Valspar Industries USA, Inc. - Executive Summary |
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VALSPAR Fremont Facility-Executive Summary The VALSPAR Fremont Facility is located in the city of Fremont, Newago County, Michigan. The facility has been in continuous operation at this location since 1975. The facility packages consumer and specialty products into user-sized quantities. Brands most associated with this facility include Dri-Slide and Guardsman, and many other OEM products for companies such as Chrysler and many others. The VALSPAR Fremont Facility is required to submit the 122(r) Risk Management Plan (RMP) plan based on the on-site storage of gaseous fuels which are used as propellant in the aerosol can product lines. These gaseous propellants consist of propane, isobutane, and butane. Originally the decision of the US Court or Appeals exempted this facility from filing the 112R plan because the facility was below the revised threshold for the gaseous fuels at the facility. Subsequent evaluation and decisions by the U.S. EPA have clarified that facilities requir ed to use these gaseous fuels as propellant, and not fuels used to power engines, are required that VALSPAR complete and submit this 112(r) Risk Management Plan. The facility has 5 horizontal above ground storage tanks for gaseous fuels. Two tanks are used to store a 50/50 blend of butane and isobutane, and the other three are used to store propane. Two of the propane tanks are used as propellants, and one small propane tank is used as motor fuels for forklift trucks. Based on a combined volume of 40,835 pounds of the gaseous fuel propane, isobutane , and butane (propellant and forklift fuels), VALSPAR has evaluated a worst-case scenario for the explosion and fire resulting from the release of these compounds. For the purposes of this evaluation, the worst case scenario was identified as having all five (5) gaseous fuel tanks explode at the same time. As allowed in the EPA Guidance Document(Section 5, Page 5-2) to allow for the calculation of a worst-case release, the total volum e of the tanks was evaluated as though they were a singe compound, propane. The evaluation of the release of the total volume of propane was performed using both the look- up tables in the RMP Guidance documents, and the release modeling evaluation. Based on the combined volume of 40,835 pounds (equivalent to 8,430 gallons), the estimated impact distance from the tanks was 0.25 miles based on the modeling, and 0.3 miles from the look-up tables from (Table 13) for 50,000 pounds. Interpolation from the look-up tables for the actual volume of the release also estimated the distance to be 0.25 miles. To be conservative, the 0.3 mile radius was selected as the RMP impact area. Once the radius was established, comparison of the distance to the number of households was performed using Geographical Information System (GIS) data of the area. Based on the available data, it was estimated that 226 households are within the 0.3 mile radius. Based on an estimated occupancy of 4 people per ho usehold, it is estimated that approximately 904 people live within the 0.3 mile radius of the facility. Additionally, 2 schools were identified as a sensitive receptors with the 0.3 mile radius. Evaluation of the school locations indicate that they are shielded from the fire/explosion potential by both the physical facility of the plant, as well as topographically. The schools are located to the northwest of the facility, and adjacent to the facility property line. The schools are built in a topographic depression below the surface level of the facility in such a manner that only the peaks of the school roof can be seen from the adjacent property of the school. |