Fisher Scientific Co-Western Distribution Center - Executive Summary |
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Facility Overview: The Western Distribution Center in Santa Clara, California 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 13,000 pounds of ethyl ether; 6,400 pounds of chloroform; and 5,200 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 respective threshold quantities of chloroform and hydrochloric acid. 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 an d Emergency Response Policies: The 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 distance to the toxic endpoint for chloroform was 0.01 miles, and the distance to the endpoint for hydrochloric acid was 0 .03 miles. The worst-case release scenario for ethyl ether involved a vapor cloud 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: The facility has instituted procedures for the packing and labelling of chemicals to prevent releases. In addition, new employees are trained on release procedures during new employee orientation. Remaining employees receive refresher training on release procedures during the annual hazard communication training. Members of the facility's emergency response team also receive the required annual refresher training. 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 ha s instituted a facility emergency response team consisting of employees from the various shifts. The team has received training as described in 29 CFR 1910.120. If a release were to occur that could not be handled by the team, the facility has coordinated response efforts with the City of Santa Clara Fire Department to ensure that the Department will respond as necessary. The facility has also established a notification mechanism to ensure that the City of Santa Clara 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 City of Santa Clara Fire Department. The Western Distribution Center is subject to emergency response plan requirements including 29 CFR 1910.38 and 1910.120. In addition, the facility 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 Improv e 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. |