Great Western Chemical Company - Anchorage - Executive Summary |
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CAA 112 Executive Summary Great Western Chemical Company - Anchorage, Alaska Great Western Chemical Company (GWCC) is a multinational wholesale distributor of chemical products. As of the date of this submission, the Company operates twenty-eight distribution warehouses in the United States; only a few of these facilities are subject to Risk Management Program Planning. This summary describes GWCC's Risk Management Program for its Anchorage, Alaska facility. I. Statement of Senior Management Commitment to Safety GWCC's President and Chief Executive Officer drafted a formal "Statement of Corporate Policy on Safety and Environmental Protection." This statement has been provided to all employees and the Company's public and private emergency responders as evidence of the Company's commitment to safety. The following excerpt is taken directly from the Corporate Statement: The personal safety and health of each member of GWCC staff is of paramount importance. As a company, our v ery existence depends on service to our customers and support from our neighbors. GWCC's reputation for safety in handling chemical products will do much to determine the company's future growth. Our goals include employee safety and prevention of all hazardous material releases to the environment. We will maintain a safety and environmental program which embodies the proper attitudes toward safety and environmental protection on the part of everyone. This program requires the total cooperation on the part of every employee in all safety, health and environmental matters. GWCC has specifically authorized designated facility emergency coordinators to "commit any resources necessary to control an incident. This includes mobilization of other emergency response organizations as well as the purchase of necessary supplies and equipment." II. General Facility Description GWCC Anchorage is situated in an industrial zoned area within the city's limits. The nearest residence is appro ximately one mile away. There are no at-risk populations (e.g., schools, nursing homes, day-care centers, hospitals, prisons, etc.) located within one mile of the facility. The closest environmentally sensitive area is Ship Creek and Cook Inlet (Pacific Ocean). The GWCC Anchorage facility coordinates emergency planning and response with the Anchorage Fire Department, and the Anchorage Municipality LEPC. A. Description of Primary Activities at Facility GWCC Anchorage is a warehousing and distribution facility. Chemical products are received, stored and delivered to customers in closed containers. B. Description of Facility Processes GWCC Anchorage engages in the following activities: -- Receiving/delivery of chemical products in bulk and non-bulk UN-approved containers -- Internal movement of chemical products from the receiving area by forklift or pallet jack to and from the designated storage area -- Delivery of chemical products to customers C. Description of Products/Qu antities Handled at Facility GWCC Anchorage may store one CAA 112 RMP program chemicals in an amount that exceeds the threshold quantity, which is chlorine. The largest container of chlorine gas that might be stored at the facility is a one-ton container. III. Worst Case Release Scenarios/Alternative Release Scenarios This section summarizes the worst-case release scenarios and the alternative release scenarios presented in the GWCC Anchorage' RMP plan. A. Worst Case Release Scenarios The worst-case scenario for GWCC Anchorage is a release of a one-ton container of chlorine gas. A release of this magnitude would impact receptors within a 2.2-mile radius (as determined by RMP*Comp). The Company believes that this release scenario is extremely unlikely given the inherent integrity of containers used for chlorine. Chlorine one-ton containers are manufactured to meet stringent U.S. Department of Transportation standards. These container standards are specifically designed to minimize (if not eliminate) the possibility of accidental release during the rigors of transportation in commerce. Manufacturing specifications include the use of >1-inch thick steel for the body of the container. Container weight exceeds 1,500 pounds when empty. These containers can only be moved at the facility in single units (i.e., one at a time). This factor, by itself, makes the possibility of a release (during onsite movement) of a quantity greater than a one-ton container extremely remote. Container valves are protected within a recessed compartment to prevent accidental damage during handling/transportation. GWCC Anchorage stores chlorine containers outdoors in a stationary storage van to provide protection from weather/temperature. The storage van is not located in an area subject to major traffic. B. Alternative Release Scenarios The alternative release scenario at GWCC Anchorage is the accidental release of 300 pounds of chorine from a one-ton container. Rele ase of Chlorine: Because of the inherent integrity of the container itself, only the valve and fusible plug present feasible release scenarios. As explained above, the valve is recessed inside the container and damage could only occur if an object enters the recessed area with sufficient force to damage the valve. The fusible plug is designed to begin to melt at approximately 157' F. If the fusible plug melts as a result of fire, it is expected that the chlorine would be entirely consumed by the fire. The Company has requested information from the Chlorine Institute that would allow us to estimate the worst case release-rate from a melted fusible plug. The Chlorine Institute responded that there were too many variables (e.g., temperature during the release) to make a reasonable estimate of the release rate. The estimate of the quantity released (300 pounds) is based on the assumption that chlorine kits will be applied within one hour (active mitigation). The facility has the ap propriate chlorine kits for containing releases from chlorine containers. These kits are designed to seal leaks at the valve or fusible plug. The radius of the area affected by the alternative release scenario is approximately 0.1 miles. Therefore, only the street immediately in front of the facility could be affected by a release under the alternative scenario. IV. Accidental Release Prevention Planning at the Facility A. Rules and Regulations that Apply to this Facility Several 100 federal, state and local environmental and safety rules and regulations apply to this facility; it is not possible to summarize all of the regulatory requirements in this document. The primary legislation affecting chlorine is OSHA's Process Safety Management rule. A chlorine PSM program has been implemented at the Anchorage branch. The Uniform Fire Code and related building codes apply to this facility. The Anchorage Fire Department performs site inspections regularly. The Company has a formal safety training program designed to meet training requirements promulgated by OSHA, DOT and EPA. Hazard communication training (OSHA) is the primary method the Company uses to educate employees on the risks associated with chlorine. Emergency response training is performed in accordance with OSHA's HAZWOPER regulations (29 CFR Part 1910.120). B. Internal (Company) Release Prevention Program Requirements GWCC is a member of the National Association of Chemical Distributors (NACD). Membership requires companies to prepare policies and procedures that promote the safe use and handling of chemical products by member companies and also by customers who purchase the chemical products. GWCC has more than 100 policies/procedures that address topics including the storage, handling, and transportation of compressed gases and specific incident planning for chlorine. GWCC facilities are regularly audited for compliance with all internal and external requirements by GWCC environmental staf f. V. Five-Year Accident History There has never been an accident or accidental release involving chlorine at GWCC Anchorage. VI. Emergency Response Program The facility has an emergency response plan that outlines proper response, notification and reporting procedures. The plan is reviewed and updated as often as necessary (e.g., to reflect changes in personnel, emergency response contractors, etc.). Assistance will be provided to the Anchorage branch by the fire department for any incident that cannot be handled by the facility, or by the contracted external emergency responder. The facility has one on-site emergency coordinator, and one off-site emergency coordinator who are trained to manage all incidents that require implementation of the plan. GWCC maintains a corporate emergency spill response telephone number (1-800-GWSPILL). This number is staffed 24-hours; the on-call technical support employee will be paged immediately to provide assistance during an incident . The on-call staff acts as backup to the on-site emergency coordinators. VII. Planned Improvements to Safety Program GWCC is committed to accident prevention and, accordingly, maintains an excellent reputation in the chemical distribution industry. The primary planned improvement to GWCC's safety program is an update of the training materials (e.g., videos and handouts) to meet revised regulatory requirements. |