Fisher Scientific Co-Southeast Distribution Center - Executive Summary

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Facility Overview:  The Southeast Distribution Center in Suwanee, Georgia 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 20,000 pounds of chloroform; 14,000 pounds of hydrochloric acid; and 9,300 pounds of ethyl ether in storage.  The amounts of hydrochloric acid and ethyl ether 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 hydrochloric acid and ethyl ether 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 
:  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 0.02 miles, and the distance to the endpoint for hydrochloric acid was 0.03 miles.  The worst-case re 
lease 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 trains new employees on chemical safety and release prevention prior to placing the employees on the warehouse floor.  Existing employees are provided with annual refreshers on chemical safety.  In addition, individual departments discuss chemical handling and release prevention approximately every two months.   
 
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:  A group of employees are trained as first responders according to the requirements of 29 CFR 1910.120.  If the first responders are not ab 
le to contain a release, the facility has contracted with an outside contractor, MKC, for emergency response.  The facility has also coordinated response efforts with the Gwinnett County Department of Fire and Emergency Services.  The facility has established a notification mechanism to ensure that Station 13 of the Gwinnett County Department of Fire and Emergency Services will be properly notified when response is required for a release and has provided the Department with a copy of its emergency response plan and evacuation procedures.  Copies of the facility's SARA 302, 311, and 312 reports have been sent to the Gwinnett County Department of Fire and Emergency Services.  The Southeast 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 Chang 
es 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.
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