Helena Chemical Company, Holtville, CA - Executive Summary |
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Helena Chemical Company (Helena) owns and operates an agricultural chemical dealership near Holtville, Imperial County, California (Facility). Helena 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. To meet their commitment to prevention, Helena has implemented an EPA Risk Management Pllan (EPA RMP) to address regulatory requirements from Section 112(r) of the the Clean Air Act (CAA). Based on the regulatory requirements, a Program Level 2 Prevention Program has been prepared for the Facility operations. The Facility stores and distributes agricultural chemicals to the local agricultural community. Some of these chemicals could potentially pose a health hazard to the Facility employees in the event of an accidental release of the stored materials. The chemical stored in a process at the Facility that is regulated under the E PA RMP regulations is:114,000 pounds of Anhydrous Ammonia, CAS No. 7664-41-7, Storage and Handling. This EPA RMP includes a review of potential hazards associated with the regulated chemical at the Facility, operational procedures, maintenance procedures, and employee training. Safety reviews are communicated to the employees to reduce the possibility of an accidental release. To minimize the hazards presented by an accidental release to Facility employees or the public, Helena has prepared an emergency response plan that coordinates the actions of Facility employees with local emergency responders. The Faciity'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, U. S. DOT Hazardous Materials and Emergency Response regulations, other state regulation, the industry's Pre-Fire Planning Program, and internal company policies and proceedures. This inform ation has been provided to the Local Emergency Planning Committee and to local emergency response agencies. There have been no reportable releases of regulated materials at the facility within the last five years. As required by 112(r) of the CAA, the hypothetical worst-case release scenarios using the parameters described in 40 CFR 68.25, have been evaluated. An alternate release scenario was evaluated using parameters described in 40 CFR 68.28, and the EPA's Off-Site Consequence Analysis guidance document. These analyses indicated that in the event of a hypothetical catastrophic release, regulated chemicals could migrate off the Facility site and potentially pose a threat to the the surrounding community. Toxic Endpoint concentrations (TEs) for the regulated chemical, published in the EPA regulations were used for this evaluation. These secnarios and mitigation measures to limit them igration distance for each scenario are summarized below. Anhydrous Ammonia Storage Worst-Cas e Scenario - Simultaneous failure of two adjacent storage tanks could potentially release up to 11,400 pounds of anhydrous ammonia. It is assumed that the entire contents of both tanks is released as a liquid at a rate of 1,400 gallons per minute. The liquid is assumed to vaporize soon after contact with ambient air. Air despersion modeling estimates the TE for ammonia could extend downwind as far as 1.8 miles. Anhydrous Ammonia Alternate Release Scenario - Failure of a 1-inch transfer hose. The contents of the hose and storage tank would be released for approximately one minute until the manual shut off valve could be closed. The resulting spilled liquid material would then vaporize after contact with ambient air. Air dispersion modeling estimates the TE for ammonia could extend downwind as far as 0.8 miles. Based on Helena's policy, safety meetings for employees are conducted on a continuing basis and ongoing safety improvements are routinely adopted. Additional employee tra ining and preventative manitenance 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. |