GW International - Fairbanks - Executive Summary |
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CAA 112 Executive Summary GW International - Fairbanks, Alaska GW International (GWI) is a multinational wholesale distributor of chemical products. As of the date of this submission, the Company operates twenty-eight distribution warehouses in the United States; only a few of these facilities are subject to Risk Management Program Planning. This summary describes GWI's Risk Management Program for its Fairbanks, Alaska facility. I. Statement of Senior Management Commitment to Safety GWI's President and Chief Executive Officer drafted a formal "Statement of Corporate Policy on Safety and Environmental Protection." This statement has been provided to all employees and the Company's public and private emergency responders as evidence of the Company's commitment to safety. The following excerpt is taken directly from the Corporate Statement: The personal safety and health of each member of GWI staff is of paramount importance. As a company, our very existence depends on service to our customers and support from our neighbors. GWI's reputation for safety in handling chemical products will do much to determine the company's future growth. Our goals include employee safety and prevention of all hazardous material releases to the environment. We will maintain a safety and environmental program which embodies the proper attitudes toward safety and environmental protection on the part of everyone. This program requires the total cooperation on the part of every employee in all safety, health and environmental matters. GWI has specifically authorized designated facility emergency coordinators to "commit any resources necessary to control an incident. This includes mobilization of other emergency response organizations as well as the purchase of necessary supplies and equipment." II. General Facility Description GWI Fairbanks is situated within an industrial area just outside Fairbanks' city limits. The surrounding area is sparsely populat ed with the nearest residence being approximately one mile away. There are no at-risk populations (e.g., schools, nursing homes, day-care centers, hospitals, prisons, etc.) located within one mile of the facility. The closest environmentally sensitive area is the Chena River. The GWI Fairbanks facility coordinates emergency planning and response with the Fairbanks University Fire Department, and the Fairbanks North Star Borough. A. Description of Primary Activities at Facility GWI Fairbanks is a warehousing and distribution facility that also packages and blends chemical products. Chemical products are received, stored and delivered to customers in closed containers, or in bulk quantities. B. Description of Facility Processes GWI Fairbanks engages in the following activities: -- Delivery by flatbed trailer of chlorine and sulfur dioxide tonners -- Manufacturing of chemical blends -- Receiving/delivery by cargo tanker truck, rail cars and ISOtainers of chemical p roducts in bulk -- Delivery of chemical product in non-bulk UN-approved containers -- Internal movement of chemical products from the receiving area by forklift or pallet jack to and from the designated storage area -- Delivery of chemical products to customers -- Packaging of salt -- Cement blending C. Description of Products/Quantities Handled at Facility GWI Fairbanks may store two CAA 112 RMP program chemicals, chlorine and sulfur dioxide, in amounts that exceed threshold quantities. The largest containers of chlorine gas and anhydrous sulfur dioxide that might be stored at the facility are one-ton containers, although 150 pound cylinders are stored as well. III. Worst Case Release Scenarios/Alternative Release Scenarios This section summarizes the worst-case release scenarios and the alternative release scenarios presented in the GWI - Fairbanks RMP plan. A. Worst Case Release Scenarios The worst-case scenario for GWI Fairbanks is a release of a one-t on container of anhydrous sulfur dioxide gas. A release of this magnitude would impact receptors within a 3.1-mile radius (as determined by RMP*Comp). The Company believes that this release scenario is extremely unlikely given the inherent integrity of containers used for sulfur dioxide. Sulfur dioxide one-ton containers are manufactured to meet stringent U.S. Department of Transportation standards. These container standards are specifically designed to minimize (if not eliminate) the possibility of accidental release during the rigors of transportation in commerce. Manufacturing specifications include the use of >1-inch thick steel for the body of the container. Container weight exceeds 1,500 pounds when empty. These containers can only be moved at the facility in single units (i.e., one at a time). This factor, by itself, makes the possibility of a release (during onsite movement) of a quantity greater than a one-ton container extremely remote. Container valves are protect ed within a recessed compartment to prevent accidental damage during handling/transportation. GWI Fairbanks stores chlorine, and sulfur dioxide containers outdoors in a stationary storage van, when space permits, to provide protection from weather/temperature. The storage van is not located in an area subject to major traffic. B. Alternative Release Scenarios 1. Chlorine Gas The alternative release scenario at GWI Fairbanks is the accidental release of five pounds per minute for a duration of one hour of chlorine gas from a one-ton container. Release of Chlorine: Because of the inherent integrity of the container itself, only the valve and fusible plug present feasible release scenarios. As explained above, the valve is recessed inside the container and damage could only occur if an object enters the recessed area with sufficient force to damage the valve. The fusible plug is designed to begin to melt at approximately 157? F. If the fusible plug melts as a resu lt of fire, it is expected that the chlorine would be entirely consumed by the fire. The Company has requested information from the Chlorine Institute that would allow us to estimate the worst case release-rate from a melted fusible plug. The Chlorine Institute responded that there were too many variables (e.g., temperature during the release) to make a reasonable estimate of the release rate. The estimate of the quantity released (300 pounds) is based on the assumption that containment kits will be applied within one hour (active mitigation). The facility has the appropriate chlorine kits for containing releases from chlorine containers. These kits are designed to seal leaks at the valve or fusible plug. The radius of the area affected by the alternative release scenario is approximately 0.1 miles. Therefore, only the street immediately in front of the facility and the neighboring facility immediately to the east could be affected by a release under the alternative scenario. 2. Sulfur Dioxide Gas The alternative release scenario at GWI Fairbanks is the accidental release of five pounds per minute for a duration of one hour of sulfur dioxide gas from a one-ton container. Release of sulfur dioxide: Because of the inherent integrity of the container itself, only the valve and fusible plug present feasible release scenarios. As explained above, the valve is recessed inside the container and damage could only occur if an object enters the recessed area with sufficient force to damage the valve. The fusible plug is designed to begin to melt at approximately 157? F. If the fusible plug melts as a result of fire, it is expected that the chlorine would be entirely consumed by the fire. The Company has requested information from the Chlorine Institute that would allow us to estimate the worst case release-rate from a melted fusible plug. The Chlorine Institute responded that there were too many variables (e.g., temperature during the release) to make a reasonable estimate of the release rate. The estimate of the quantity released (300 pounds) is based on the assumption that containment kits will be applied within one hour (active mitigation). The facility has the appropriate chlorine kits for containing releases from chlorine containers. These kits are designed to seal leaks at the valve or fusible plug. The radius of the area affected by the alternative release scenario is approximately 0.1 miles. Therefore, only the street immediately in front of the facility and the neighboring facility immediately to the east could be affected by a release under the alternative scenario. IV. Accidental Release Prevention Planning at the Facility A. Rules and Regulations that Apply to this Facility Several-hundred federal, state and local environmental and safety rules and regulations apply to this facility; it is not possible to summarize all of the regulatory requirements in this document. The primary legislation affectin g chlorine is OSHA's Process Safety Management rule. A chlorine PSM program has been implemented at the Fairbanks branch. The Fairbanks University Fire Department performs site inspections. The Uniform Fire Code and related building codes also apply to this facility and are monitored by the University Fire Department. The Company has a formal safety training program designed to meet training requirements promulgated by OSHA, DOT and EPA. Hazard communication training (OSHA) is the primary method the Company uses to educate employees on the risks associated with chlorine and sulfur dioxide. Emergency response training is performed in accordance with OSHA's HAZWOPER regulations (29 CFR Part 1910.120). B. Internal (Company) Release Prevention Program Requirements GWI is a member of the National Association of Chemical Distributors (NACD). Membership requires companies to prepare policies and procedures that promote the safe use and handling of chemical products by member companies and also by customers who purchase the chemical products. GWI has more than 100 policies/procedures that address topics including the storage, handling, and transportation of compressed gases and specific incident planning for chlorine and sulfur dioxide. GWI facilities are regularly audited for compliance with all internal and external requirements by GWI environmental staff. V. Five-Year Accident History There has never been an accident or accidental release involving chlorine or sulfur dioxide at GWI Fairbanks. VI. Emergency Response Program The facility has an emergency response plan that outlines proper response, notification and reporting procedures. The plan is reviewed and updated as often as necessary (e.g., to reflect changes in personnel, emergency response contractors, etc.). Assistance will be provided to the Fairbanks branch by the fire department for any incident that cannot be handled by the facility, or by the contracted external emergen cy responder. The facility has four on-site emergency coordinators who are trained to manage all incidents that require implementation of the plan. GWI maintains a corporate emergency spill response telephone number (1-800-GWSPILL). This number is staffed 24-hours; the on-call technical support employee will be paged immediately to provide assistance during an incident. The on-call staff acts as backup to the on-site emergency coordinators. VII. Planned Improvements to Safety Program GWI is committed to accident prevention and, accordingly, maintains an excellent reputation in the chemical distribution industry. The primary planned improvement to GWI's safety program is an update of the training materials (e.g., videos and handouts) to meet revised regulatory requirements. |