Fisher Scientific Co-Denver Distribution Center - Executive Summary |
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Facility Overview: The Denver Distribution Center in Denver, Colorado is a distribution center for laboratory equipment, apparatuses, and laboratory-grade chemicals. The facility is regulated under 40 CFR Part 68 of the Clean Air Act Amendments due to onsite storage capacities of chloroform, hydrochloric acid, and ethyl ether. At the time of the submittal, the facility had approximately 12,000 pounds of ethyl ether; 14,000 pounds of chloroform; and 8,500 pounds of hydrochloric acid in storage. The amounts of chloroform and hydrochloric acid differ from the quantities reported in Section 1.17 of this document; the amounts in Section 1.17 are the threshold quantities of these substances. The facility predictively filed for chloroform and hydrochloric acid in the event that the quantity of these materials stored on site exceeds the threshold quantities. Chemical storage is the only regulated process at the facility. Accidental Release Prevention and Emergency Response Policies: Th e facility's overall approach and committment to proper chemical management is demonstrated by training, procedures, and maintenance systems currently in place at the facility. The facility is committed to ensuring safe operations in accordance with Part 68 requirements and has established a senior manager responsible for Part 68 implementation and compliance. Release Scenarios: Worst-case scenarios were conducted for chloroform, hydrochloric acid, and ethyl ether for each chemical's single largest vessel based on US EPA's Offsite Consequence Analysis guidance and EPA-approved modeling. The worst-case release scenarios for chloroform and hydrochloric acid consisted of a liquid spill and vaporization. The largest container size of chloroform was 200 liters; the largest container size of hydrochloric acid was 6.5 gallons. The distances to the toxic endpoints for chloroform and hydrochloric acid were 0.03 miles. The worst-case release scenario for ethyl ether involved a vapor clo ud explosion of a 20 liter container. The distance to the endpoint was 0.02 miles. None of the worst-case scenarios resulted in an impact to the public or environmental receptors. General Accidental Release Prevention Program and Chemical-specific Prevention Steps: New employees are trained on how to properly handle chemicals and on what to do in the event of a release during the new employee orientation. Existing employees receive annual refreshers which include the proper handling of chemicals and release notification procedures. Five-year Accident History: The facility has had no RMP-reportable accidents/releases of ethyl ether, hydrochloric acid, or chloroform within the five years preceding RMP submittal. Emergency Response Program: The facility has contracted with an outside contractor, Rocky Mountain Catastrophe, for emergency response. The facility has also coordinated response efforts with the Denver Fire Department to ensure that the Department will respond to accid ental releases from the storage process as necessary. A notification mechanism has been established to ensure that the Denver Fire Department will be properly notified when response is required for a release. The facility submitted copies of its SARA 302, 311, and 312 reports to the Denver Fire Department and the Denver Office of Emergency Management. The Denver Distribution Center is subject to emergency response plan requirements including 29 CFR 1910.38. In addition, the facilty is subject to the preparedness and prevention requirements of 40 CFR 265 Subpart C since the facility is a small quantity generator of hazardous waste. Planned Changes to Improve Safety: Periodic reviews of the program, training, and maintenance procedures are conducted to ensure that any necessary and appropriate changes are made to maintain and improve safety. Summary: As documented in this submittal, the facility has met Part 68 requirements and has certified compliance. |