GW International - Portland - Executive Summary |
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CAA 112(r) Executive Summary GW International - Portland, Oregon 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 Portland, Oregon, facility. A. 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 - Portland is located in an industrial area along the Williamette River, inside Portland city limits. The site is bounded to the North by the Williamette River and to the south by the Portland West Hills. Surrounding uses are heavy industrial. The closest residence is 0.5 miles away. There are no at-risk populations (e.g., schools, nursing homes, day-care centers, hospitals, prisons, etc.) located within 1.0 miles of the facility. The closest environmentally sensitive area is the Williamette River. GWI is an active participant in the local community awareness and emergency response group (CAER) group, which coordinates emergency planning and response within this industrial area. A. Description of Primary Activities at Facility GWI - Portland is a warehousing, blending, packaging, and distribution facility only. No manufacturing of chemical products occurs at this facility. All RMP regulated chemical products are received, stored and delivered to customers in closed containers. B. Description of Facility Processes GWI- Portland engages in the following activities: -- Delivery by truck of chemical products in bulk and nonbulk 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 --Blending and packaging of chemical products C. Description of Products/Quantities Handled at Facility GWI - Portland may store two CAA 112 RMP program chemicals in amounts that exceed threshold quantities: Chlorine gas and 70% aqueous hydrofluoric acid are stored at the facility. The largest container of chlorine gas that might be stored at the facility is a 150 pound cylinder. The cylinders are never opened or connected to other cylinders or processes. The largest container of hydrofluoric acid (70%) is a 500 pound drum. hydrofluoric acid is never opened, and is not used in any processes. III. Worst Case Release Scenarios/Alternative Release Scenarios This section summaizes the worst-case release scenarios and the alter native release scenarios presented in the facility's RMP plan. As defined by the CAA, the worst-case scenario describes the consequences of a release of the entire contents of the largest single container with the greatest distance to a toxic endpoint within 10-minutes. The alternative release scenario describes the consequences of a release of 150 pounds of chlorine from the cylinder, within an hour with active mitigation being considered. A. Worst Case Release Scenarios The worse-case scenario for GWI - Portland is a release of a 150 pound cylinder of chlorine gas. A release of this magnitude would impact receptors within a 0.4 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 chlorine. Chlorine cylinders are manufactured to meet stringent U.S. Department of Transportation standards. These container standards are specifically designed to minimize (if not elimi nate) the possibility of accidental release during the rigors of transportation in commerce. Manufacturing specifications include the use of thick steel for the body of the cylinder. These containers can only be moved at the facility in single units (i.e., one at a time). This factor, by itself, eliminates the possibility of a release (during onsite movement) of a quantity greater than one cylinder. Cylinder valves are protected with a steel housing to prevent accidental damage during handling/transportation. GWI - Portland stores chlorine containers outdoors under a canopy to provide protection from weather/temperature. The storage area is not located in an area subject to traffic. B. Alternative Release Scenarios 1. Chlorine The chlorine alternative release scenario at GWI- Portland includes the accidental release of chorine from a full 150 pound cylinder. Release of Chlorine: Because of the inherent integrity of the cylinder itself, only the valve and fusib le plug present feasible release scenarios. As explained above, the valve is protected by a steel housing and damage could only occur if an object removed the housing with great force. The fusible plug is designed to melt at 157 degrees 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 facility has the appropriate chlorine kits for containing releases from chlorine cylinders. These kits are designed to seal leaks at the valve or fusible plug. This active mitigation would occur within an hour of release by trained personnel. The radius of the area affected by the alternative release scenario is less than 0.1 miles. Therefore, only the street immediately in front of the facility and the neighboring facility to the south could be affected by a release under the alternative scenario. 2. Hydrofluoric Acid 70% The hydrofluoric acid alternative release scenario at GWI-Portland involves the accidental release of 400 pounds of 70% hydrofluoric acid for a duration of 15 minutes. Release of Hydrofluoric Acid: hydrofluoric acid is stored in plastic UN-approved, 55-gallon drums. The most likely release scenario would occur if a drum was punctured during onsite movement by the forks of a forklift. In this case, it is expected that the contents would release at approximately 25 pounds per minute. Active mitigation measures could lessen the amount released (e.g., patching the drum by trained employees wearing the appropriate personal protection equipment). This release would be in an enclosed building and have the same affected area as the previous alternative scenario. Forklifts are inspected daily to minimize the risk of malfunction. Annual preventive maintenance is also performed to minimize the risks associated with equipment failure. C. Accidental Release Prevention Planning at the Facility 1. Rules and Regulations that Apply to this Facility Too many federal, state and local environmental and safety rules and regulations apply to this facility to detail in this summary. The primary legislation affecting chlorine is OSHA's Process Safety Management rule. A chlorine PSM program has been implemented at the facility. The uniform fire and building codes also apply to this facility and are enforced by the Portland Fire Department. The fire department performs regular (e.g., annual) safety inspections of the facility (with oversight by the 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 these two chemicals. Emergency response training is performed in accordance with OSHA's HAZWOPER regulations (29 CFR Part 1910.120). 2. Internal (Company) Release Prevention Program Requirements GWI is a member of the National Association of Chemical Distributors (NACD). It is actively engaged in the process of becoming certified under the NACD's "Product Stewardship/Responsible Distribution" Program. This program requires member 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 incident planning for chlorine and hydrofluoric acid (among other GWI-designated "chemicals of concern"). GWI facilities are audited at least every year and a half for compliance with all internal and external requirements by GWI environmental staff. D. Five-Year Accident History There have never been any accidents or accidental releases involving this process chemical at GWI - Portland. E. Emergency Response Program GWI - Portland has an emergency response plan that is exercised annually, often with the participation of the Portland Fire Department. The plan is reviewed and updated as often as necessary (e.g., to reflect changes in personnel, emergency response contractors, etc.). The facility has contracted with two emergency response contractors to provide assistance with any incidents that cannot be handled by the facility or the fire department. GWI - Portland has four on-site emergency coordinators who are trained to manage all incidents that require implementation of the plan. GWI also maintains a corporate emergency spill response phone number (1-800-GWSPILL). This number is staffed 24-hours per day; 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. E. Planned Improvements to Safety Program GWI is committed to accident prevention and, accordingly, maintains an excellent reputation in t he 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. |