Great Western Chemical Company - Nampa - Executive Summary

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CAA 112(r) Executive Summary 
 
Great Western Chemical Company - Nampa, Idaho 
 
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 Nampa, Idaho, 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 very exi 
stence 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 - Nampa is located in an industrial area along I-84, inside Nampa city limits.  The site is split into two separat 
e properties within the industrial area.  The property that provides storage for the RMP chemicals is bounded on three sides by other businesses and factories, and to the east by a large field.  Surrounding uses are industrial.  The closest residence is 0.3 miles away.  There are no at-risk populations (e.g., schools, nursing homes, day-care centers, hospitals, prisons, etc.) located within 0.5 mile of the facility.  The closest environmentally sensitive area is the Deer Flat National Wildlife Refuge, approximately 5.0 miles away. 
 
A. Description of Primary Activities at Facility 
 
GWCC - Nampa is a warehousing , distribution  and packaging facility only. No manufacturing of chemical products occurs at this facility.  All RMP regulated chemical products are received, stored and delivered to customers in closed containers.  
 
B.  Description of Facility Processes 
 
GW- Nampa engages in the following activities: 
 
-- Delivery by truck of chemical products in bulk and nonbulk UN-approved cont 
ainers 
-- 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 
--Packaging from large containers into small containers 
 
C.  Description of Products/Quantities Handled at Facility 
 
GW - Nampa may store two CAA 112 RMP program chemicals in amounts that exceed threshold quantities:  Chlorine gas and Sulfur Dioxide Gas.  The largest container of chlorine gas that might be stored at the facility is a one-ton cylinder.  The largest container of sulfur dioxide gas that might be stored at GW- Nampa is a one-ton container.   
 
III.  Worst Case Release Scenarios/Alternative Release Scenarios 
 
This section summaizes the worst-case release scenarios and the alternative release scenarios presented in the facility's RMP plan.  
 
A.  Worst Case Release Scenarios 
 
There are two worst-case scenarios for the GW-Nampa branch, each with the exact same affected areas and receptors.  T 
he worse-case scenario for GW - Nampa is a release of a one-ton container of either sulfur dioxide gas or chlorine gas.  A release of this magnitude would impact receptors within a 1.3 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.  Compressed gas ton containers (like those used for both the chlorine and sulfur dioxide) 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.  Cylinder 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, eliminates the possibility of a re 
lease (during onsite movement) of a quantity greater than one container.  Container valves are protected within a recessed compartment to prevent accidental damage during handling/transportation.   
 
GW - Nampa stores both chlorine and sulfur dioxide containers outdoors.  
 
B.  Alternative Release Scenarios 
 
Alternative release scenarios at GW- Idaho Falls include (1) the accidental release of 300 pounds of chorine from a one-ton container and (2) the accidental release of 300 pounds of sulfur dioxide from a one-ton container.   
 
Release 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 cylinder 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 melt at approximately 157 degrees F.  If the fusible plug melts as a result of fire, it is expected that the chlo 
rine would be entirely consumed by the fire.  The facility has the appropriate chlorine kits for containing releases from chlorine containers.  The quantity released in dependent upon the timeliness of applying the chlorine kits as active mitigation.  This scenario assumes that the active mitigation will occur within an hour.  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 and the neighboring businesses could be affected by a release under the alternative scenario. 
 
Release of Sulfur Dioxide: 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 cylinder 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 melt at approximately 157 degrees F.  Because the cylinders are stored outside, away from any combustible materials, this is not a high risk.  This scenario assumes that a Act of God damages a valve inside its recessed compartment.  The facility has the appropriate containment kits for containing releases from sulfur dioxide containers.  The quantity released in dependent upon the timeliness of applying the kits as active mitigation.  This scenario assumes that the active mitigation will occur within an hour.  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 and the neighboring businesses 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 
 
Too many federal, state and loc 
al environmental and safety rules and regulations apply to this facility to detail in this summary.  The primary legislation affecting chlorine is OSHA's Process Safety Management rule.  There are no rules that apply specifically to hydroflouric acid, although it is covered generally under OSHA and EPA regulations.  A chlorine PSM program has been implemented at the facility.   The uniform fire and building codes also apply to this facility and are enforced by the Nampa Fire Department.  The fire department performs safety inspections of the facility. 
 
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 these two chemicals.  Emergency response training is performed in accordance with OSHA's HAZWOPER regulations (29 CFR Part 1910.120). 
 
B.  Internal (Company) Release Prevention Program Require 
ments 
 
GW is a member of the National Association of Chemical Distributors (NACD).  It is actively engaged in the process of becoming certified under the NACD's "Product Stewardship/Responsible Distribution" Program.  This program requires member 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.  GW has more than 100 policies/procedures that address topics including the storage, handling, and transportation of compressed gases and incident planning for chlorine and hydrofluoric acid (among other GW-designated "chemicals of concern").  
 
GW facilities are audited regularly for compliance with all internal and external requirements by GW environmental staff.   
 
V.  Five-Year Accident History 
 
There have never been any accidents or accidental releases involving either of these chemicals at GW - Nampa. 
 
VI.  Emergency Response Program 
 
GW - Nampa has an emerge 
ncy response plan that is exercised annually, often with the participation of the Nampa Fire Department.  The plan is reviewed and updated as often as necessary (e.g., to reflect changes in personnel, emergency response contractors, etc.).  The facility has contracted with two emergency response contractors to provide assistance with any incidents that cannot be handled by the facility or the fire department.  GW - Nampa has two on-site emergency coordinators who are trained to manage all incidents that require implementation of the plan.    
 
GW also maintains a corporate emergency spill response phone number (1-800-GWSPILL).  This number is staffed 24-hours per day; 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 t 
he chemical distribution industry.  The primary planned improvement to GW's safety program is an update of the training materials (e.g., videos and handouts) to meet revised regulatory requirements.
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