius with an atmospheric stability class D and wind speed of 3.0 meters per second. Based on the U.S. EPA RMP Comp, Version 1.6 model, the estimated distance to 1 pound per square inch (psi) overpressure is approximately 0.009 miles downwind of the source. Based on Inland Star policy, safety meetings for employees are conducted on a continuing basis and ongoing safety improvemts are routinely adopted. Additional employee training and preventative maintenance programs will be implemented in response to the results of internal auditing procedures, process changes, or changes in the regulated substances handled at the Facility. |