Great Western Chemical Company - Helena - Executive Summary

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CAA 112(r) Executive Summary 
Great Western Chemical Company - Helena, Montana 
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 Helena, Montana, 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 ve 
ry 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 - Helena is located in a residential area near inside Helena city limits.  The site is bounded to the North  
by the Burlington Northern Railroad, to the East by Interstate-15 and to the South and West by residential properties.  There are no at-risk populations (e.g., schools, nursing homes, day-care centers, hospitals, prisons, etc.) located within 1.0 miles of the facility.  There are also no environmental receptors within 1.0 miles.  
A. Description of Primary Activities at Facility 
GWCC - Helena is primarily a warehousing and distribution facility.  Very little packaging (e.g. transferring materials from a large container to a smaller container) occurs at this facility.  No manufacturing occurs at this facility.  All RMP Process chemical products are received, stored and delivered to customers in closed containers.  
B.  Description of Facility Processes 
GW - Helena engages in the following activities: 
-- Delivery by truck of chemical products in bulk and nonbulk 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 
--Very minimal repackaging from large container to small container as mentioned above 
C.  Description of Products/Quantities Handled at Facility 
GW - Helena may store one CAA 112 RMP program chemical in amounts that exceed threshold quantities.  That chemical is Chlorine gas.  The largest container of chlorine gas that might be stored at the facility is a 150-lb cylinder.  
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.  As defined by the CAA, the worst-case scenario describes the consequences of a release of the entire contents of the largest single container with the largest distance to a toxic endpoint within 10-minutes.  The alternative release scenario describes the consequences of a release of 150 pounds of chlorine from the container, within an half- 
an-hour with active mitigation being considered. 
A.  Worst Case Release Scenarios 
The worse-case scenario for GW - Helena is a release of a 150 pound cylinder of chlorine gas.  A release of this magnitude would impact receptors within a 0.4 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 cylinders 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.  These containers are only be moved at the facility in single units (i.e., one at a time).  This factor, by itself, eliminates the possibility of a release (during onsite movement) of a quantity greater than one cylinder.  Cylinder valves are by a steel housing to prevent accidental damage during handling/trans 
GW - Helena stores chlorine containers outdoors under a canopy to provide protection from weather/temperature.  The storage area is not located in an area subject to traffic.  
B.  Alternative Release Scenarios 
The alternative release scenario at GW- Helena includes the accidental release of a 150 pound cylinder of Chlorine gas with active mitigation.   
Release of Chlorine: Because of the inherent integrity of the cylinder itself, only the valve and fusible plug present feasible release scenarios.  As explained above, the valve is protected by a steel housing on top of the cylinder and damage could only occur if a force strong enough to remove the housing occurs.  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 chlorine would be entirely consumed by the fire.  The facility has the appropriate chlorine kits for containing releases from chlorine cylinders.  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 properties across the street 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 local 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.  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 Helena Fire Department.  The fire department performs regular safety inspections of the facility. 
The Company has a formal safety training program designed to meet training requirements promulga 
ted 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 chemicals.  Emergency response training is performed in accordance with OSHA's HAZWOPER regulations (29 CFR Part 1910.120). 
B.  Internal (Company) Release Prevention Program Requirements 
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 (among other GW-designated "chemicals of concern").  
GW fac 
ilities are audited at least every year and a half 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 - Helena. 
VI.  Emergency Response Program 
GW - Helena has an emergency response plan that is reviewed and updated as often as necessary (e.g., to reflect changes in personnel, emergency response contractors, etc.).  The facility has contracted with an emergency response contractor to provide assistance with any incidents that cannot be handled by the facility or the fire department.  GW - Pasco 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 the 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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