HELENA CHEMICAL COMPANY, Butte City, CA - Executive Summary |
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Helena Chemical Company (Helena) owns and operates an agricultural chemical dealership near Butte City, in Glenn 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 a comprehensive EPA Risk Management Plan (EPA RMP) to address regulatory requirements from Section 112(r) of the Clean Air Act (CAA). Based on Facility operations and 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 Faci lity that is regulated under the EPA RMP regulations is: 30,974 pounds of ammonia in Aqua Ammonia (20% Concentration or greater), 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 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, U.S. DOT Hazardous Materials and Emergency Response regulations, other state regulations, the industry's Pre-Fire Plan ning Program, and internal company policies and procedures. This information 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 of the Facility site and potentially pose a threat to the surrounding community. Toxic Endpoint concentrations (TEs) for the regulated chemical, published in the EPA regulations were used for this evaluation. These scenarios and mitigation measures to limit the downwind migration distance f or each scenario, are summarized below. Aqua Ammonia Storage Worst-Case Scenario - Failure of the largest storage tanks when full would release 125,400 pounds of aqua ammonia. It is assumed that the entire contents are released as a vapor at a rate of 3,010 pounds per minute. Air dispersion modeling estimates the TE for ammonia could extend downwind as far as 2.7 miles. Aqua Ammonia Alternate Release Scenario - Failure of a 2-inch aqua ammonia transfer hose. The contents of the 25-foot hose and storage tanks would be released for approximately one minute until the main storage tank valve could be closed. The resulting unconfined vapor and liquid would be discharged onto the concrete load pad, and vapors would be released. Air dispersion modeling estimates that ammonia concentrations exceeding the TE could extend downwind as far as 0.1 miles. Based on Helena's policy, safety meeting for employees are conducted on a continuing basis and ongoing safety improvements are routinely a dopted. Additional employee training and preventive 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. |