mini research request - ntxawma.org

REQUEST FOR RESEARCH SUPPORT DATE: June 24, 2010

REQUESTOR: David A. Weeks, Risk Management & Engineering Ltd., 2218 S. Jupiter Rd., Ste. 103, Garland, TX 75041; 972‐272‐0386; [email protected]

REQUEST: RME seeks a student to perform a literature review and prepare a recommendation for determining the vapor emissions associated with the ambient storage and spillage of NITRO-SUL from a 9,000 gallon storage tank that is operated in Blythe, California.

NITRO-SUL is a solution of ammonium polysulfide and ammonium hydroxide (see attached MSDSs.) RME has been requested to evaluate the potential emissions of hydrogen sulfide and anhydrous ammonia from the ambient storage and spillage of this material. RME is requesting that a member of the student chapter of AWMA undertake a literature review of the potential emissions from this chemical and provide an analysis of if, and what percentages could be, of H2S and NH3 emitted when this chemical is stored or spilled at a location where the maximum ambient temperature can reach 120 degree F. ADMINISTRATION: RME is willing to pay for 8 hours of labor to conduct this effort at a rate of $25/hr, for a total of $200.00. The student performing this work will work as a 1099 employee of RME and will be responsible for paying all relevant taxes on the income associated with this project. RME retains full responsibility for the quality and accuracy of the student’s work to its Client. DELIVERABLE: The expected deliverable is a MS Word document summarizing the literature review and analysis, and PDF copies of the relevant articles. RME expects the deliverable will be at least 2 pages and include the following sections: Introduction, Summary of Literature Review, and Recommendations for Determining the Percentage of Emissions. DUE DATE: July 6, 2010; or as negotiated between the student and RME. ATTACHMENTS

1. MSDS 2. Tank Drawing 3. RMP for Helena Chemical Company facility located in Blythe, CA (provided for general

background purposes)

DISCLAIMER The company providing this information, the university, other educational institution and students participating in this project are solely responsible for all details pertaining to this project. Air and Waste Management Association (A&WMA), the NTX Chapter of A&WMA and the NTX Environmental Education Committee have no responsibility or involvement whatsoever, other than making the opportunity known to it's members.

REQUEST FOR RESEARCH SUPPORT

DATA REQUIRED TO ISSUE IRS Form 1099

STUDENT INFORMATION DATA

Name:

Phone No.:

Email Address:

Street Address:

City:

State:

Zip Code:

Social Security No.:

INSTRUCTIONS TO PRINTERSFORM W-9, PAGE 1 of 4MARGINS: TOP 13mm (1⁄2 "), CENTER SIDES. PRINTS: HEAD to HEADPAPER: WHITE WRITING, SUB. 20. INK: BLACKFLAT SIZE: 216mm (81⁄2 ") � 279mm (11")PERFORATE: (NONE)

Give form to therequester. Do notsend to the IRS.

Form W-9 Request for TaxpayerIdentification Number and Certification(Rev. October 2004)

Department of the TreasuryInternal Revenue Service

Name (as reported on your income tax return)

List account number(s) here (optional)

Address (number, street, and apt. or suite no.)

City, state, and ZIP code

Pri

nt o

r ty

pe

See

Sp

ecifi

c In

stru

ctio

ns o

n p

age

2.

Taxpayer Identification Number (TIN)

Enter your TIN in the appropriate box. The TIN provided must match the name given on Line 1 to avoidbackup withholding. For individuals, this is your social security number (SSN). However, for a residentalien, sole proprietor, or disregarded entity, see the Part I instructions on page 3. For other entities, it isyour employer identification number (EIN). If you do not have a number, see How to get a TIN on page 3.

Social security number

––or

Requester’s name and address (optional)

Employer identification numberNote. If the account is in more than one name, see the chart on page 4 for guidelines on whose numberto enter. –

Certification

1. The number shown on this form is my correct taxpayer identification number (or I am waiting for a number to be issued to me), and

I am not subject to backup withholding because: (a) I am exempt from backup withholding, or (b) I have not been notified by the InternalRevenue Service (IRS) that I am subject to backup withholding as a result of a failure to report all interest or dividends, or (c) the IRS hasnotified me that I am no longer subject to backup withholding, and

2.

Certification instructions. You must cross out item 2 above if you have been notified by the IRS that you are currently subject to backupwithholding because you have failed to report all interest and dividends on your tax return. For real estate transactions, item 2 does not apply.For mortgage interest paid, acquisition or abandonment of secured property, cancellation of debt, contributions to an individual retirementarrangement (IRA), and generally, payments other than interest and dividends, you are not required to sign the Certification, but you mustprovide your correct TIN. (See the instructions on page 4.)

SignHere

Signature ofU.S. person � Date �

Purpose of Form

Form W-9 (Rev. 10-2004)

Part I

Part II

Business name, if different from above

Cat. No. 10231X

Check appropriate box:

Under penalties of perjury, I certify that:

3I.R.S. SPECIFICATIONS TO BE REMOVED BEFORE PRINTING

DO NOT PRINT — DO NOT PRINT — DO NOT PRINT — DO NOT PRINT

TLS, have youtransmitted all Rtext files for thiscycle update?

Date

Action

Revised proofsrequested

Date Signature

O.K. to print

U.S. person. Use Form W-9 only if you are a U.S. person(including a resident alien), to provide your correct TIN to theperson requesting it (the requester) and, when applicable, to:

1. Certify that the TIN you are giving is correct (or you arewaiting for a number to be issued),

2. Certify that you are not subject to backup withholding,or

3. Claim exemption from backup withholding if you are aU.S. exempt payee.

Foreign person. If you are a foreign person, use theappropriate Form W-8 (see Publication 515, Withholding ofTax on Nonresident Aliens and Foreign Entities).

3. I am a U.S. person (including a U.S. resident alien).

A person who is required to file an information return with theIRS, must obtain your correct taxpayer identification number(TIN) to report, for example, income paid to you, real estatetransactions, mortgage interest you paid, acquisition orabandonment of secured property, cancellation of debt, orcontributions you made to an IRA.

Individual/Sole proprietor Corporation Partnership Other �

Exempt from backupwithholding

Note. If a requester gives you a form other than Form W-9 torequest your TIN, you must use the requester’s form if it issubstantially similar to this Form W-9.

Nonresident alien who becomes a resident alien.Generally, only a nonresident alien individual may use theterms of a tax treaty to reduce or eliminate U.S. tax oncertain types of income. However, most tax treaties contain aprovision known as a “saving clause.” Exceptions specifiedin the saving clause may permit an exemption from tax tocontinue for certain types of income even after the recipienthas otherwise become a U.S. resident alien for tax purposes.

If you are a U.S. resident alien who is relying on anexception contained in the saving clause of a tax treaty toclaim an exemption from U.S. tax on certain types of income,you must attach a statement that specifies the following fiveitems:

1. The treaty country. Generally, this must be the sametreaty under which you claimed exemption from tax as anonresident alien.

2. The treaty article addressing the income.3. The article number (or location) in the tax treaty that

contains the saving clause and its exceptions.

● an individual who is a citizen or resident of the UnitedStates,● a partnership, corporation, company, or associationcreated or organized in the United States or under the lawsof the United States, or

● any estate (other than a foreign estate) or trust. SeeRegulation section 301.7701-6(a) for additional information.

For federal tax purposes you are considered a person if youare:

INSTRUCTIONS TO PRINTERSFORM W-9, PAGE 2 of 4MARGINS: TOP 13 mm (1⁄2"), CENTER SIDES. PRINTS: HEAD to HEADPAPER: WHITE WRITING, SUB. 20. INK: BLACKFLAT SIZE: 216 mm (81⁄2") � 279 mm (11")PERFORATE: (NONE)

Form W-9 (Rev. 10-2004) Page 2

Sole proprietor. Enter your individual name as shown onyour social security card on the “Name” line. You may enteryour business, trade, or “doing business as (DBA)” name onthe “Business name” line.

3I.R.S. SPECIFICATIONS TO BE REMOVED BEFORE PRINTING


Other entities. Enter your business name as shown onrequired Federal tax documents on the “Name” line. Thisname should match the name shown on the charter or otherlegal document creating the entity. You may enter anybusiness, trade, or DBA name on the “Business name” line.

If the account is in joint names, list first, and then circle,the name of the person or entity whose number you enteredin Part I of the form.

Limited liability company (LLC). If you are a single-memberLLC (including a foreign LLC with a domestic owner) that isdisregarded as an entity separate from its owner underTreasury regulations section 301.7701-3, enter the owner’sname on the “Name” line. Enter the LLC’s name on the“Business name” line. Check the appropriate box for yourfiling status (sole proprietor, corporation, etc.), then checkthe box for “Other” and enter “LLC” in the space provided.

Specific Instructions

Name

Exempt From Backup Withholding

Generally, individuals (including sole proprietors) are notexempt from backup withholding. Corporations are exemptfrom backup withholding for certain payments, such asinterest and dividends.

5. You do not certify to the requester that you are notsubject to backup withholding under 4 above (for reportableinterest and dividend accounts opened after 1983 only).

Certain payees and payments are exempt from backupwithholding. See the instructions below and the separateInstructions for the Requester of Form W-9.

Civil penalty for false information with respect towithholding. If you make a false statement with noreasonable basis that results in no backup withholding, youare subject to a $500 penalty.Criminal penalty for falsifying information. Willfullyfalsifying certifications or affirmations may subject you tocriminal penalties including fines and/or imprisonment.

PenaltiesFailure to furnish TIN. If you fail to furnish your correct TINto a requester, you are subject to a penalty of $50 for eachsuch failure unless your failure is due to reasonable causeand not to willful neglect.

Misuse of TINs. If the requester discloses or uses TINs inviolation of Federal law, the requester may be subject to civiland criminal penalties.

If you are an individual, you must generally enter the nameshown on your social security card. However, if you havechanged your last name, for instance, due to marriagewithout informing the Social Security Administration of thename change, enter your first name, the last name shown onyour social security card, and your new last name.

Exempt payees. Backup withholding is not required on anypayments made to the following payees:

1. An organization exempt from tax under section 501(a),any IRA, or a custodial account under section 403(b)(7) if theaccount satisfies the requirements of section 401(f)(2),

2. The United States or any of its agencies orinstrumentalities,

3. A state, the District of Columbia, a possession of theUnited States, or any of their political subdivisions orinstrumentalities,

4. A foreign government or any of its political subdivisions,agencies, or instrumentalities, or

5. An international organization or any of its agencies orinstrumentalities.

Other payees that may be exempt from backupwithholding include:

6. A corporation,

If you are exempt, enter your name as described above andcheck the appropriate box for your status, then check the“Exempt from backup withholding” box in the line followingthe business name, sign and date the form.

4. The IRS tells you that you are subject to backupwithholding because you did not report all your interest anddividends on your tax return (for reportable interest anddividends only), or

3. The IRS tells the requester that you furnished anincorrect TIN, or

2. You do not certify your TIN when required (see the PartII instructions on page 4 for details), or

You will not be subject to backup withholding on paymentsyou receive if you give the requester your correct TIN, makethe proper certifications, and report all your taxable interestand dividends on your tax return.

1. You do not furnish your TIN to the requester, or

What is backup withholding? Persons making certainpayments to you must under certain conditions withhold andpay to the IRS 28% of such payments (after December 31,2002). This is called “backup withholding.” Payments thatmay be subject to backup withholding include interest,dividends, broker and barter exchange transactions, rents,royalties, nonemployee pay, and certain payments fromfishing boat operators. Real estate transactions are notsubject to backup withholding.

Payments you receive will be subject to backupwithholding if:

If you are a nonresident alien or a foreign entity not subjectto backup withholding, give the requester the appropriatecompleted Form W-8.

Example. Article 20 of the U.S.-China income tax treatyallows an exemption from tax for scholarship incomereceived by a Chinese student temporarily present in theUnited States. Under U.S. law, this student will become aresident alien for tax purposes if his or her stay in the UnitedStates exceeds 5 calendar years. However, paragraph 2 ofthe first Protocol to the U.S.-China treaty (dated April 30,1984) allows the provisions of Article 20 to continue to applyeven after the Chinese student becomes a resident alien ofthe United States. A Chinese student who qualifies for thisexception (under paragraph 2 of the first protocol) and isrelying on this exception to claim an exemption from tax onhis or her scholarship or fellowship income would attach toForm W-9 a statement that includes the informationdescribed above to support that exemption.

Note. You are requested to check the appropriate box foryour status (individual/sole proprietor, corporation, etc.).

Note. If you are exempt from backup withholding, youshould still complete this form to avoid possible erroneousbackup withholding.

4. The type and amount of income that qualifies for theexemption from tax.

5. Sufficient facts to justify the exemption from tax underthe terms of the treaty article.


I.R.S. SPECIFICATIONS TO BE REMOVED BEFORE PRINTING



3

Part I. Taxpayer IdentificationNumber (TIN)Enter your TIN in the appropriate box. If you are a residentalien and you do not have and are not eligible to get an SSN,your TIN is your IRS individual taxpayer identification number(ITIN). Enter it in the social security number box. If you donot have an ITIN, see How to get a TIN below.

How to get a TIN. If you do not have a TIN, apply for oneimmediately. To apply for an SSN, get Form SS-5,Application for a Social Security Card, from your local SocialSecurity Administration office or get this form on-line atwww.socialsecurity.gov/online/ss-5.pdf. You may also get thisform by calling 1-800-772-1213. Use Form W-7, Applicationfor IRS Individual Taxpayer Identification Number, to applyfor an ITIN, or Form SS-4, Application for EmployerIdentification Number, to apply for an EIN. You can apply foran EIN online by accessing the IRS website atwww.irs.gov/businesses/ and clicking on Employer IDNumbers under Related Topics. You can get Forms W-7 andSS-4 from the IRS by visiting www.irs.gov or by calling1-800-TAX-FORM (1-800-829-3676).

If you are asked to complete Form W-9 but do not have aTIN, write “Applied For” in the space for the TIN, sign anddate the form, and give it to the requester. For interest anddividend payments, and certain payments made with respectto readily tradable instruments, generally you will have 60days to get a TIN and give it to the requester before you aresubject to backup withholding on payments. The 60-day ruledoes not apply to other types of payments. You will besubject to backup withholding on all such payments until youprovide your TIN to the requester.

If you are a sole proprietor and you have an EIN, you mayenter either your SSN or EIN. However, the IRS prefers thatyou use your SSN.

If you are a single-owner LLC that is disregarded as anentity separate from its owner (see Limited liability company(LLC) on page 2), enter your SSN (or EIN, if you have one). Ifthe LLC is a corporation, partnership, etc., enter the entity’sEIN.Note. See the chart on page 4 for further clarification ofname and TIN combinations.

Note. Writing “Applied For” means that you have alreadyapplied for a TIN or that you intend to apply for one soon.Caution: A disregarded domestic entity that has a foreignowner must use the appropr iate Form W-8.

9. A futures commission merchant registered with theCommodity Futures Trading Commission,

10. A real estate investment trust,11. An entity registered at all times during the tax year

under the Investment Company Act of 1940,12. A common trust fund operated by a bank under

section 584(a),13. A financial institution,14. A middleman known in the investment community as a

nominee or custodian, or15. A trust exempt from tax under section 664 or

described in section 4947.

THEN the payment is exemptfor . . .

IF the payment is for . . .

All exempt recipients except for 9

Interest and dividend payments

Exempt recipients 1 through 13.Also, a person registered underthe Investment Advisers Act of1940 who regularly acts as abroker

Broker transactions

Exempt recipients 1 through 5Barter exchange transactionsand patronage dividends

Generally, exempt recipients1 through 7

Payments over $600 requiredto be reported and directsales over $5,000 1

See Form 1099-MISC, Miscellaneous Income, and its instructions.

However, the following payments made to a corporation (including grossproceeds paid to an attorney under section 6045(f), even if the attorney is acorporation) and reportable on Form 1099-MISC are not exempt frombackup withholding: medical and health care payments, attorneys’ fees; andpayments for services paid by a Federal executive agency.

The chart below shows types of payments that may beexempt from backup withholding. The chart applies to theexempt recipients listed above, 1 through 15.

1

2

7. A foreign central bank of issue,8. A dealer in securities or commodities required to register

in the United States, the District of Columbia, or apossession of the United States,

2



I.R.S. SPECIFICATIONS TO BE REMOVED BEFORE PRINTING


What Name and Number To Give theRequester

Give name and SSN of:For this type of account:

The individual1. Individual

The actual owner of the accountor, if combined funds, the firstindividual on the account 1

2. Two or more individuals (jointaccount)

The minor 23. Custodian account of a minor(Uniform Gift to Minors Act)

The grantor-trustee 14. a. The usual revocablesavings trust (grantor isalso trustee)

1. Interest, dividend, and barter exchange accountsopened before 1984 and broker accounts consideredactive during 1983. You must give your correct TIN, but youdo not have to sign the certification.

The actual owner 1b. So-called trust accountthat is not a legal or validtrust under state law2. Interest, dividend, broker, and barter exchange

accounts opened after 1983 and broker accountsconsidered inactive during 1983. You must sign thecertification or backup withholding will apply. If you aresubject to backup withholding and you are merely providingyour correct TIN to the requester, you must cross out item 2in the certification before signing the form.

The owner 35. Sole proprietorship orsingle-owner LLC

Give name and EIN of:For this type of account:

3. Real estate transactions. You must sign thecertification. You may cross out item 2 of the certification.

A valid trust, estate, orpension trust

6.

Legal entity 4

4. Other payments. You must give your correct TIN, butyou do not have to sign the certification unless you havebeen notified that you have previously given an incorrect TIN.“Other payments” include payments made in the course ofthe requester’s trade or business for rents, royalties, goods(other than bills for merchandise), medical and health careservices (including payments to corporations), payments to anonemployee for services, payments to certain fishing boatcrew members and fishermen, and gross proceeds paid toattorneys (including payments to corporations).

The corporationCorporate or LLC electingcorporate status on Form8832

7.

The organizationAssociation, club, religious,charitable, educational, orother tax-exempt organization

8.

5. Mortgage interest paid by you, acquisition orabandonment of secured property, cancellation of debt,qualified tuition program payments (under section 529),IRA, Coverdell ESA, Archer MSA or HSA contributions ordistributions, and pension distributions. You must giveyour correct TIN, but you do not have to sign thecertification.

The partnershipPartnership or multi-memberLLC

9.

The broker or nomineeA broker or registerednominee

10.

The public entityAccount with the Departmentof Agriculture in the name ofa public entity (such as astate or local government,school district, or prison) thatreceives agricultural programpayments

11.

Privacy Act Notice

List first and circle the name of the person whose number you furnish. Ifonly one person on a joint account has an SSN, that person’s number mustbe furnished.

Circle the minor’s name and furnish the minor’s SSN.

You must show your individual name and you may also enter your businessor “DBA” name on the second name line. You may use either your SSN orEIN (if you have one). If you are a sole proprietor, IRS encourages you touse your SSN.List first and circle the name of the legal trust, estate, or pension trust. (Donot furnish the TIN of the personal representative or trustee unless the legalentity itself is not designated in the account title.)

Note. If no name is circled when more than one name islisted, the number will be considered to be that of the firstname listed.

Sole proprietorship orsingle-owner LLC

The owner 3

12.

Part II. Certification

For a joint account, only the person whose TIN is shown inPart I should sign (when required). Exempt recipients, seeExempt From Backup Withholding on page 2.

3

You must provide your TIN whether or not you are required to file a tax return. Payers must generally withhold 28% of taxableinterest, dividend, and certain other payments to a payee who does not give a TIN to a payer. Certain penalties may also apply.

To establish to the withholding agent that you are a U.S.person, or resident alien, sign Form W-9. You may berequested to sign by the withholding agent even if items 1, 4,and 5 below indicate otherwise.

Section 6109 of the Internal Revenue Code requires you to provide your correct TIN to persons who must file information returnswith the IRS to report interest, dividends, and certain other income paid to you, mortgage interest you paid, the acquisition orabandonment of secured property, cancellation of debt, or contributions you made to an IRA, or Archer MSA or HSA. The IRSuses the numbers for identification purposes and to help verify the accuracy of your tax return. The IRS may also provide thisinformation to the Department of Justice for civil and criminal litigation, and to cities, states, and the District of Columbia to carryout their tax laws. We may also disclose this information to other countries under a tax treaty, or to Federal and state agenciesto enforce Federal nontax criminal laws and to combat terrorism. The authority to disclose information to combat terrorismexpired on December 31, 2003. Legislation is pending that would reinstate this authority.

Signature requirements. Complete the certification asindicated in 1 through 5 below.

1

2

3

4

Material Safety Data Sheet

NITRO-SUL®, 20-0-0-45S

MSDS Number 5100 (Revised: 1/02/08) 6 Pages

Section 1: CHEMICAL PRODUCT and COMPANY IDENTIFICATION

1.1 Product Name ....................................... NITRO-SUL, 20-0-0-45S Chemical Family .................................... Inorganic salt solution Synonyms .............................................. Ammonium polysulfide and ammonium hydroxide, APS Formula .................................................. (NH4)2SX 1.2 Manufacturer .........................................Tessenderlo Kerley Inc. 2255 N. 44

th Street, Suite 300

Phoenix, Arizona 85008-3279 Information ....................................…..... (602) 889-8300 1.3 Emergency Contact ...................... (800) 877-1737 (Tessenderlo Kerley) (800) 424-9300 (CHEMTREC)

Section 2: COMPOSITION, INFORMATION ON INGREDIENTS

2.1 Chemical Ingredients (% by wt.) Ammonium polysulfide CAS #:12259-92-6 55% Ammonium hydroxide CAS #:1336-21-6 31% Free Water CAS #:7732-18-5 14% (See Section 8 for exposure guidelines)

Section 3: HAZARDS IDENTIFICATION

NFPA: Health - 3 Flammability - 1 Reactivity - 1

EMERGENCY OVERVIEW

Warning: Avoid inhalation of product fumes near openings on storage container. Upon release of product solution to the environment ammonia and hydrogen sulfide vapors will evolve. Both of these gases are highly toxic. Product solution is alkaline and corrosive to the skin. Eye contact will cause severe eye irritation and possible corneal damage. Ingestion will result in corrosion of tissues of the gastrointestinal tract.


3.1 POTENTIAL HEALTH EFFECTS EYE: Contact with the eyes by product mist or solution will cause irritation and a burning sensation. Eye contact may result in severe corneal injury. SKIN CONTACT: Contact with product mist or solution will cause skin irritation and may result in corrosion of the skin. SKIN ABSORPTION: Absorption is unlikely to occur. INGESTION: Ingestion of product solution will cause irritation and corrosion of the gastrointestinal tract to include nausea, vomiting and diarrhea. Contact with stomach acid will cause highly toxic hydrogen sulfide to evolve. INHALATION: Inhalation of product vapors (ammonia and hydrogen sulfide) will cause dizziness and unconsciousness possibly resulting in serious falls from elevated positions.. CHRONIC EFFECTS/CARCINOGENICITY: Not listed as a carcinogen by NTP, IARC or OSHA.

Section 4: FIRST AID MEASURES

4.1 EYES: Immediately flush with large quantities of water for 15 minutes. Hold eyelids apart during irrigation to insure thorough flushing of the entire area of the eye and lids. Obtain immediate medical attention. 4.2 SKIN: Immediately flush with large quantities of water. Remove contaminated clothing under a safety shower. Obtain immediate medical attention. 4.3 INGESTION: DO NOT INDUCE VOMITING. If victim is conscious, immediately give large quantities of water. If vomiting does occur, continue to give fluids. Obtain immediate medical attention. 4.4 INHALATION: Remove victim from contaminated atmosphere. If breathing is labored, administer oxygen. If breathing has ceased, clear airway and start mouth to mouth resuscitation. If heart has stopped beating, external heart massage should be applied. Obtain immediate medical attention.

Section 5: FIRE FIGHTING MEASURES

5.1 FLAMMABLE PROPERTIES FLASH POINT: Not flammable (See Section 5.4) METHOD USED: NA 5.2 FLAMMABLE LIMITS H2S LFL: 4% UFL: 44% NH3 LFL: 16% UFL: 28% 5.3 EXTINGUISHING MEDIA: Water spray or foam or as appropriate for combustibles involved in fire.

Section 5: FIRE FIGHTING MEASURES (Cont.)

5.4 FIRE & EXPLOSIVE HAZARDS: .When heated or diluted ammonia vapors and hydrogen sulfide vapors will evolve. Both of these gases may form explosive mixtures with air. (See Section 5.2) Keep containers/storage vessels in fire area cooled with water spray. 5.5 FIRE FIGHTING EQUIPMENT: Because of the possible presence of toxic gases and the corrosive nature of the product, wear self-contained breathing apparatus, pressure demand, MSHA/NIOSH (approved or equivalent) and full protective gear.

Section 6: ACCIDENTAL RELEASE MEASURES

6.1 Small releases: Confine and absorb small releases on sand, earth or other inert absorbent. Released material may contain residual sulfides. Spray with weak (~5%) hydrogen peroxide to oxidize sulfides. 6.2 Large releases: Confine area to qualified personnel. Wear proper protective equipment. Shut off release if safe to do so. Dike spill area to prevent runoff into sewers, drains (possible explosive mixtures) or surface waterways (potential aquatic toxicity). Spray product vapors with water spray or mist. Recover as much of the solution as possible. Treat remaining material as a small release (above).

Section 7: HANDLING and STORAGE

7.1 Handling: Handle in enclosed containers to avoid breathing product. Avoid contact with skin and eyes. Dilute only in enclosed containers. Use in a well ventilated area. Wash thoroughly after handling. 7.2 Storage: Store in well ventilated areas in enclosed containers. Do not store combustibles in the area of storage vessels. Keep away from any sources of heat or flame. Store tote and smaller containers out of direct sunlight at moderate temperatures [<90ºF (32ºC)]. (See Section 10.4 for materials of construction)

Section 8: EXPOSURE CONTROLS, PERSONAL PROTECTION

8.1 RESPIRATORY PROTECTION: Wear self-contained breathing apparatus, pressure demand, MSHA/NIOSH (approved or equivalent). 8.2 SKIN PROTECTION: Gloves, boots, and chemical suit should be worn to prevent liquid contact. Wash contaminated clothing prior to reuse. Contaminated shoes cannot be cleaned and should be discarded 8.3 EYE PROTECTION: Chemical goggles and a full face shield. 8.4 EXPOSURE GUIDELINES: OSHA ACGIH TWA STEL TLV STEL Ammonia 25 ppm 35 ppm 25 ppm 35 ppm Hydrogen sulfide 20 ppm (ceiling) 10 ppm (ceiling) 8.5 ENGINEERING CONTROLS: Use adequate exhaust ventilation to prevent inhalation of product vapors. Maintain eyewash/safety shower in areas where chemical is handled.

Section 9: PHYSICAL and CHEMICAL PROPERTIES

9.1 APPEARANCE: Ruby red liquid 9.2 ODOR: Strong ammonia odor.

9.3 BOILING POINT: 100 °F(38 °C)

9.4 VAPOR PRESSURE: 314 mm Hg @ 70 °F (21.1 °C) 9.5 VAPOR DENSITY: Not determined 9.6 SOLUBILITY IN WATER: Dissolves with precipitation of elemental sulfur. 9.7 SPECIFIC GRAVITY: 1.15 - 1.18 (9.6 - 9.8 lbs/gal) 9.8 FREEZING POINT: 0º - 32º F (-17.8º - 0º C) 9.9 pH: 10.8 - 11.5 9.10 VOLATILE: Not applicable

Section 10: STABILITY and REACTIVITY

10.1 STABILITY: This is a stable material 10.2 HAZARDOUS POLYMERIZATION: Will not occur. 10.3 HAZARDOUS DECOMPOSITION PRODUCTS: Heating this product will initially evolve ammonia. As the pH of the solution decreases more hydrogen sulfide vapors will evolve. Continued heating will also cause oxides of nitrogen to be released. 10.4 INCOMPATIBILITY: Strong oxidizers such as nitrates, nitrites or chlorates can cause explosive mixtures if heated to dryness. Acids will cause the release of hydrogen sulfide, a highly toxic gas and ammonia. Alkalies will accelerate the evolution of ammonia. Ammonium polysulfide is not compatible with copper, zinc or their alloys (i.e. bronze, brass, galvanized metals, etc.). These materials of construction should not be used in handling systems or storage containers for this product. (SEE Section 7.2, Storage)

Section 11: TOXICOLOGICAL INFORMATION

11.1 ORAL: Oral-Rat LD50: 152 mg/Kg (ammonium polysulfide) Oral-Rat LD50: 350 mg/Kg (ammonium hydroxide) 11.2 DERMAL: Data not available 11.3 INHALATION: Data not available 11.4 CHRONIC/CARCINOGENICITY: No evidence available 11.5 TERATOLOGY: Data not available 11.6 REPRODUCTION: Data not available 11.7 MUTAGENICITY: Data not available

Section 12: ECOLOGICAL INFORMATION

No data available.

Section 13: DISPOSAL CONSIDERATIONS

If released to the environment for other than its intended purpose, this product contains some reactive sulfides and may meet the definition of a D003, hazardous waste.

Section 14: TRANSPORT INFORMATION

14.1 DOT Shipping Name: Ammonium polysulfide solution 14.2 DOT Hazard Class: 8 (6.1) 14.3 UN/NA Number: 2818 14.4 Packing Group: III 14.5 DOT Placard: Corrosive 14.6 DOT Label(s): Corrosive, Toxic 14.7 IMO Shipping Name: Ammonium polysulphide solution 14.8 RQ (Reportable Quantity): 100 lbs (Hydrogen sulfide released - requires 173 gal of product.) 14.9 RR STCC Number: 28-191-44

Section 15: REGULATORY INFORMATION

15.1 OSHA: This product is listed as a hazardous material under criteria of the Federal OSHA Hazard Communication Standard, 29 CFR 1910.1200. 15.2 SARA TITLE III: a. EHS (Extremely Hazardous Substance) List: No b. Section 311/312, (Tier I,II) Categories: Immediate (acute) Yes Fire Yes Sudden release No Reactivity Yes Delayed (chronic) No c. Section 313 (Toxic Release Reporting-Form R): Yes Chemical Name CAS Number Concentration Ammonia 7664-41-7 24.3% d. TPQ (Threshold Planning Quantity): No

Section 15: REGULATORY INFORMATION, Cont

15.3 CERCLA/SUPERFUND: RQ (Reportable Quantity) No 15.4 TSCA (Toxic Substance Control Act) Inventory List: Yes 15.5 RCRA (Resource Conservation and Recovery Act) Status: No (See Section 13) 15.6 WHMIS (Canada) Hazard Classification: E, D2B 15.7 DOT Hazardous Material: (See Section 14) Yes 15.8 CAA Hazardous Air Pollutant (HAP) No

Section 16: OTHER INFORMATION

REVISIONS: The entire MSDS was reformatted to comply to ANSI Standard Z400.1- 1993, by Technical Services-Tessenderlo Kerley, Inc. Address updated, 4/30/99 Revised Section 8.3, Eye Protection and logo, 5/2/02 Revised Section 13, Disposal considerations, 5/12/06 Revised Section 14, Transportation Information 1/02/08 THE INFORMATION PUBLISHED IN THIS MATERIAL SAFETY DATA SHEET HAS BEEN COMPILED FROM OUR EXPERIENCE AND OSHA, ANSI, NFPA, DOT, ERG, AND CHRIS. IT IS THE USER’S RESPONSIBILITY TO DETERMINE THE SUITABILITY OF THIS INFORMATION FOR THE ADOPTION OF NECESSARY SAFETY PRECAUTIONS. WE RESERVE THE RIGHT TO REVISE MATERIAL SAFETY DATA SHEETS PERIODICALLY AS NEW INFORMATION BECOMES AVAILABLE.

Material Safety Data Sheet

NITRO-SUL®, 20-0-0-40S

MSDS Number 5000 (Revised: 1/02/08) 6 Pages

Section 1: CHEMICAL PRODUCT and COMPANY IDENTIFICATION

1.1 Product Name ....................................... NITRO-SUL, 20-0-0-40S Chemical Family .................................... Inorganic salt solution Synonyms .............................................. Ammonium polysulfide and ammonium hydroxide, APS Formula .................................................. (NH4)2SX 1.2 Manufacturer .........................................Tessenderlo Kerley Inc. 2255 N. 44

th Street, Suite 300

Phoenix, Arizona 85008-3279 Information ....................................…..... (602) 889-8300 1.3 Emergency Contact ...................... (800) 877-1737 (Tessenderlo Kerley) (800) 424-9300 (CHEMTREC)

Section 2: COMPOSITION, INFORMATION ON INGREDIENTS

2.1 Chemical Ingredients (% by wt.) Ammonium polysulfide CAS #:12259-92-6 45% Ammonium hydroxide CAS #:1336-21-6 33% Free Water CAS #:7732-18-5 18% (See Section 8 for exposure guidelines)


NFPA: Health - 3 Flammability - 1 Reactivity - 1

EMERGENCY OVERVIEW

Warning: Avoid inhalation of product fumes near openings on storage container. Upon release of product solution to the environment ammonia and hydrogen sulfide vapors will evolve. Both of these gases are highly toxic. Product solution is alkaline and corrosive to the skin. Eye contact will cause severe eye irritation and possible corneal damage. Ingestion will result in corrosion of tissues of the gastrointestinal tract.


3.1 POTENTIAL HEALTH EFFECTS EYE: Contact with the eyes by product mist or solution will cause irritation and a burning sensation. Eye contact may result in severe corneal injury. SKIN CONTACT: Contact with product mist or solution will cause skin irritation and may result in corrosion of the skin. SKIN ABSORPTION: Absorption is unlikely to occur. INGESTION: Ingestion of product solution will cause irritation and corrosion of the gastrointestinal tract to include nausea, vomiting and diarrhea. Contact with stomach acid will cause highly toxic hydrogen sulfide to evolve. INHALATION: Inhalation of product vapors (ammonia and hydrogen sulfide) will cause dizziness and unconsciousness possibly resulting in serious falls from elevated positions.. CHRONIC EFFECTS/CARCINOGENICITY: Not listed as a carcinogen by NTP, IARC or OSHA.

Section 4: FIRST AID MEASURES

4.1 EYES: Immediately flush with large quantities of water for 15 minutes. Hold eyelids apart during irrigation to insure thorough flushing of the entire area of the eye and lids. Obtain immediate medical attention. 4.2 SKIN: Immediately flush with large quantities of water. Remove contaminated clothing under a safety shower. Obtain immediate medical attention. 4.3 INGESTION: DO NOT INDUCE VOMITING. If victim is conscious, immediately give large quantities of water. If vomiting does occur, continue to give fluids. Obtain immediate medical attention. 4.4 INHALATION: Remove victim from contaminated atmosphere. If breathing is labored, administer oxygen. If breathing has ceased, clear airway and start mouth to mouth resuscitation. If heart has stopped beating, external heart massage should be applied. Obtain immediate medical attention.

Section 5: FIRE FIGHTING MEASURES

5.1 FLAMMABLE PROPERTIES FLASH POINT: Not flammable (See Section 5.4) METHOD USED: NA 5.2 FLAMMABLE LIMITS H2S LFL: 4% UFL: 44% NH3 LFL: 16% UFL: 28% 5.3 EXTINGUISHING MEDIA: Water spray or foam or as appropriate for combustibles involved in fire.

Section 5: FIRE FIGHTING MEASURES (Cont.)

5.4 FIRE & EXPLOSIVE HAZARDS: .When heated or diluted ammonia vapors and hydrogen sulfide vapors will evolve. Both of these gases may form explosive mixtures with air. (See Section 5.2) Keep containers/storage vessels in fire area cooled with water spray. 5.5 FIRE FIGHTING EQUIPMENT: Because of the possible presence of toxic gases and the corrosive nature of the product, wear self-contained breathing apparatus, pressure demand, MSHA/NIOSH (approved or equivalent) and full protective gear.

Section 6: ACCIDENTAL RELEASE MEASURES

6.1 Small releases: Confine and absorb small releases on sand, earth or other inert absorbent. Released material may contain residual sulfides. Spray with weak (~5%) hydrogen peroxide to oxidize sulfides. 6.2 Large releases: Confine area to qualified personnel. Wear proper protective equipment. Shut off release if safe to do so. Dike spill area to prevent runoff into sewers, drains (possible explosive mixtures) or surface waterways (potential aquatic toxicity). Spray product vapors with water spray or mist. Recover as much of the solution as possible. Treat remaining material as a small release (above).

Section 7: HANDLING and STORAGE

7.1 Handling: Handle in enclosed containers to avoid breathing product. Avoid contact with skin and eyes. Dilute only in enclosed containers. Use in a well ventilated area. Wash thoroughly after handling. 7.2 Storage: Store in well ventilated areas in enclosed containers. Do not store combustibles in the area of storage vessels. Keep away from any sources of heat or flame. Store tote and smaller containers out of direct sunlight at moderate temperatures [<90ºF (32ºC)]. (See Section 10.4 for materials of construction)

Section 8: EXPOSURE CONTROLS, PERSONAL PROTECTION

8.1 RESPIRATORY PROTECTION: Wear self-contained breathing apparatus, pressure demand, MSHA/NIOSH (approved or equivalent). 8.2 SKIN PROTECTION: Gloves, boots, and chemical suit should be worn to prevent liquid contact. Wash contaminated clothing prior to reuse. Contaminated shoes cannot be cleaned and should be discarded 8.3 EYE PROTECTION: Chemical goggles and a full face shield. 8.4 EXPOSURE GUIDELINES: OSHA ACGIH TWA STEL TLV STEL Ammonia 25 ppm 35 ppm 25 ppm 35 ppm Hydrogen sulfide 20 ppm (ceiling) 10 ppm (ceiling) 8.5 ENGINEERING CONTROLS: Use adequate exhaust ventilation to prevent inhalation of product vapors. Maintain eyewash/safety shower in areas where chemical is handled.

Section 9: PHYSICAL and CHEMICAL PROPERTIES

9.1 APPEARANCE: Ruby red liquid 9.2 ODOR: Strong ammonia odor.

9.3 BOILING POINT: 100 °F(38 °C)

9.4 VAPOR PRESSURE: 314 mm Hg @ 70 °F (21.1 °C) 9.5 VAPOR DENSITY: Not determined 9.6 SOLUBILITY IN WATER: Dissolves with precipitation of elemental sulfur. 9.7 SPECIFIC GRAVITY: 1.13 - 1.16 (9.4 - 9.7 lbs/gal) 9.8 FREEZING POINT: 0º - 32º F (-17.8º - 0º C) 9.9 pH: 10.8 - 11.5 9.10 VOLATILE: Not applicable

Section 10: STABILITY and REACTIVITY

10.1 STABILITY: This is a stable material 10.2 HAZARDOUS POLYMERIZATION: Will not occur. 10.3 HAZARDOUS DECOMPOSITION PRODUCTS: Heating this product will initially evolve ammonia. As the pH of the solution decreases more hydrogen sulfide vapors will evolve. Continued heating will also cause oxides of nitrogen to be released. 10.4 INCOMPATIBILITY: Strong oxidizers such as nitrates, nitrites or chlorates can cause explosive mixtures if heated to dryness. Acids will cause the release of hydrogen sulfide, a highly toxic gas and ammonia. Alkalies will accelerate the evolution of ammonia. Ammonium polysulfide is not compatible with copper, zinc or their alloys (i.e. bronze, brass, galvanized metals, etc.). These materials of construction should not be used in handling systems or storage containers for this product. (SEE Section 7.2, Storage)

Section 11: TOXICOLOGICAL INFORMATION

11.1 ORAL: Oral-Rat LD50: 152 mg/Kg (ammonium polysulfide) Oral-Rat LD50: 350 mg/Kg (ammonium hydroxide) 11.2 DERMAL: Data not available 11.3 INHALATION: Data not available 11.4 CHRONIC/CARCINOGENICITY: No evidence available 11.5 TERATOLOGY: Data not available 11.6 REPRODUCTION: Data not available 11.7 MUTAGENICITY: Data not available

Section 12: ECOLOGICAL INFORMATION

No data available.

Section 13: DISPOSAL CONSIDERATIONS

If released to the environment for other than its intended purpose, this product contains some reactive sulfides and may meet the definition of a D003, hazardous waste.

Section 14: TRANSPORT INFORMATION

14.1 DOT Shipping Name: Ammonium polysulfide solution 14.2 DOT Hazard Class: 8, 6.1 IMO: 8, 6.1 14.3 UN/NA Number: 2818 IMO: 2818 14.4 Packing Group: III 14.5 DOT Placard: Corrosive IMO: Corrosive, poison 14.6 DOT Label(s): Corrosive, poison IMO: Corrosive, poison 14.7 IMO Shipping Name: Ammonium polysulphide solution 14.8 RQ (Reportable Quantity): 100 lbs (Hydrogen sulfide released - requires 176 gal of product.) 14.9 RR STCC Number: 28-714-33

Section 15: REGULATORY INFORMATION

15.1 OSHA: This product is listed as a hazardous material under criteria of the Federal OSHA Hazard Communication Standard, 29 CFR 1910.1200. 15.2 SARA TITLE III: a. EHS (Extremely Hazardous Substance) List: No b. Section 311/312, (Tier I,II) Categories: Immediate (acute) Yes Fire Yes Sudden release No Reactivity Yes Delayed (chronic) No c. Section 313 (Toxic Release Reporting-Form R): Yes

Section 15: REGULATORY INFORMATION, Cont

Chemical Name CAS Number Concentration Ammonia 7664-41-7 24.3% d. TPQ (Threshold Planning Quantity): No 15.3 CERCLA/SUPERFUND: RQ (Reportable Quantity) No 15.4 TSCA (Toxic Substance Control Act) Inventory List: Yes 15.5 RCRA (Resource Conservation and Recovery Act) Status: No (See Section 13) 15.6 WHMIS (Canada) Hazard Classification: E, D2B 15.7 DOT Hazardous Material: (See Section 14) Yes 15.8 CAA Hazardous Air Pollutant (HAP) No

Section 16: OTHER INFORMATION

REVISIONS: The entire MSDS was reformatted to comply to ANSI Standard Z400.1- 1993, by Technical Services-Tessenderlo Kerley, Inc. Address updated, 4/30/99 Section 8.3, Eye Protection revised and revised logo, 4/30/02 Section 13, Disposal considerations revised, 5/12/06 Section 14, Transportation Information revised 1/02/08 THE INFORMATION PUBLISHED IN THIS MATERIAL SAFETY DATA SHEET HAS BEEN COMPILED FROM OUR EXPERIENCE AND OSHA, ANSI, NFPA, DOT, ERG, AND CHRIS. IT IS THE USER’S RESPONSIBILITY TO DETERMINE THE SUITABILITY OF THIS INFORMATION FOR THE ADOPTION OF NECESSARY SAFETY PRECAUTIONS. WE RESERVE THE RIGHT TO REVISE MATERIAL SAFETY DATA SHEETS PERIODICALLY AS NEW INFORMATION BECOMES AVAILABLE.

F e b O B O B 1 1 : 5 5 a R e d E u a l d I n c

2 7 0 . - - @ -

8 3 0 7 8 0 4 ? ' , 7 ?

IIANTANK NO- 3

9,OOO GALLON FERTILIZER STORAGE TANK

I REF: BLYTHE. cA.

BIG W SALESSTOCKTON. CALIFORNIADRAWTNG f SK25160

p . 4

N

If

n

oIi-

\zY

,r'-l

Ft o

I

;-^,-/SUHP AT

IHt-.1

AY,

I HIGH END II oF sLoPE II EonoM I

180.

IoI

I

"r9s

+HI9la l

\r:\

\\162

RISK MANAGEMENT PLAN Prepared for: Paul Cooper Helena Chemical Company 10821 W. 15th Avenue Blythe, CA 92225 Prepared by: David A. Weeks, P.E., DEE, CIH Risk Management & Engineering Ltd. 705 W. Avenue B, Suite 400 Garland, TX 75044 972-272-0386 [email protected] October 16, 2008

TABLE OF CONTENTS 1.0 Introduction ............................................................................................................... 1

2.0 Site Specific Information ........................................................................................... 1

3.0 Process Description ................................................................................................... 3

4.0 Management System ................................................................................................. 3

5.0 Five Year Accident History ....................................................................................... 4

6.0 Offsite Consequence Analysis (OCA) ....................................................................... 4

6.1 Anhydrous Ammonia Worst Case OCA Strategy ................................................ 4 6.2 Anhydrous Ammonia Alternative Case OCA Strategy ........................................ 6 6.3 Other Regulated Chemical Worst Case OCA Strategy ........................................ 6 6.4 Other Regulated Chemical Alternative Case OCA............................................... 9

7.0 Accident Prevention Program .................................................................................... 9

7.1 Safety Information (40 CFR § 68.48, CALARP § 2755.1 ) .................................... 9 7.2 Hazard Review (40 CFR § 68.50, CALARP § 2755.2) ........................................ 10 7.3 Operating Procedures (40 CFR § 68.52, CALARP § 2755.3) .............................. 10 7.4 Training (40 CFR § 68.54, CALARP § 2755.4) ................................................... 10 7.5 Maintenance (40 CFR § 68.56, CALARP § 2755.5) ............................................ 10 7.6 Compliance Audits (40 CFR § 68.58, CALARP § 2755.6) .................................. 10 7.7 Incident Investigation (40 CFR § 68.60, CALARP § 2755.7) .............................. 11

8.0 Emergency Response............................................................................................... 11

9.0 State Requirements .................................................................................................. 11

LIST OF ATTACHMENTS Attachment A ― Simple RMP Attachment B ― Chemical Inventory and Process Flow Diagram Attachment C ― Management System Attachment D ― Offsite Consequence Analysis Attachment E ― Safety Specifications Attachment F ― Facility Safety Information Attachment G ― Hazard Review Attachment H ― Operating Procedures Attachment I ― Training Attachment J ― Maintenance Procedures Attachment K ― Compliance Audits Attachment L ― Accident Investigations Attachment M ― Contingency Plan

Risk Management Plan Revision Date 10/16/08 Blythe, CA Page 1 of 11

1.0 Introduction

This Risk Management Plan (RMP) was prepared on behalf of Helena Chemical Company (Helena) pursuant to the requirements of the Clean Air Act § 112(r) as codified by the U.S. Environmental Protection Agency (EPA) at 40 CFR Part 68. Requirements specific to the State of California in the Accidental Release Prevention (CalARP) Program are also addressed in this document. (CALARP specific requirements are discussed in a separate section at the end of this RMP.) This RMP document is designed to address all the requirements of the U.S. EPA and CALARP programs with the specific requirements related to accident prevention that occur on a routine basis consolidated into a sub-document known as the Simple RMP. Facility personnel are encouraged to use the Simple RMP (provided as Attachment A) for daily management of the RMP Program and consult the additional information provided throughout this entire document as necessary. Helena engages in the distribution and sale of chemicals to customers at the Blythe, CA location, most of whom use Helena’s products to support agricultural operations. Standards codified by the Occupational Safety and Health Administration (OSHA) at 29 CFR § 1910.119 are not applicable to operations at this facility because the facility is operated as a retail operation and is exempt from the OSHA standards. Thus, the facility is classified as a Program Level 2 facility under the CALARP and RMP regulations. However, the OSHA standards at 29 CFR § 1910.111, Storage and Handling of Anhydrous Ammonia, are applicable.

2.0 Site Specific Information

The following information is specific to Helena’s operation at this facility. RMP Implementation Manager: Paul Cooper Branch Manager Facility Mailing Address: 10821 W. 15th Avenue Blythe, CA 92225 Facility Location Address: 10821 W. 15th Avenue Blythe, CA 92225 Daytime Phone Number: (760) 922-0243


24-hr Emergency Person and Phone Number: Primary: Paul Cooper

Branch Manager (760) 954-5284 Secondary: Jerry Chaney Warehouse Manager 760-702-1441

RMP Facility I.D. No.: 1000 0003 8791 CESQG No. None Dun & Bradstreet No.: 00-703-6759 NAICS Code: 424910 (Farm Supplies Merchant Wholesalers) Latitude/Longitude of Facility

(North American Datum 1983): 33° 35’ 28.84” / -114° 36’ 9.68”

Name of Local Emergency Contacts: LEPC Region VI

NICK VENT County of San Diego Hazardous Materials Division P.O. Box 129261 San Diego, CA 92112-9261 Phone: (619) 338-2217; Fax. (619) 338-2139 E-mail: [email protected]

Riverside County Fire Department Office of Emergency Services Peter Lent OES1 4080 Lemon Street, Suite 8 P.O. Box 1412 Riverside, CA 92501 (951) 955-4700


Riverside County Fire Department-Blythe Station Bill Zimmerman 140 W. Barnard Blythe, CA 92225 Phone: 760-922-7822

No. of Full-time Employees: 8 Worst Case Consequence Distance: 7,127.1 meters (4.43 miles) Alternative Consequence Distance: 20.68 meters (67.8 ft) Program Level: 2

3.0 Process Description

The Blythe Facility is a retail agricultural chemical facility. Process operations conducted at this facility consist of transferring anhydrous ammonia (ammonia) into one of two storage tanks, and transferring the ammonia from the storage tanks to nurse tanks. Transfer operations from commercial vehicles into storage tanks are conducted by the transportation personnel. Transfer operations from railcars into storage tanks, and from storage tanks into the nurse tanks are performed by Helena personnel. Additional operations include transfer of herbicides, pesticides, and insecticides into a warehouse, warehouse storage, and from the warehouse to customer or Helena vehicles. Helena owns and operates one 15,000–gallon ammonia storage tank and one 12,000–gallon ammonia storage tank. Helena also owns and operates 63 nurse tanks of varying capacities. Helena sales the ammonia in the nurse tanks to the farmers for direct application. A summary of the covered chemicals and process equipment is provided in Attachment B and in the Process Flow Diagram. The total possible bulk storage quantity of ammonia at the Blythe facility is 1,735,917 lbs assuming all tanks are filled to administrative capacity at the same time. The total possible warehouse storage of regulated herbicides, pesticides, and insecticides is 14,532 lbs.

4.0 Management System

The Helena Branch Manager implements the risk management planning process at the Blythe Facility. The Branch Manager has delegated responsibility for many of the day-to-day accident prevention procedures to the Warehouse Manager. Additional routine RMP support operations have been further delegated to other Helena staff. A description of the Blythe RMP Management System is provided in Attachment C.


5.0 Five Year Accident History

The operation of ammonia processing at this location in the past five years has not resulted in any of the following:

• on-site deaths, injuries, or significant property damage; or • off-site deaths, injuries, property damage, environmental damage,

evacuations, or sheltering in place.

In accordance with 40 CFR § 68.3, Helena understands the term “injury” with respect to the RMP program to mean only those effects requiring medical treatment or hospitalization.

6.0 Offsite Consequence Analysis (OCA)

Helena has conducted an offsite consequence analysis in accordance with the following U.S. Environmental Protection Agency and CALARP guidance documents.

California Accidental Release Prevention (CalARP) Program Administering Agency Guidance, January 31, 2005.

Risk Management Program Guidance for Chemical Distributors, EPA 550-B-00-005, Office of Solid Waste and Emergency Response, May, 2000.

General Guidance on Risk Management Programs for Chemical Accident Prevention, EPA 550-B-04-001, Office of Solid Waste and Emergency Response, April, 2004.

Both worst case and alternative consequence analyses were completed for the ammonia storage and other regulated chemical processes. A detailed description of the OCA is provided in Attachment D including a graphical representation of the worst case and alternative distances to toxic endpoints when modeled chemical concentrations exceed the specified toxic endpoint.

6.1 Anhydrous Ammonia Worst Case OCA Strategy Anhydrous ammonia is a gas at normal temperature and pressure and is stored at the Blythe Facility as a liquid under pressure. The worst case OCA for ammonia was


conducted by calculating an emission rate as the total administrative quantity (85% of total volume) divided by 10 minutes. The fate and transport of the ammonia vapor was modeled with SLAB. The U.S. Department of Energy, U.S. Air Force, and the American Petroleum Institute developed SLAB to model the dispersion of denser-than-air gases. EPA recognized the use of SLAB in its Guidance on the Application of Refined Dispersion Models to Hazardous/Toxic Air Pollutant Releases, EPA-454/R-93-002, 1993. For purposes of modeling the release from the ammonia source, it was assumed that the ammonia tanks were punctured on the side at ground level. The resulting release of ammonia was modeled as a ground level horizontal jet. The molecular weight of ammonia was set equal to the molecular weight of air (29 kg/kg-mol) in the SLAB model in order to keep the ammonia plume from behaving as a buoyant gas. (Otherwise, the ammonia would be incorrectly modeled as buoyant (lighter than air) and not behave properly in the dense gas model.) Additional SLAB parameters that were input to the model are as follows:

• Vapor Heat Capacity (CPS) = 2170 J/Kg-K° • Boiling Point Temperature (TBP) = 239.8 K° • Heat of Vaporization (DHE) = 1,370,840 J/Kg • Liquid Heat Capacity (CHSL) = 4,294 J/Kg-K° • Liquid Density (RHOSL) = 702.99 Kg/m3 • Saturation Pressure Constant (SPB) = 2,132.52 • Saturation Pressure Constant (SPC) = -32.98

SLAB also requires the user to define the area of the release. For purposes of the analysis, it was assumed that some event punctured the ammonia tank resulting in a rectangular hole 4” long and 1.5” wide. The resulting area of the hole is 3.87E-3 m2. The concentration averaging time was set equal to 1-hr (3,600 seconds). Meteorological conditions input into the model were set equal to those specified in Exhibit 4-3 of the EPA RMP Guidance for Chemical Distributors and CALARP 2750.2. The meteorological conditions exercised in the SLAB model are summarized as follows.

• Wind Speed – 1.5 meters per second • Stability Class – F • Ambient Temperature – 49.4 °C (121 °F, maximum 3-year temperature) • Humidity – 50% • Surface Roughness – 0.20 rural


• Release Temperature – model defaults to boiling point temperature at temperatures greater than boiling point

SLAB requires the toxic endpoint concentration to be input into the model in units of parts per million. A conversion from 0.14 mg/L to ppm was made using a molar volume of gas at 121 °F equal to 26.46 moles/liter resulting in a toxic endpoint of 217.9 ppmv. The resulting distance to toxic endpoint is 4.43 miles. The total effected population was calculated from the LandView 6 Census 2000 Population Estimator software package. The total affected population is estimated to be 13,127 people. The public receptors include residences, schools, hospitals, long-term health care facilities, child day care facilities, recreational areas, and commercial industrial areas. No federal RMP environmental receptors are affected including national parks, forests, or monuments; officially designated wildlife preserves, refuges, or sanctuaries; or federal wilderness areas. A small section of the Colorado River does lie within worst case OCA radius.

6.2 Anhydrous Ammonia Alternative Case OCA Strategy The alternative consequence chosen for analysis was the rupture of a 1.5” ammonia transfer hose that was assumed to occur during nurse tank filling. A chemical release equation provided in the referenced guidance (Equation A-6, Appendix 4A, of RMP Guidance for Chemical Distributors) for a pipe discharging liquid under pressure was used to describe the emission rate.

Similar to the worst case OCA, SLAB was used to model the fate and transport of the ammonia. However, in this case, the model was setup to allow SLAB to apportion the flashing of liquid to vapor in accordance with the thermodynamics of the release. The same physical/chemical parameters and meteorological conditions used in the worst case OCA were used in the alternative OCA. The resulting OCA radius (67.8 ft) does not extend beyond the facility boundaries. Therefore, no public or environmental receptors are affected.

6.3 Other Regulated Chemical Worst Case OCA Strategy The OCA for the herbicides, pesticides, and insecticides was challenging because there are multiple chemicals to consider with differing quantities and differing toxic endpoints, and because the chemicals are in both liquid and solid form. Other worst case OCA work assumed a warehouse fire, which although a valid scenario, may not be worst case. The warehouse fire scenario considered the release of a single surrogate chemical, a single


toxic endpoint based on the weight averaged toxic endpoints of the various chemicals involved in the fire, and buoyancy induced lofting of the smoke plume (which effectively creates a release that occurs above ground level and enhances dispersion, although no reduction in the mass of the chemicals from burning was assumed.) RME chose not to pursue this approach because the distance to toxic endpoint for chemicals with very low toxic endpoints may not be conservative and the release does not effectively occur at ground level since the heat from the fire creates an artificial stack height. The worst case analysis chosen by RME involves the spillage of an individual chemical and then vaporization of the liquid pool in the case of chemicals in liquid form, or the entrainment of particles into the air in the case of chemicals in particulate form. Toward that end, the first part of the analysis requires an assumption to be made regarding the amount of chemical that is released (i.e. spilled) into the environment. (The vaporization of regulated chemicals from solid particulate was considered, but the results were not reported in RMP Submit or the results section above due to the lack of accurate vapor pressure data for chemicals in a solid matrix.) The RMP/CALARP regulations require the OCA to consider at least the mass of the chemical in the largest single vessel. In the case of the herbicides, pesticides, and insecticides, the chemicals are stored in small containers (e.g. 2.5 gallons) of which multiple containers are stored in boxes, with multiple boxes stored on pallets. Therefore, using the quantity in the single largest vessel in a worst case OCA may be inappropriate for chemicals stored together in boxes on pallets because a worst case accident will likely be an event in which multiple containers are involved (e.g. the puncturing of multiple containers with a forklift.) A worst case OCA should involve more chemical than the amount stored in the largest single vessel. Since a determination of how many vessels could be involved in such an accident is beyond the scope of this OCA, the total possible maximum quantity stored was used in this analysis. Such an assumption is highly conservative since it is unlikely that all individual containers would be punctured at one time. The emission rate of the chemicals was calculated using standard equations recommended by U.S. EPA for such analyses. The amount of liquid chemical that evaporates is dependent on the vapor pressure of the chemical, the temperature of the liquid, the size of the pool, and the velocity of the air flowing over the liquid surface. The amount of solid chemical that is entrained into the air is dependent of the size of the particles and the velocity of the air flowing over the particles. Because of the dependence of emission rates on wind velocity above the spill, two separate emission scenarios are required to be considered, one scenario being outdoors


and the other being inside the warehouse. The RMP/CALARP required wind speed of 1.5 meter/sec at 10-meter anemometer height was scaled to a speed above the ground surface for outdoor spills using the friction velocity equation above. The results of this analysis show that solid granule particles cannot become airborne in the case of an outdoor spill because the friction velocity imparted by the air stream does not exceed the threshold friction velocity of the solid granule particles. However, rather using 1.5 m/sec, the mean indoor surface wind speed reported in the technical literature was used to model emissions inside the warehouse. (It should be noted that this value is considered highly conservative for the Blythe warehouse because the study sites were ventilated whereas the Blythe warehouse is not. Additionally, the literature reported mean wind speed was not scaled to a speed directly above the spilled substance because the measurement heights of the supporting literature data differed.) The fate and transport of the evaporated liquid chemical and solid particulate chemical was modeled via a standard U.S. EPA screening air dispersion model, SCREEN3. The validity of using SCREEN3 rather than a dense gas model was verified by estimating the density of the gas above the liquid chemical. The air density of the chemicals was less than air at the maximum 3-year ambient temperature. Air dispersion modeling is required to be completed for every chemical evaluated because the toxic endpoint is different for different chemicals, unless a methodology is used to determine the worst case chemical. A method for determining the worst case chemical was employed in this OCA. The method involved calculating a hazard ratio (HR) defined as the total emission rate of the chemical divided by the chemical's toxic endpoint. Thus, the chemical with the largest emission rate and the smallest toxic endpoint will have the greatest hazard ratio. The liquid and solid chemicals with the greatest hazard ratios were carried through the air dispersion modeling phase. The U.S. EPA SCREEN3 model inputs are limited to emission rate (and area of the spill in the case of area sources, or the initial height and width of the plume in the case of volume sources), height of release, wind speed, anemometer height, and stability class. In this worst case OCA, the height of release was set at 0 meters, wind speed was set at 1.5 m/sec, anemometer height was set at 10 meters, and stability class was specified at F. Initial model runs were made at 10-meter intervals until the toxic endpoint concentration was bounded between two 10-meter intervals. Once bounded, additional distances (if necessary) were trial and errored until the distance to toxic endpoint was established within one meter.


Releases that were assumed to occur outdoors were modeled as area sources with the area established as the area of the spill. Releases that were assumed to occur inside the warehouse were modeled as volume sources with the initial height of the plume established at the height of the warehouse door, and the initial width of the plume established as the width of the warehouse door. The results of the analysis show that the maximum worst case distance to toxic endpoint is 108.3 feet for an outdoor spill of liquid pesticide. This distance does not exceed the facility boundary. Therefore, no public or environmental receptors are affected. However, it should be noted that the distance to toxic endpoint is 1,519 feet for solid chemicals when the vapor emissions of the solid chemical are estimated with procedures used to estimate vapor emissions from liquid chemicals. As reported earlier, the uncertainty of using a procedure established for chemicals in liquid form on chemicals in solid form precludes the reporting of this information in the formal results. Additionally, Section 2750.3 states that “In performing an offsite consequence analysis for solids that are listed in Section 2770.5 Table 3, an owner or operator may use a USEPA, California Air Resources Board, or OES approved model which appropriately considers the dispersion and settling of particles.” Since such a procedure was used, the OCA adequately complies with the requirements of the CALARP regulation.

6.4 Other Regulated Chemical Alternative Case OCA The alternative case OCA was performed in the same manner as the worst case OCA except that the quantity used in the analysis was the quantity in a single container. The results of the alternative OCA show that emissions are not significant enough to exceed the toxic endpoint concentration. Therefore, no public or environmental receptors are affected.

7.0 Accident Prevention Program

Helena’s accident prevention program contains all of the required RMP elements for a Program 2 facility. The specific detail to the accident Prevention Program is provided in the various attachments as discussed below. The attachments have been prepared to address the activities and processes that could be relevant to any and all of the Helena facilities.

7.1 Safety Information (40 CFR § 68.48, CALARP § 2755.1 ) The safety information relevant to the Helena facilities is provided in Attachments E and F. The safety information includes relevant codes and standards to which Helena facilities are built and operated, MSDS documentation for regulated chemicals, storage and process limits, and equipment specifications.


7.2 Hazard Review (40 CFR § 68.50, CALARP § 2755.2) Helena has completed a hazard review applicable to its operations. The hazard review checklist is provided as Attachment G.

7.3 Operating Procedures (40 CFR § 68.52, CALARP § 2755.3) Operating procedures at Helena facilities relevant to ammonia storage processes focus on the loading and unloading of ammonia from railcar and tanker trucks into stationary storage tanks, and from stationary storage tanks into nurse tanks. The operating procedures for the warehouse focus on moving materials from trucks to the warehouse in a safe manner. The relevant operating procedures are provided in Attachment H. (The commercial carrier is responsible for implementing the operating procedures for all RMP covered processes at this facility as related to its transfer operations into the storage tanks.)

7.4 Training (40 CFR § 68.54, CALARP § 2755.4) Helena provides training to its employees on the operating procedures of Helena facility ammonia storage processes which may include the loading and unloading of ammonia. A Certification of Required Knowledge (Attachment I) is completed at each facility location and for each person trained. However, the commercial carrier is responsible for performing training related to its RMP covered processes that includes the transfer of ammonia from a rail car or tanker truck into a storage tank. Commercial carriers are required to submit certifications of training.

7.5 Maintenance (40 CFR § 68.56, CALARP § 2755.5) The relevant maintenance procedures at the Helena facilities are specifically related to the process of storing and transferring ammonia. The relevant procedures are provided in Attachment J. At Helena facilities where railcar(s) are parked or where tanker trucks are used to deliver the ammonia, the owner of the railcar or tanker truck is responsible for implementing their respective RMP covered process maintenance procedures.

7.6 Compliance Audits (40 CFR § 68.58, CALARP § 2755.6) Helena will conduct an audit of the facility’s compliance with the RMP at least once every 3 years. An example of an audit checklist that Helena may use to guide the audit process is provided in Attachment MK. Helena will maintain documentation that an audit of the RMP process was completed for a minimum of 5 years from the date of the audit.


7.7 Incident Investigation (40 CFR § 68.60, CALARP § 2755.7) Helena will investigate incidents that result in, or could have resulted in a “catastrophic release of a regulated substance.” A catastrophic release is one that presents an imminent and substantial endangerment to public health and the environment. Helena has defined this to be a release of ammonia from the facility in amounts that leave the property boundary or cause an RMP defined injury to Helena workers. Attachment NL provides an example of Helena’s Incident Investigation Report.

8.0 Emergency Response

Helena will conduct emergency response in accordance with the current version of its Contingency Plan. The Contingency Plan is provided as Attachment OM. The Helena Blythe facility is a non-responding facility.

9.0 State Requirements

In the State of California, the “Risk Management Plan Program” is the California Accidental Release Prevention Program, or CalARP. CalARP is the Federal Risk Management Plan Program with additional state requirements, including an additional list of regulated substances and thresholds. For this RMP, the additional chemicals include a variety of pesticides, herbicides, and insecticides.

Health & Safety Code (H&SC), §§ 25531 to 25543.3 is the California statute that authorizes the program. California Code of Regulations, Title 19 (19 CCR or “Title 19”), §§ 2735.1 to 2785.1, contains the regulations for the program.

Risk Management Plan Revision Date 10/16/08 Blythe, CA

ATTACHMENT A

SIMPLE RMP


ATTACHMENT B

CHEMICAL INVENTORY AND PROCESS FLOW DIAGRAM

Units Auto-Ignition T

Quantity3 Unit4 Container Type (F)

Temik 15G Aldicarb 116-06-3 21,645 lb 45 lbs in "Lock & Load" NA 15.0% 3,246.75 Solid N/A 100Furadan 4F Carbofuran 1563-66-2 200 gal 2.5 gal - plastic jug 9.32 44.0% 820 Liquid 680 10Dimethoate 267 Dimethoate 60-51-5 180 gal 2.5 gal - plastic jug 8.59 30.5% 472 Liquid N/A 500Dimethoate 4EC Dimethoate 60-51-5 720 gal 2.5 gal - plastic jug 8.90 43.5% 2,787 Liquid N/A 500Di-Syston 8E Disulfoton 298-04-4 200 gal 2.5 gal - plastic jug 9.34 85.0% 1,588 Liquid 608 500Thionex 3EC Endosulfan 115-29-7 200 gal 2.5 gal - plastic jug 8.82 33.7% 594 Liquid N/A 10Lannate LV Methomyl 16752-77-5 180 gal 2.5 gal - plastic jug 8.52 29.0% 444 Liquid 581 500Lannate SP Methomyl 16752-77-5 1,000 lb 10 lb bags NA 90.0% 900.0 Solid 581 500Vydate C-LV Oxamyl 23135-22-0 200 gal 2.5 gal - plastic jug 9.02 42.0% 758 Liquid 725 100Vydate L Oxamyl 23135-22-0 120 gal 2.5 gal - plastic jug 8.19 24.0% 236 Liquid 577 100Firestorm Paraquat Dichloride 1910-42-5 200 gal 2.5 gal - plastic jug 9.39 43.8% 823 Liquid NA 10Gramoxone Inteon Paraquat Dichloride 1910-42-5 200 gal 2.5 gal - plastic jug 9.35 30.1% 563 Liquid NA 10Thimet 20G Phorate 298-02-2 6500 lb 40 lbs in "Lock & Load" NA 20.0% 1,300 Solid 532 10

14,532

Anhydrous Ammonia Ammonia (15,000 gal tank)

7664-41-7 12750 gal 12750 gal 5.69 99.70% 72330 Liquid NA 500

Anhydrous Ammonia Ammonia (12,000 gal tank)

7664-41-7 10200 gal 10200 gal 5.69 99.70% 57864 Liquid NA 500

Anhydrous Ammonia Ammonia (30,000 gal Railcar - 3)

7664-41-7 76500 gal 25500 gal 5.69 99.70% 433979 Liquid NA 500

Anhydrous AmmoniaAmmonia (1,100 gal Nurse Tanks (3) - all full)

7664-41-7 2550 gal 935 gal 5.69 99.70% 14466 Liquid NA 500

Anhydrous AmmoniaAmmonia (1,000 gal Nurse Tanks (45) - all full)

7664-41-7 38250 gal 850 gal 5.69 99.70% 216990 Liquid NA 500

Anhydrous AmmoniaAmmonia (500 gal Nurse Tanks (15) - all full)

7664-41-7 12750 gal 425 gal 5.69 99.70% 72330 Liquid NA 500

Anhydrous Ammonia Total 7664-41-7 153,000 gal NA 0.68 99.70% 867,958 Liquid 1203 500

1,735,917

Warehouse Storage

Bulk StorageTotal Possible Warehouse Storage of CALARP Regulated Herbicides, Pesticides, and Insecticides

Total Possible Bulk Storage of Anhydrous Ammonia

Quanity in Single

ContainerDensity (lb/gal)

Percent Active

Ingredient5

Maximum Regulated Chemical Storage6

(pounds)

Physical State7

Threshold Planning Quantity8 (pounds)

ATTACHMENT B

MAXIMUM DAILY QUANTITY CHEMICAL INVENTORY

Helena Chemical CompanyBlythe Facility, Riverside County, California

Trade NameRegulated

Chemical Name1CAS

Number

Maximum Daily Storage2

Attachment B Page 1 of 2

5. The percentage of the active ingredient (regulated chemical) that is contained in the stored trade name product.6. Calculated weight of maximum daily storage of regulated chemical (quantity x percent active ingredient x liquid density).

7. The physical state of the regulated chemical as stored

8. Threshold planning quantity for regulated chemicals in pounds, as defined in 19 California Code of Regulations (CCR) Division 2, Chapter 4.5.

3. The maximum daily storage amount.4. Units of the maximum daily storage quantity.

1. The regulated chemical that is the active ingredient of the trade name product.2. The maximum daily storage quantity of a trade name product containing a regulated chemical, present at any time, based on the Facility inventory.

Attachment B Page 2 of 2

rme project #: 1040

PROCESS FLOW DIAGRAM

JULY 29, 2008

HOWECOMPRESSOR

12,000 GALLON TANK

VVI0 VV11

VV9

15,000 GALLON TANK

LVIIFDI 2

VAPOR

PRV3 PRV4

PRV1 PRV2

VVI2

LV13

LV12

INSTALLATION OF TRIPOD BREAKAWAYSHUT-OFF VALVES ANTICIPATED

CORKINCOMPRESSOR

4 - WAY VALVE

VV7

(VV2)

VV8 LV9

VAPOR

LIQUID

VV1 LV1

HRV1

FLOWDIRECTIONINDICATOR(FDI 1)

EMERGENCYSHUT-OFFVALVE(LV2)

HRV 2

(VV3) (LV3)

(VV4)

(LV4)

(VV5)

(LV6)

(LV5)

VV6

LV7

LV8

TRI POD BREAKAWAYSHUT-OFF VALVE

4 - WAY VALVE

EXV 2

EXF 1

HELENA CHEMICAL COMPANY10821 15th AVENUEBLYTHE, CA 92225

LIQUID

LV10

LV14


ATTACHMENT C

MANAGEMENT SYSTEM


ATTACHMENT D

OFFSITE CONSEQUENCE ANALYSIS

ATTACHMENT D - 1

1.0 Introduction

Helena has conducted an offsite consequence analysis in accordance with the following U.S. Environmental Protection Agency and CALARP guidance documents.

California Accidental Release Prevention (CalARP) Program Administering Agency Guidance, January 31, 2005.

Risk Management Program Guidance for Chemical Distributors, EPA 550-B-00-005, Office of Solid Waste and Emergency Response, May, 2000.

General Guidance on Risk Management Programs for Chemical Accident Prevention, EPA 550-B-04-001, Office of Solid Waste and Emergency Response, April, 2004.

Both worst case and alternative consequence analyses were completed for the ammonia storage and other regulated chemical processes.

2.0 Anhydrous Ammonia OCA Results

2.1 OCA Results (Worst Case) (1) Chemical name: Anhydrous Ammonia (2) Percentage weight of the chemical in a liquid mixture: 99.7% (3) Physical state (toxics only): Gas Liquefied Under Pressure (4) Basis of results (give model name if used): Tank Puncture, SLAB Model (5) Scenario (explosion, fire, toxic gas release, or liquid spill and vaporization): Toxic Gas Release (6) Quantity released in pounds: 144,660 lb (7) Release rate: 14,466 lb/min (8) Release duration: 10 min (9) Wind speed and atmospheric stability class (toxics only): 1.5 m/sec, F (10) Topography (toxics only): Flat (11) Distance to endpoint: 4.43 miles (7,127.4 meters) (12) Public and environmental receptors within the distance: Public; Schools, Hospital, Long-term Health Care Facilities, Child Care Centers, Recreational Areas, and major Commercial and Industrial Areas. Environmental, None.

2.2 OCA Results (Alternative Case) (1) Chemical name: Anhydrous Ammonia (2) Percentage weight of the chemical in a liquid mixture: 99.7% (3) Physical state (toxics only): Gas Liquefied Under Pressure (4) Basis of results (give model name if used): Hose Break, SLAB Model (5) Scenario (explosion, fire, toxic gas release, or liquid spill and vaporization): Toxic Gas Release (6) Quantity released in pounds: 112.46 lb (7) Release rate: 56.23 lb/min (8) Release duration: 2 min (9) Wind speed and atmospheric stability class (toxics only): 1.5 m/sec, F (10) Topography (toxics only): Flat (11) Distance to endpoint: 67.8 ft (12) Public and environmental receptors within the distance: None

ATTACHMENT D - 2

2.3 Worst Case OCA Strategy

Anhydrous ammonia is a gas at normal temperature and pressure and is stored at the Blythe Facility as a liquid under pressure. The worst case OCA for ammonia was conducted by calculating an emission rate as the total administrative quantity (85% of total volume) divided by 10 minutes as described below and shown in Table 1.

Where,

MA = Mass of ammonia (lbs)

TWC = Tank water capacity (gallons) x 85%

Where,

ER = Emission rate (lb/min)

MA = Mass of ammonia (lb)

The fate and transport of the ammonia vapor was modeled with SLAB. The U.S. Department of Energy, U.S. Air Force, and the American Petroleum Institute developed SLAB to model the dispersion of denser-than-air gases. EPA recognized the use of SLAB in its Guidance on the Application of Refined Dispersion Models to Hazardous/Toxic Air Pollutant Releases, EPA-454/R-93-002, 1993.

For purposes of modeling the release from the ammonia source, it was assumed that the ammonia tanks were punctured on the side at ground level. The resulting release of ammonia was modeled as a ground level horizontal jet. The molecular weight of ammonia was set equal to the molecular weight of air (29 kg/kg-mol) in the SLAB model in order to keep the ammonia plume from behaving as a buoyant gas. (Otherwise, the ammonia would be incorrectly modeled as buoyant (lighter than air) and not behave

( ) ⎟⎟⎠

⎞⎜⎜⎝

⎛×=

gallbsgalTM WCA 69.5

min10ER MA=

⎟⎟⎠

⎞⎜⎜⎝

⎛×⎟⎟

⎠

⎞⎜⎜⎝

⎛×⎟

⎠⎞

⎜⎝⎛=⎟

⎠⎞

⎜⎝⎛

s60min

lb2.2kg

minlbER

skgER

ATTACHMENT D - 3

properly in the dense gas model.) Additional SLAB parameters that were input to the model are as follows:

• Vapor Heat Capacity (CPS) = 2170 J/Kg-K° • Boiling Point Temperature (TBP) = 239.8 K° • Heat of Vaporization (DHE) = 1,370,840 J/Kg • Liquid Heat Capacity (CHSL) = 4,294 J/Kg-K° • Liquid Density (RHOSL) = 702.99 Kg/m3 • Saturation Pressure Constant (SPB) = 2,132.52 • Saturation Pressure Constant (SPC) = -32.98

SLAB also requires the user to define the area of the release. For purposes of the analysis, it was assumed that some event punctured the ammonia tank resulting in a rectangular hole 4” long and 1.5” wide. The resulting area of the hole is 3.87E-3 m2. The concentration averaging time was set equal to 1-hr (3,600 seconds).

Meteorological conditions input into the model were set equal to those specified in Exhibit 4-3 of the EPA RMP Guidance for Chemical Distributors and CALARP 2750.2. The meteorological conditions exercised in the SLAB model are summarized as follows.

• Wind Speed – 1.5 meters per second • Stability Class – F • Ambient Temperature – 49.4 °C (121 °F, maximum 3-year temperature) • Humidity – 50% • Surface Roughness – 0.20 rural • Release Temperature – model defaults to boiling point temperature at

temperatures greater than boiling point

SLAB requires the toxic endpoint concentration to be input into the model in units of parts per million. A conversion from 0.14 mg/L to ppm was made using a molar volume of gas at 121 °F equal to 26.46 moles/liter resulting in a toxic endpoint of 217.9 ppmv. The resulting distance to toxic endpoint is 4.43 miles. The SLAB model reports and figures that show the distance to toxic endpoint are provided in Tab 1 of this attachment. The total effected population was calculated from the LandView 6 Census 2000 Population Estimator software package. The total affected population is estimated to be 13,127 people. The public receptors include residences, schools, hospitals, long term health care facilities, child day care facilities, recreational areas, and commercial industrial areas. No federal RMP environmental receptors are affected including national parks, forests, or monuments; officially designated wildlife preserves, refuges, or sanctuaries; or federal wilderness areas. A small section of the Colorado River does lie within worst case OCA radius.

ATTACHMENT D - 4

2.4 Alternative Case OCA Strategy

The alternative consequence chosen for analysis was the rupture of a 1.5” ammonia transfer hose that was assumed to occur during nurse tank filling. A chemical release equation provided in the referenced guidance (Equation A-6, Appendix 4A, of RMP Guidance for Chemical Distributors) for a pipe discharging liquid under pressure was used to describe the emission rate.

( )pl

L

CTVhFalbER×+××××

=)460(

490,9min

lg

Where:

a = area of the release (ft2),

F = friction loss factor,

hL = latent heat of vaporization (BTU/lb),

Vlg = difference in specific volume between gas and liquid (lb/ft3)

T = reservoir temperature (R)

Cpl = liquid heat capacity (BTU/lb-F)

The parameter values used in the calculation are provided in Table 2.

Similar to the worst case OCA, SLAB was used to model the fate and transport of the ammonia. However, in this case, the model was setup to allow SLAB to apportion the flashing of liquid to vapor in accordance with the thermodynamics of the release. The same physical/chemical parameters and meteorological conditions used in the worst case OCA were used in the alternative OCA. The resulting OCA radius (67.8 ft) does not extend beyond the facility boundaries. Therefore, no public or environmental receptors are affected.

3.0 Other Regulated Chemical OCA Results

3.1 OCA Results (Worst Case for Liquid Chemicals) (1) Chemical name: Vydate C-LV (Oxamyl) (2) Percentage weight of the chemical in a liquid mixture: 42% (3) Physical state (toxics only): Liquid (4) Basis of results (give model name if used): Spill of Maximum Possible Quantity, SCREEN3 (5) Scenario (explosion, fire, toxic gas release, or liquid spill and vaporization): Liquid Spill and

Vaporization (6) Quantity released in pounds: 758 lb (7) Release rate: 3.03E-03 lb/min (8) Release duration: Instantaneous for liquid, 4,164 hours for vapor (9) Wind speed and atmospheric stability class (toxics only): 1.5 m/sec, F (10) Topography (toxics only): Flat

ATTACHMENT D - 5

(11) Distance to endpoint: 108.3 ft (12) Public and environmental receptors within the distance: None.

3.2 OCA Results (Alternative Case for Liquid Chemicals) (1) Chemical name: Vydate L (Oxamyl) (2) Percentage weight of the chemical in a liquid mixture: 24% (3) Physical state (toxics only): Liquid (4) Basis of results (give model name if used): Spill of Quantity in Single Container, SCREEN3 (5) Scenario (explosion, fire, toxic gas release, or liquid spill and vaporization): Liquid Spill and

Vaporization (6) Quantity released in pounds: 4.91 lb (7) Release rate: 1.13E-04 lb/min (8) Release duration: Instantaneous for liquid, 722 hours for vapor (9) Wind speed and atmospheric stability class (toxics only): 1.5 m/sec, F (10) Topography (toxics only): Flat (11) Distance to endpoint: 0 ft (12) Public and environmental receptors within the distance: None

3.3 OCA Results (Worst Case for Solid Chemicals) (1) Chemical name: Thimet 20G (Phorate) (2) Percentage weight of the chemical in solid: 20% (3) Physical state (toxics only): Solid granules (4) Basis of results (give model name if used): Spill of Maximum Possible Quantity, SCREEN3 (5) Scenario (explosion, fire, toxic gas release, or liquid spill and vaporization): Solid spill and particle

entrainment in air stream (6) Quantity released in pounds: 1,300 lb (7) Release rate: 2.58E-04 lb/min (8) Release duration: Spill of solid granules occurs instantaneously (9) Wind speed and atmospheric stability class (toxics only): 1.5 m/sec, F (10) Topography (toxics only): Flat (11) Distance to endpoint: 0 ft. (12) Public and environmental receptors within the distance: None.

3.4 OCA Results (Alternative Case for Solid Chemicals) (1) Chemical name: Thimet 20G (Phorate) (2) Percentage weight of the chemical in a liquid mixture: 20% (3) Physical state (toxics only): Solid granules (4) Basis of results (give model name if used): Spill of Quantity in Single Container, SCREEN3 (5) Scenario (explosion, fire, toxic gas release, or liquid spill and vaporization): Solid spill and particle

entrainment in air stream (6) Quantity released in pounds: 8 lb (7) Release rate: 1.59E-6 lb/min (8) Release duration: Spill of solid granules occurs instantaneously (9) Wind speed and atmospheric stability class (toxics only): 1.5 m/sec, F (10) Topography (toxics only): Flat (11) Distance to endpoint: 0 ft (12) Public and environmental receptors within the distance: None

3.5 Worst Case OCA Strategy The OCA for the herbicides, pesticides, and insecticides was challenging because there are multiple chemicals to consider with differing quantities and differing toxic endpoints, and because the chemicals are in both liquid and solid form. Prior worst case OCA work conducted by other consultants assumed a warehouse fire, which although a valid

ATTACHMENT D - 6

scenario, may not be worst case. In conducting the analysis of the warehouse fire scenario the other consultants modeled the release of a single surrogate chemical, weight averaged the toxic endpoints of the various chemicals to determine a single toxic endpoint, and allowed the fire plume to loft thereby creating significant dispersion. (Although no reduction in the mass of the chemicals from burning was assumed.) RME chose not to pursue this approach because the distance to toxic endpoint for chemicals with very low toxic endpoints may not be conservative and the release does not effectively occur at ground level since the heat from the fire creates an artificial stack height. The worst case analysis chosen by RME involves the spillage of an individual chemical and then vaporization of the liquid pool in the case of chemicals in liquid form, or the entrainment of particles into the air in the case of chemicals in particulate form. Toward that end, the first part of the analysis requires an assumption to be made regarding the amount of chemical that is released (i.e. spilled) into the environment. (The vaporization of regulated chemicals from solid particulate was considered, but the results were not reported in RMP Submit or the results section above due to the lack of accurate vapor pressure data for chemicals in a solid matrix.) The RMP/CALARP regulations require the OCA to consider at least the mass of the chemical in the largest single vessel. In the case of the herbicides, pesticides, and insecticides, the chemicals are stored in small containers (e.g. 2.5 gallons) of which multiple containers are stored in boxes, with multiple boxes stored on pallets. Therefore, using the quantity in the single largest vessel in a worst case OCA may be inappropriate for chemicals stored together in boxes on pallets because a worst case accident will likely be an event in which multiple containers are involved (e.g. the puncturing of multiple containers with a forklift.) A worst case OCA should involve more chemical than the amount stored in the largest single vessel. Since a determination of how many vessels could be involved in such an accident is beyond the scope of this OCA, the total possible maximum quantity stored was used in this analysis. Such an assumption is highly conservative since it is unlikely that all individual containers would be punctured at one time. The emission rate of the chemicals was calculated using standard equations recommended by U.S. EPA for such analyses. As shown below, the amount of liquid chemical that evaporates is dependent on the vapor pressure of the chemical, the temperature of the liquid, the size of the pool, and the velocity of the air flowing over the liquid surface. The amount of solid chemical that is entrained into the air is dependent of the size of the particles and the velocity of the air flowing over the particles. Liquid Chemical Emission Rate

LPiuD

TRPvW

cmgG AM

××

××××

=⎟⎟⎠

⎞⎜⎜⎝

⎛−

*

22

sec

Where,

ATTACHMENT D - 7

G = emission flux (g/cm2-sec) WM = mole weight of the evaporating species (g/mole) Pv = vapor pressure of the evaporating species at the liquid temperature (kPa), R = universal gas constant (8.314E3 kPa-cm3/mol-K), DA = diffusivity in air of evaporating species (cm2/sec), u* = wind velocity above the liquid pool (cm/sec), L = length of the evaporating pool (cm) Solid Chemical Emission Rate

( ) ( )[ ]tt uuuukyrm

gEF −×+−××=⎟⎟⎠

⎞⎜⎜⎝

⎛−

*2*2 2558

Where, EF = emission flux (g/m2-yr), k = particle size multiplier (1.0 for particle greater than 30 um), u* = friction velocity (m/sec), see equation below, ut = threshold friction velocity (m/sec) as scaled from Figure 3-3 in Cowherd et.

al. and is dependent on the size of the particle

( ) 10* 053.0sec umu ×=

Where, u10 = wind speed at 10 meters above ground surface (1.5 m/sec) Because of the dependence of emission rates on wind velocity above the spill, two separate emission scenarios are required to be considered, one scenario being outdoors and the other being inside the warehouse. The RMP/CALARP required wind speed of 1.5 meter/sec at 10 meter anemometer height was scaled to a speed above the ground surface for outdoor spills using the friction velocity equation above. The results of this analysis show that solid granule particles cannot become airborne in the case of an outdoor spill because the friction velocity imparted by the air stream does not exceed the threshold friction velocity of the solid granule particles (see Table 5.) However, rather using 1.5 m/sec, the mean indoor surface wind speed reported in the technical literature was used to model emissions inside the warehouse. (It should be noted that this value is considered highly conservative for the Blythe warehouse because the study sites were ventilated whereas the Blythe warehouse is not. Additionally, the literature reported mean wind speed was not scaled to a speed directly above the spilled substance because the measurement heights of the supporting literature data differed.)

ATTACHMENT D - 8

The fate and transport of the evaporated liquid chemical and solid particulate chemical was modeled via a standard U.S. EPA screening air dispersion model, SCREEN3. The validity of using SCREEN3 rather than a dense gas model was verified by estimating the density of the gas above the liquid chemical. The air density of the chemicals was less than air at the maximum 3-year ambient temperature. Air dispersion modeling is required to be completed for every chemical evaluated because the toxic endpoint is different for different chemicals, unless a methodology is used to determine the worst case chemical. A method for determining the worst case chemical was employed in this OCA. The method involved calculating a hazard ratio (HR) defined as the total emission rate of the chemical divided by the chemical's toxic endpoint. Thus, the chemical with the largest emission rate and the smallest toxic endpoint will have the greatest hazard ratio. The liquid and solid chemicals with the greatest hazard ratios were carried through the air dispersion modeling phase.

⎟⎠⎞⎜

⎝⎛

⎟⎠⎞⎜

⎝⎛

=⎟⎟⎠

⎞⎜⎜⎝

⎛

3

3 secsec

mgTE

gERmHR

Where, ER = emission rate (g/sec) calculated by multiplying emission flux by the surface

area of the spill TE = toxic endpoint (g/m3) reported in either Table 3 of the CALARP regulations

or Appendix B of the CALARP guidance. The calculations, parameters, and equation references are summarized in Tables 3 thru 7. The U.S. EPA SCREEN3 model inputs are limited to emission rate (and area of the spill in the case of area sources, or the initial height and width of the plume in the case of volume sources), height of release, wind speed, anemometer height, and stability class. In this worst case OCA, the height of release was set at 0 meters, wind speed was set at 1.5 m/sec, anemometer height was set at 10 meters, and stability class was specified at F. Initial model runs were made at 10 meter intervals until the toxic endpoint concentration was bounded between two 10 meter intervals. Once bounded, additional distances (if necessary) were trial and errored until the distance to toxic endpoint was established within one meter. Releases that were assumed to occur outdoors were modeled as area sources with the area established as the area of the spill. Releases that were assumed to occur inside the warehouse were modeled as volume sources with the initial height of the plume established at the height of the warehouse door, and the initial width of the plume established as the width of the warehouse door. A summary of the model inputs and results of the SCREEN3 modeling are described in Tables 8 thru 15. The SCREEN3

ATTACHMENT D - 9

model runs and figures depicting distance to toxic endpoint (for distances greater than 0 ft) are provided in Tab 2 to this attachment. The results of the analysis show that the maximum worst case distance to toxic endpoint is 108.3 feet for an outdoor spill of liquid pesticide. This distance does not exceed the facility boundary. Therefore, no public or environmental receptors are affected. However, it should be noted that the distance to toxic endpoint is 1,519 feet for solid chemicals when the vapor emissions of the solid chemical are estimated with procedures used to estimate vapor emissions from liquid chemicals. As reported earlier, the uncertainty of using a procedure established for chemicals in liquid form on chemicals in solid form precludes the reporting of this information in the formal results. Additionally, Section 2750.3 states that “In performing an offsite consequence analysis for solids that are listed in Section 2770.5 Table 3, an owner or operator may use a USEPA, California Air Resources Board, or OES approved model which appropriately considers the dispersion and settling of particles.” Since such a procedure was used, the OCA adequately complies with the requirements of the CALARP regulation.

3.6 Alternative Case OCA

The alternative case OCA was performed in the same manner as the worst case OCA except that the quantity used in the analysis was the quantity in a single container. The results of the alternative OCA show that emissions are not significant enough to exceed the toxic endpoint concentration. Therefore, no public or environmental receptors are affected. The results of the alternative OCA are included in the same tables referenced above.

4.0 Conclusion The results of the OCA show that only anhydrous ammonia in its worst case quantity has the potential for offsite consequences. The worst case distance to toxic endpoint is 4.43 miles. It should be noted that the toxic endpoint chosen to be evaluated by U.S. EPA and the State of California is based on the Emergency Response Planning Guideline Level 2 (ERPG-2). This concentration is the maximum concentration in air below which it is believed nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms that could impair their abilities to take protective action. The distance to the Acute Exposure Guideline Level 3 (AEGL-3) for the worst case OCA is 1.16 miles. The AGEL-3 is the airborne concentration (expressed as ppm or mg/m3) of a substance above which it is predicted that the general population, including susceptible individuals, could experience life-threatening health effects or death. Therefore, the prevention of accidents associated with storing and handling ammonia are important. The facility has had no accidents resulting in offsite impacts since Helena’s operation of the facility.

TABLES, CALCULATIONS, AND REFERENCES

BLYTHE, OCAANNHYDROUS AMMONIA

Units

Container Type

Anhydrous Ammonia

Ammonia (30,000 gal

Railcar)7664-41-7 25500 gal - Tank 5.69 99.70% 144660 14466 110

Emission Rate (lb/min)1

Emission Rate

(kg/s)2Constant

Hose/Pipe Diameter3 (ft) Area4 (ft2) F5 HL

6 Vlg6 T7 Constant Cpl

6

3-inch line 224.90 1.70 9490 0.250 0.04908739 0.85 589.4 42.51 121 460 1.02562-inch line 99.96 0.76 9490 0.167 0.02181662 0.85 589.4 42.51 121 460 1.0256

1.5-inch line 56.23 0.43 9490 0.125 0.01227185 0.85 589.4 42.51 121 460 1.0256

4. Pi/4 * diameter^2.5. Selected Based on hose/pipe length of 10 feet and recommendations in RMP guidance.6. Based standard properties of ammonia.7. Based on maximum temperature over 3 year period.

ATT D - TABLE 1: WORST CASE OCA FOR GASES LIQUIFIED UNDER PRESSURE

Trade Name Regulated Chemical Name

CAS Number

Product Quantity

Density (lb/gal)

Percent Active

Ingredient

Regulated Chemical

Quantity (lb)

10-Min Emission

Rate (lb/min)

10-Min Emission

Rate (kg/sec)

ATT D - TABLE 2: ALTERNATIVE CONSEQUENCE OCA FOR GASES LIQUIFIED UNDER PRESSURE

1. Based on Equ. A6 in Appendix 4A of the Risk Management Program Guidance for Chemical Distributors (May 2000), ER (lb/min) = 9490 x a x F x hL/[Vlg([T+460]Cpl)1/2]. Release considered to occur for 2 minutes.2. ER (lb/min) * kg / 2.2 lb * min / 60 sec.3. Diameter (in.) / 12.

BYLTHE, CALIQUID PESTICIDES

Units

Container Type

Furadan 4F Carbofuran 1563-66-2 2.5 gal - plastic jug 9.32 44.0% 10.25 221.00 1.95E-08 1.10E-03 1.77E-03 2.36E-04 0.05198 9464.1 109.77 7.95 322.4 1.35E-09 1.28E-05 4650.3 101,288 4.3E-04 2.97E-02Dimethoate 267 Dimethoate 60-51-5 2.5 gal - plastic jug 8.59 30.5% 6.55 229.00 1.11E-07 1.10E-03 9.77E-03 1.30E-03 0.05076 9464.1 109.77 7.95 322.4 7.61E-09 7.20E-05 2971.1 11,460 3.0E-02 2.40E-03Dimethoate 4EC Dimethoate 60-51-5 2.5 gal - plastic jug 8.90 43.5% 9.68 229.00 1.11E-07 1.10E-03 9.77E-03 1.30E-03 0.05076 9464.1 109.77 7.95 322.4 7.61E-09 7.20E-05 4390.3 16,934 3.0E-02 2.40E-03Di-Syston 8E Disulfoton 298-04-4 2.5 gal - plastic jug 9.34 85.0% 19.85 274.00 6.92E-07 1.10E-03 5.08E-02 6.77E-03 0.00100 9464.1 109.77 7.95 322.4 6.65E-09 6.29E-05 9003.6 39,767 2.0E-03 3.14E-02Thionex 3EC Endosulfan 115-29-7 2.5 gal - plastic jug 8.82 33.7% 7.43 407.00 6.54E-08 1.10E-03 3.23E-03 4.31E-04 0.00100 9464.1 109.77 7.95 322.4 6.28E-10 5.94E-06 3370.6 157,610 8.0E-04 7.43E-03Lannate LV Methomyl 16752-77-5 2.5 gal - plastic jug 8.52 29.0% 6.17 162.00 2.27E-08 1.10E-03 2.81E-03 3.75E-04 0.06394 9464.1 109.77 7.95 322.4 1.74E-09 1.65E-05 2800.3 47,237 1.0E-02 1.65E-03Vydate C-LV Oxamyl 23135-22-0 2.5 gal - plastic jug 9.02 42.0% 9.48 219.00 1.30E-06 1.10E-03 1.20E-01 1.60E-02 0.05229 9464.1 109.77 7.95 322.4 9.06E-08 8.58E-04 4297.9 1,392 1.7E-03 5.04E-01Vydate L Oxamyl 23135-22-0 2.5 gal - plastic jug 8.19 24.0% 4.91 219.00 1.30E-06 1.10E-03 1.20E-01 1.60E-02 0.05229 9464.1 109.77 7.95 322.4 9.06E-08 8.58E-04 2229.0 722 1.7E-03 5.04E-01Firestorm Paraquat Dichloride 1910-42-5 2.5 gal - plastic jug 9.39 43.8% 10.28 257.00 4.99E-10 1.10E-03 3.91E-05 5.21E-06 0.04700 9464.1 109.77 7.95 322.4 3.29E-11 3.11E-07 4664.4 4,164,758 1.0E-04 3.11E-03Gramoxone Inteon Paraquat Dichloride 1910-42-5 2.5 gal - plastic jug 9.35 30.1% 7.04 257.00 4.99E-10 1.10E-03 3.91E-05 5.21E-06 0.04700 9464.1 109.77 7.95 322.4 3.29E-11 3.11E-07 3191.5 2,849,636 1.0E-04 3.11E-03

Furadan 4F Carbofuran 1563-66-2 200 gal - total quantity 9.32 44.0% 820.16 221.00 1.95E-08 1.10E-03 1.77E-03 2.36E-04 0.05198 757127.8 981.84 7.95 322.4 4.51E-10 3.41E-04 372024.6 302,920 4.3E-04 7.93E-01Dimethoate 267 Dimethoate 60-51-5 180 gal - total quantity 8.59 30.5% 471.60 229.00 1.11E-07 1.10E-03 9.77E-03 1.30E-03 0.05076 681415.0 931.45 7.95 322.4 2.61E-09 1.78E-03 213918.7 33,382 3.0E-02 5.93E-02Dimethoate 4EC Dimethoate 60-51-5 720 gal - total quantity 8.90 43.5% 2787.48 229.00 1.11E-07 1.10E-03 9.77E-03 1.30E-03 0.05076 2725660.0 1862.91 7.95 322.4 1.85E-09 5.03E-03 1264400.9 69,758 3.0E-02 1.68E-01Di-Syston 8E Disulfoton 298-04-4 200 gal - total quantity 9.34 85.0% 1587.94 274.00 6.92E-07 1.10E-03 5.08E-02 6.77E-03 0.00100 757127.8 981.84 7.95 322.4 2.22E-09 1.68E-03 720287.8 118,930 2.0E-03 8.41E-01Thionex 3EC Endosulfan 115-29-7 200 gal - total quantity 8.82 33.7% 594.47 407.00 6.54E-08 1.10E-03 3.23E-03 4.31E-04 0.00100 757127.8 981.84 7.95 322.4 2.10E-10 1.59E-04 269650.7 471,364 8.0E-04 1.99E-01Lannate LV Methomyl 16752-77-5 180 gal - total quantity 8.52 29.0% 444.49 162.00 2.27E-08 1.10E-03 2.81E-03 3.75E-04 0.06394 681415.0 931.45 7.95 322.4 5.97E-10 4.07E-04 201620.8 137,599 1.0E-02 4.07E-02Vydate C-LV Oxamyl 23135-22-0 200 gal - total quantity 9.02 42.0% 758.01 219.00 1.30E-06 1.10E-03 1.20E-01 1.60E-02 0.05229 757127.8 981.84 7.95 322.4 3.03E-08 2.29E-02 343831.5 4,164 1.7E-03 1.35E+01Vydate L Oxamyl 23135-22-0 120 gal - total quantity 8.19 24.0% 235.87 219.00 1.30E-06 1.10E-03 1.20E-01 1.60E-02 0.05229 454276.7 760.53 7.95 322.4 3.44E-08 1.56E-02 106991.5 1,901 1.7E-03 9.20E+00Firestorm Paraquat Dichloride 1910-42-5 200 gal - total quantity 9.39 43.8% 822.64 257.00 4.99E-10 1.10E-03 3.91E-05 5.21E-06 0.04700 757127.8 981.84 7.95 322.4 1.10E-11 8.32E-06 373148.4 12,455,533 1.0E-04 8.32E-02Gramoxone Inteon Paraquat Dichloride 1910-42-5 200 gal - total quantity 9.35 30.1% 562.87 257.00 4.99E-10 1.10E-03 3.91E-05 5.21E-06 0.04700 757127.8 981.84 7.95 322.4 1.10E-11 8.32E-06 255317.8 8,522,399 1.0E-04 8.32E-02

ATTACHMENT D - TABLE 3: CALCULATION OF EMISSION RATES AND SELECTION OF MOST DANGEROUS CHEMICAL FOR PURPOSES OF OCA (OUTDOOR SPILL)


CAS Number

Product Quantity

Density1

(lb/gal)

Percent Active

Ingredient1

Regulated Chemical

Quantity2 (lb)

Molecular Wt. (g/mol)

Vapor Density @ T

(g/cm3) 3

Length of Puddle7

(cm)

Velocity Parallel to Surface8

(cm/sec)

Temperature9

(K)

Vapor Density Air @ T (g/cm3)

Available Vapor

Pressure4

(mmHg)

Available Vapor

Pressure (kPa)

Diffusity in Air5

(cm2/s)

Toxic Endpint14

(g/m3)

Haz Factor

(ER/TE)

LIQUID @ Ambient T and P, Quanity on Single Pallet

1. From MSDS.

LIQUID @ Ambient T and P, Quanity in Single Container

Vapor Flux10

(g/cm2/sec)

Emission Rate11

(g/sec)

Total Mass Spilled12

(g)

Duration of Release13

(hr)

Surface Area of Spill (cm2) 6

2. Product Qty. (gal) x Density (lb/gal) x Percent Active Ingredient.3. n * M.W./V = P/ RT; P = Vapor Pressure of Pure Chemical, T = 322 K (121 F).4. From MSDS if value in MSDS given as pure chemical, otherwise vapor pressure taken from Hazardous Substances Data Bank (http://toxnet.nlm.nih.gov/cgi-bin/sis/htmlgen?HSDB). The stated vapor pressures from the literature resources were multiplied by a factor of 532 since the vapor pressures stated are at 20 to 25 degree C and maximum temperature used in analysis is 49.4 degree C. It is assumed that vapor pressure increases 17.73 mmHg for every increase in temperature above 20 degree C following a curve similar for that of Pentane. This results in a factor of 521 and is considered a conservative factor based on typical vapor pressure curves.

5. Except for Disulfoton and Endosulfan, Diffusivity calculated as Da = 1.9/(M.W.)^(2/3) based on the U.S. EPA Human Health Risk Assessment Protocol for Hazardous Waste Combustion Facilities. Values Disulfoton and Endosulfan were taken from the U.S. EPA AIR EMISSIONS MODELS FOR WASTE AND WASTEWATER (1994).6. Calculated as Product Quantity (gal) / 7.28 gal/ft3 / 35.315 ft3/m3 * (100^3 cm3/m3) / 1 cm depth.7. Calculated as (Surface Area (cm2) * 4 / PI)^0.58. Surface Friction Velocity for 10 m Wind Speed of 1.5 m/sec (from CALARP OCA requirements) calculated as u* = 0.053 * U10. Based on Equation 3-5, Cowherd, C.P. et. al. Hazardous Waste TSDF Fugitive Particulate Matter Air Emissions Guidance Document (May 1989).

9. Maximum recorded temperature from NCDC data (2005 - 2007) for Blythe, CA.10. Calculated as G (g/cm2/sec) = [2 * M.W. * Vapor Pressure (kPA) / (8.314E3 kPA/cm3 - K * Temp. (K))] * [(Diffusivity in Air (cm2/sec) * Air Velocity Above Pool (cm/sec) / PI * Length of Puddle (cm)]^0.5. Based on OPPT "Models to Calculate the Rate of Evaporation of Pure LIquids from Open Surfaces", May 2003; The Penetration Model.

11. Calculated as Vapor Flux * Surface Area.12. Calculated as Product Quantity (gal) * Density (lb/gal) * 453.6 gram/lb.13. Calculated as Total Mass Spilled (gram) / Emission Rate (gram/sec).14. Taken from Table 3 of CALARP regulations.15. Calculated as Emission Rate / Toxic Endpoint. This factor represents the chemical with the highest emissions relative to the lowest toxic endpoint and is the most dangerous in the event of an accident.

BYLTHE, CALIQUID PESTICIDES

Units

Container Type

Furadan 4F Carbofuran 1563-66-2 2.5 gal - plastic jug 9.32 44.0% 10.25 221.00 1.95E-08 1.10E-03 1.77E-03 2.36E-04 0.05198 9464.1 109.77 35 322.4 2.83E-09 2.68E-05 4650.3 48,273 4.3E-04 6.22E-02Dimethoate 267 Dimethoate 60-51-5 2.5 gal - plastic jug 8.59 30.5% 6.55 229.00 1.11E-07 1.10E-03 9.77E-03 1.30E-03 0.05076 9464.1 109.77 35 322.4 1.60E-08 1.51E-04 2971.1 5,462 3.0E-02 5.04E-03Dimethoate 4EC Dimethoate 60-51-5 2.5 gal - plastic jug 8.90 43.5% 9.68 229.00 1.11E-07 1.10E-03 9.77E-03 1.30E-03 0.05076 9464.1 109.77 35 322.4 1.60E-08 1.51E-04 4390.3 8,070 3.0E-02 5.04E-03Di-Syston 8E Disulfoton 298-04-4 2.5 gal - plastic jug 9.34 85.0% 19.85 274.00 6.92E-07 1.10E-03 5.08E-02 6.77E-03 0.00100 9464.1 109.77 35 322.4 1.39E-08 1.32E-04 9003.6 18,953 2.0E-03 6.60E-02Thionex 3EC Endosulfan 115-29-7 2.5 gal - plastic jug 8.82 33.7% 7.43 407.00 6.54E-08 1.10E-03 3.23E-03 4.31E-04 0.00100 9464.1 109.77 35 322.4 1.32E-09 1.25E-05 3370.6 75,116 8.0E-04 1.56E-02Lannate LV Methomyl 16752-77-5 2.5 gal - plastic jug 8.52 29.0% 6.17 162.00 2.27E-08 1.10E-03 2.81E-03 3.75E-04 0.06394 9464.1 109.77 35 322.4 3.65E-09 3.46E-05 2800.3 22,513 1.0E-02 3.46E-03Vydate C-LV Oxamyl 23135-22-0 2.5 gal - plastic jug 9.02 42.0% 9.48 219.00 1.30E-06 1.10E-03 1.20E-01 1.60E-02 0.05229 9464.1 109.77 35 322.4 1.90E-07 1.80E-03 4297.9 664 1.7E-03 1.06E+00Vydate L Oxamyl 23135-22-0 2.5 gal - plastic jug 8.19 24.0% 4.91 219.00 1.30E-06 1.10E-03 1.20E-01 1.60E-02 0.05229 9464.1 109.77 35 322.4 1.90E-07 1.80E-03 2229.0 344 1.7E-03 1.06E+00Firestorm Paraquat Dichloride 1910-42-5 2.5 gal - plastic jug 9.39 43.8% 10.28 257.00 4.99E-10 1.10E-03 3.91E-05 5.21E-06 0.04700 9464.1 109.77 35 322.4 6.90E-11 6.53E-07 4664.4 1,984,903 1.0E-04 6.53E-03Gramoxone Inteon Paraquat Dichloride 1910-42-5 2.5 gal - plastic jug 9.35 30.1% 7.04 257.00 4.99E-10 1.10E-03 3.91E-05 5.21E-06 0.04700 9464.1 109.77 35 322.4 6.90E-11 6.53E-07 3191.5 1,358,122 1.0E-04 6.53E-03

Furadan 4F Carbofuran 1563-66-2 200 gal - total quantity 9.32 44.0% 820.16 221.00 1.95E-08 1.10E-03 1.77E-03 2.36E-04 0.05198 757127.8 981.84 35 322.4 9.45E-10 7.16E-04 372024.6 144,370 4.3E-04 1.66E+00Dimethoate 267 Dimethoate 60-51-5 180 gal - total quantity 8.59 30.5% 471.60 229.00 1.11E-07 1.10E-03 9.77E-03 1.30E-03 0.05076 681415.0 931.45 35 322.4 5.48E-09 3.74E-03 213918.7 15,909 3.0E-02 1.25E-01Dimethoate 4EC Dimethoate 60-51-5 720 gal - total quantity 8.90 43.5% 2787.48 229.00 1.11E-07 1.10E-03 9.77E-03 1.30E-03 0.05076 2725660.0 1862.91 35 322.4 3.88E-09 1.06E-02 1264400.9 33,247 3.0E-02 3.52E-01Di-Syston 8E Disulfoton 298-04-4 200 gal - total quantity 9.34 85.0% 1587.94 274.00 6.92E-07 1.10E-03 5.08E-02 6.77E-03 0.00100 757127.8 981.84 35 322.4 4.66E-09 3.53E-03 720287.8 56,681 2.0E-03 1.76E+00Thionex 3EC Endosulfan 115-29-7 200 gal - total quantity 8.82 33.7% 594.47 407.00 6.54E-08 1.10E-03 3.23E-03 4.31E-04 0.00100 757127.8 981.84 35 322.4 4.40E-10 3.33E-04 269650.7 224,650 8.0E-04 4.17E-01Lannate LV Methomyl 16752-77-5 180 gal - total quantity 8.52 29.0% 444.49 162.00 2.27E-08 1.10E-03 2.81E-03 3.75E-04 0.06394 681415.0 931.45 35 322.4 1.25E-09 8.54E-04 201620.8 65,579 1.0E-02 8.54E-02Vydate C-LV Oxamyl 23135-22-0 200 gal - total quantity 9.02 42.0% 758.01 219.00 1.30E-06 1.10E-03 1.20E-01 1.60E-02 0.05229 757127.8 981.84 35 322.4 6.36E-08 4.81E-02 343831.5 1,984 1.7E-03 2.83E+01Vydate L Oxamyl 23135-22-0 120 gal - total quantity 8.19 24.0% 235.87 219.00 1.30E-06 1.10E-03 1.20E-01 1.60E-02 0.05229 454276.7 760.53 35 322.4 7.22E-08 3.28E-02 106991.5 906 1.7E-03 1.93E+01Firestorm Paraquat Dichloride 1910-42-5 200 gal - total quantity 9.39 43.8% 822.64 257.00 4.99E-10 1.10E-03 3.91E-05 5.21E-06 0.04700 757127.8 981.84 35 322.4 2.31E-11 1.75E-05 373148.4 5,936,245 1.0E-04 1.75E-01Gramoxone Inteon Paraquat Dichloride 1910-42-5 200 gal - total quantity 9.35 30.1% 562.87 257.00 4.99E-10 1.10E-03 3.91E-05 5.21E-06 0.04700 757127.8 981.84 35 322.4 2.31E-11 1.75E-05 255317.8 4,061,733 1.0E-04 1.75E-01

ATTACHMENT D - TABLE 4: CALCULATION OF EMISSION RATES AND SELECTION OF MOST DANGEROUS CHEMICAL FOR PURPOSES OF OCA (WAREHOUSE SPILL)

Trade NameRegulated Chemical

NameCAS

NumberProduct Quantity

Density1

(lb/gal)

Percent Active

Ingredient1

Regulated Chemical

Quantity2 (lb)


Vapor Density @ T

(g/cm3) 3


Available Vapor

Pressure4

(mmHg)

Available Vapor

Pressure (kPa)

Diffusity in Air5

(cm2/s)

Surface Area of Spill (cm2) 6

Length of Puddle7

(cm)

2. Product Qty. (gal) x Density (lb/gal) x Percent Active Ingredient.3. n * M.W./V = P/ RT; P = Vapor Pressure of Pure Chemical, T = 322 K (121 F).

Total Mass Spilled12

(g)


(hr)

Toxic Endpint14

(g/m3)

Haz Factor

(ER/TE)


(cm/sec)

Temperature9

(K)Vapor Flux10

(g/cm2/sec)

Emission Rate11

(g/sec)

15. Calculated as Emission Rate / Toxic Endpoint. This factor represents the chemical with the highest emissions relative to the lowest toxic endpoint and is the most dangerous in the event of an accident.

8. Mean Indoor Surface Wind Speed reported by Baldwin et. al. in A Survey of Wind Speeds in Indoor Workplaces, Annals of Occupational Hygiene, Vol. 42, No. 5, pp. 303 - 313. 9. Maximum recorded temperature from NCDC data (2005 - 2007) for Blythe, CA.10. Calculated as G (g/cm2/sec) = [2 * M.W. * Vapor Pressure (kPA) / (8.314E3 kPA/cm3 - K * Temp. (K))] * [(Diffusivity in Air (cm2/sec) * Air Velocity Above Pool (cm/sec) / PI * Length of Puddle (cm)]^0.5. Based on OPPT "Models to Calculate the Rate of Evaporation of Pure LIquids from Open Surfaces", May 2003; The Penetration Model.11. Calculated as Vapor Flux * Surface Area.

LIQUID @ Ambient T and P, Quanity in Single Container

12. Calculated as Product Quantity (gal) * Density (lb/gal) * 453.6 gram/lb.13. Calculated as Total Mass Spilled (gram) / Emission Rate (gram/sec).14. Taken from Table 3 of CALARP regulations.

4. From MSDS if value in MSDS given as pure chemical, otherwise vapor pressure taken from Hazardous Substances Data Bank (http://toxnet.nlm.nih.gov/cgi-bin/sis/htmlgen?HSDB). The stated vapor pressures from the literature resources were multiplied by a factor of 532 since the vapor pressures stated are at 20 to 25 degree C and maximum temperature used in analysis is 49.4 degree C. It is assumed that vapor pressure increases 17.73 mmHg for every increase in temperature above 20 degree C following a curve similar for that of Pentane. This results in a factor of 521 and is considered a conservative factor based on typical vapor pressure curves.5. Except for Disulfoton and Endosulfan, Diffusivity calculated as Da = 1.9/(M.W.)^(2/3) based on the U.S. EPA Human Health Risk Assessment Protocol for Hazardous Waste Combustion Facilities. Values Disulfoton and Endosulfan were taken from the U.S. EPA AIR EMISSIONS MODELS FOR WASTE AND WASTEWATER (1994).6. Calculated as Product Quantity (gal) / 7.28 gal/ft3 / 35.315 ft3/m3 * (100^3 cm3/m3) / 1 cm depth.7. Calculated as (Surface Area (cm2) * 4 / PI)^0.5

LIQUID @ Ambient T and P, Quanity on Single Pallet

1. From MSDS.

BLYTHE, CASOLID PESTICIDES

Units

Container Type

Temik 15G Aldicarb 116-06-3 45 lbs in "Lock & Load" 15.00% 6.75 190.30 Granule 174 - 207 190 31 7.95 NoLannate SP Methomyl 16752-77-5 10 lb bags 90.00% 9.00 162.00 Granule 174 - 207 190 31 7.95 NoThimet 20G Phorate 298-02-2 40 lbs in "Lock & Load" 20.00% 8.00 260.00 Granule 174 - 207 190 31 7.95 No

Temik 15G Aldicarb 116-06-3 21,645 lbs in "Lock & Load" 15.00% 3246.75 190.30 Granule 174 - 207 190 31 7.95 NoLannate SP Methomyl 16752-77-5 1,000 lb bags 90.00% 900.00 162.00 Granule 174 - 207 190 31 7.95 NoThimet 20G Phorate 298-02-2 6500 lbs in "Lock & Load" 20.00% 1300.00 260.00 Granule 174 - 207 190 31 7.95 No

Units

Container Type

Temik 15G Aldicarb 116-06-3 45 lbs in "Lock & Load" 15.00% 6.75 190.30 Granule 174 - 207 190 31 35 Yes 932 2.96E-005 4.43E-006 2.28 1.01E-005 3.0E-04 0.03Lannate SP Methomyl 16752-77-5 10 lb bags 90.00% 9.00 162.00 Granule 174 - 207 190 31 35 Yes 932 2.96E-005 2.66E-005 0.75 1.99E-005 1.0E-02 0.002Thimet 20G Phorate 298-02-2 40 lbs in "Lock & Load" 20.00% 8.00 260.00 Granule 174 - 207 190 31 35 Yes 932 2.96E-005 5.91E-006 2.03 1.20E-005 1.0E-04 0.12

Temik 15G Aldicarb 116-06-3 21645.00 lbs in "Lock & Load" 15.00% 3246.75 190.30 Granule 174 - 207 190 31 35 Yes 932 2.96E-005 4.43E-006 1096.84 4.86E-003 3.0E-04 16.21Lannate SP Methomyl 16752-77-5 1000.00 lb bags 90.00% 900.00 162.00 Granule 174 - 207 190 31 35 Yes 932 2.96E-005 2.66E-005 74.67 1.99E-003 1.0E-02 0.20Thimet 20G Phorate 298-02-2 6500.00 lbs in "Lock & Load" 20.00% 1300.00 260.00 Granule 174 - 207 190 31 35 Yes 932 2.96E-005 5.91E-006 329.34 1.95E-003 1.0E-04 19.47

ATTACHMENT D - TABLE 5: EVALUATION OF PARTICULATE EMISSIONS FROM SOLID PESTICIDES (SPILLED OUTDOORS)


CAS Number

Product Quantity

Percent Active

Ingredient1

Regulated Chemical

Quantity2 (lb)


Type of Particle1

Typical Granule

Size Range3

(um)

Size Selected for Evaluation

(um)

Threshold Friction Velocity4

(cm/sec)

Friction Velocity of

Wind Speed = 1.5 m/sec5

(cm/sec)

Wind Speed Sufficient to

Make Particle Airborne?

1. Taken from MSDS.2. Product Quantity * Percent Active Ingredient.3. Taken from Pesticide Formulations and Application Systems: Seventh Volume : a Symposium Sponsored by ASTM Committee E-35 on Pesticides, Phoenix, Ariz., 5-6 Nov. 1986.4. 190 um is the midpoint of the size range and was used to obtain the Threshold Friction Velocity from Figure 3-3, Relationship of Threshold Friction Velocity to Size Distribution Mode, "Hazardous Waste TSDF Fugitive Particulate Matter Air Emissions Guidance Document" (1989).5. Equation 3-5, Cowherd, C.P. et. al. Hazardous Waste TSDF Fugitive Particulate Matter Air Emissions Guidance Document (May 1989), u* = 0.053 * (150 cm/sec).

Trade NameRegulated

Chemical NameCAS

NumberProduct Quantity

Percent Active

Ingredient1

Regulated Chemical

Quantity2 (lb)


Type of Particle1

Typical Granule

Size Range3

(um)

Surface Wind Velocity5

(cm/sec)

Wind Speed Sufficient to

Make Particle Airborne?

Particulate Emission Flux6

(g/m2/yr)

Particulate Emission

Flux7

(g/m2/sec)

Haz Factor12

(ER/TE)

1. Taken from MSDS.2. Product Quantity * Percent Active Ingredient.3. Taken from Pesticide Formulations and Application Systems: Seventh Volume : a Symposium Sponsored by ASTM Committee E-35 on Pesticides, Phoenix, Ariz., 5-6 Nov. 1986.

Active Ingredient Emission

Flux8

(g/m2/sec)

Surface Area of Spill9 (m2)

Emission Rate10

(g/sec)

Size Selected for Evaluation

(um)

Threshold Friction Velocity4

(cm/sec)

Toxic Endpint11

(g/m3)

7. Particulate Emission Rate (g/m2/yr) * 1/365 days * 1/24 hours * 1/3600 seconds.8. Particulate Emission Rate (g/m2/sec) * Percent Active Ingredient.9. Calculated as Product Quantity (lbl) / 2.2 lb/kg / Bulk Density (kg/m3) * (100^3 cm3/m3) / 1 cm depth. Bulk density is reported in Table X below.

4. 190 um is the midpoint of the size range and was used to obtain the Threshold Friction Velocity from Figure 3-3, Relationship of Threshold Friction Velocity to Size Distribution Mode, "Hazardous Waste TSDF Fugitive Particulate Matter Air Emissions Guidance Document" (1989).5. Mean Indoor Surface Wind Speed reported by Baldwin et. al. in A Survey of Wind Speeds in Indoor Workplaces, Annals of Occupational Hygiene, Vol. 42, No. 5, pp. 303 - 313. 6. Equations 3-3 and 3-4; Cowherd, C.P. et. al. Hazardous Waste TSDF Fugitive Particulate Matter Air Emissions Guidance Document (May 1989), EF = 1 * P; P = 58 * (FV - Threshold FV)^2 + (FV - Threshold FV).

12. Calculated as Emission Rate / Toxic Endpoint. This factor represents the chemical with the highest emissions relative to the lowest toxic endpoint and is the most dangerous in the event of an accident.

SOLID @ Ambient T and P, Quantity in Single Container

SOLID @ Ambient T and P, Quantity on Single Pallet

ATTACHMENT D - TABLE 6: EVALUATION OF PARTICULATE EMISSIONS FROM SOLID PESTICIDES (SPILLED INDOORS)



10. Calculated as Vapor Flux * Surface Area.11. Taken from Table 3 of CALARP regulations.

BLYTHE, CASOLID PESTICIDES

Units

Container Type

Temik 15G Aldicarb 116-06-3 45 lbs in "Lock & Load" 15.00% 6.75 190.30 897 4.81E-07 1.10E-03 5.08E-02 6.77E-03 0.05743 22803.3 170.39 35 322.4 5.89E-08 1.34E-03 3061.8 95 3.0E-04 4.48E+00Lannate SP Methomyl 16752-77-5 10 lb bags 90.00% 9.00 162.00 608.7 2.27E-08 1.10E-03 2.81E-03 3.75E-04 0.06394 7467.5 97.51 35 322.4 3.87E-09 2.89E-05 4082.4 35,283 1.0E-02 2.89E-03Thimet 20G Phorate 298-02-2 40 lbs in "Lock & Load" 20.00% 8.00 260.00 897.1 9.43E-07 1.10E-03 7.29E-02 9.72E-03 0.04664 20267.3 160.64 35 322.4 1.07E-07 2.17E-03 3628.8 93 1.0E-04 2.17E+01

Temik 15G Aldicarb 116-06-3 21,645 lbs in "Lock & Load" 15.00% 3246.75 190.30 897 4.81E-07 1.10E-03 5.08E-02 6.77E-03 0.05743 1.10E+007 3737.03 35 322.4 1.26E-08 1.38E-01 1472725.8 445 3.0E-04 4.60E+02Lannate SP Methomyl 16752-77-5 1,000 lb bags 90.00% 900.00 162.00 608.7 2.27E-08 1.10E-03 2.81E-03 3.75E-04 0.06394 746747.9 975.08 35 322.4 1.22E-09 9.15E-04 408240.0 111,574 1.0E-02 9.15E-02Thimet 20G Phorate 298-02-2 6500 lbs in "Lock & Load" 20.00% 1300.00 260.00 897.1 9.43E-07 1.10E-03 7.29E-02 9.72E-03 0.04664 3293440.5 2047.76 35 322.4 3.00E-08 9.89E-02 589680.0 331 1.0E-04 9.89E+02

Notes:


(hr)

Toxic Endpint14

(g/m3)

Haz Factor15

(ER/TE)

Available Vapor

Pressure4

(mmHg)

Available Vapor

Pressure (kPa)

Percent Active

Ingredient1

Regulated Chemical

Quantity2 (lb)


Bulk Density (kg/m3)1

FOR PURPOSES OF OCA ONLY, THE EVAPORATION OF REGULATED CHEMICALS FROM SOLID GRANULES WAS ASSUMED TO BEHAVE AS EVAPORATION FROM A LIQUID. THIS IS A HIGHLY CONSERVATIVE ASSUMPTION.

Temperature9

(K)Vapor Flux10

(g/cm2/sec)

Emission Rate11

(g/sec)

Total Mass

Spilled12

(g)

Diffusity in Air5 (cm2/s)

Surface Area of Spill6 (cm2)



14. Taken from Table 3 of CALARP regulations.15. Calculated as Emission Rate / Toxic Endpoint. This factor represents the chemical with the highest emissions relative to the lowest toxic endpoint and is the most dangerous in the event of an accident.

9. Maximum recorded temperature from NCDC data (2005 - 2007) for Blythe, CA.

10. Calculated as G (g/cm2/sec) = [2 * M.W. * Vapor Pressure (kPA) / (8.314E3 kPA/cm3 - K * Temp. (K))] * [(Diffusivity in Air (cm2/sec) * Air Velocity Above Pool (cm/sec) / PI * Length of Puddle (cm)]^0.5. Based on OPPT "Models to Calculate the Rate of Evaporation of Pure LIquids from Open Surfaces", May 2003; The Penetration Model.

11. Calculated as Vapor Flux * Surface Area.12. Calculated as Product Quantity (lb) * 453.6 gram/lb.

5. Diffusivity calculated as Da = 1.9/(M.W.)^(2/3) based on the U.S. EPA Human Health Risk Assessment Protocol for Hazardous Waste Combustion Facilities.6. Calculated as Product Quantity (lbl) / 2.2 lb/kg / Bulk Density (kg/m3) * (100^3 cm3/m3) / 1 cm depth.

13. Calculated as Total Mass Spilled (gram) * % Active Ingredient / Emission Rate (gram/sec).

7. Calculated as (Surface Area (cm2) * 4 / PI)^0.58. Mean Indoor Surface Wind Speed reported by Baldwin et. al. in A Survey of Wind Speeds in Indoor Workplaces, Annals of Occupational Hygiene, Vol. 42, No. 5, pp. 303 - 313.

1. From MSDS. For Bulk Density, the reported loose density was assumed where available. No density was reported for Temik so the same density as Thimet 20G was used since both are "Lock and Load" applicators.2. Product Qty. (lb) x Percent Active Ingredient.3. n * M.W./V = P/ RT; P = Vapor Pressure of Pure Chemical, T = 322 K (121 F).

4. From MSDS if value in MSDS given as pure chemical, otherwise vapor pressure taken from Hazardous Substances Data Bank (http://toxnet.nlm.nih.gov/cgi-bin/sis/htmlgen?HSDB). The stated vapor pressures from the literature resources were multiplied by a factor of 521 since the vapor pressures stated are at 20 to 25 degree C and maximum temperature used in analysis is 49.4 degree C. It is assumed that vapor pressure increases 17.73 mmHg for every increase in temperature above 20 degree C following a curve similar for that of Pentane. This results in a factor of 521 and is considered a conservative factor based on typical vapor pressure curves.


Length of Pile7 (cm)


(cm/sec)

Vapor Density

@ T (g/cm3) 3


CAS Number

Product Quantity

ATTACHMENT D - TABLE 7: EVALUATION OF VAPOR EMISSIONS FROM SOLID PESTICIDES (SPILL INDOORS)

BLYTHE OCALIQUID PESTICIDE

PARAMETER VALUE UNITSEmission Rate 3.03E-04 g/m2/sSource Release Height 0 mLarger Side Length of Rectangular Area 9.82 mSmaller Side Length of Rectangular Area 7.71 mWind Direction Relative to Long Dimension 0 degrees

Stability Class FWind Speed 1.5 m/secBrode 2 Mixing Height NoAnemometer Height 10 m

Discrete Distances @ X meter Spacing 10 m

Maximum Concentration (Compare to 1700 ug/m3) 4,757 ug/m3

Distance to Endpoint 108 (33) ft (m)

PARAMETER VALUE UNITSEmission Rate 4.81E-02 g/sSource Release Height 0 mInitial Lateral Dimension (Width of Warehouse Door) 4.88 m (16 ft)Initial Vertical Dimension (Height of Warehouse Door) 3.66 m (12 ft)



Maximum Concentration (Compare to 1700 ug/m3) 455.5 ug/m3

Distance to Endpoint 0 ft

TABLE 8: SCREEN3 MODEL INPUTS FOR LIQUID PESTICIDES WORST CASE OUTDOOR SPILL MODELED AS AREA SOURCE

TABLE 9: SCREEN3 MODEL INPUTS FOR LIQUID PESTICIDES WORST CASE INDOOR SPILL MODELED AS VOLUME SOURCE

BLYTHE OCALIQUID PESTICIDE

PARAMETER VALUE UNITSEmission Rate 9.06E-04 g/m2/sSource Release Height 0 mLarger Side Length of Rectangular Area 1.10 mSmaller Side Length of Rectangular Area 0.86 mWind Direction Relative to Long Dimension 0 degrees










TABLE 10: SCREEN3 MODEL INPUTS FOR LIQUID PESTICIDES ALTERNATIVE CASE OUTDOOR SPILL MODELED AS AREA SOURCE

TABLE 11: SCREEN3 MODEL INPUTS FOR LIQUID PESTICIDES ALTERNATIVE CASE INDOOR SPILL MODELED AS VOLUME SOURCE

BLYTHE, CA OCASOLID PESTICIDE





Distance to Toxic Endpoint 1,519 (463) ft (m)





Distance to Toxic Endpoint 0 ft

TABLE 12: SCREEN3 MODEL INPUTS FOR SOLID PESTICIDES (VAPOR EMISSIONS) WORST CASE (INDOOR SPILL) MODELED AS VOLUME

SOURCE

TABLE 13: SCREEN3 MODEL INPUTS FOR SOLID PESTICIDES (VAPOR EMISSIONS) ALTERNATIVE CASE (INDOOR SPILL) MODELED AS VOLUME

SOURCE

BLYTHE, CA OCASOLID PESTICIDE











TABLE 14: SCREEN3 MODEL INPUTS FOR SOLID PESTICIDES PARTICULATE EMISSIONS (INDOOR SPILL) WORST CASE

TABLE 15: SCREEN3 MODEL INPUTS FOR SOLID PESTICIDES PARTICULATE EMISSIONS (INDOOR SPILL) ALTERNATIVE CASE

TAB 1 – ANHYDROUS AMMONIA MODELING RESULTS

============ SLAB REPORT ============

Run: 8/6/2008 6:34:04 PM Project File: C:\Documents and Settings\Weeks\My Documents\Blythe\NH4_WC.slb Generated By: SLAB View - Lakes Environmental Software

-------------------------------------------------------------- INPUT DATA --------------------------------------------------------------

SOURCE PARAMETERS

Source type Horizontal Jet X Coordinate: 0.00 m Y Coordinate: 0.00 m

CHEMICAL PROPERTIES

Chemical Name AMMONIA Molecular weight (WMS) 29 g/mole Vapor heat capacity (CPS) 2170 J/kg-K Boiling point temperature (TBP) 239.8 K Heat of vaporization (DHE) 1370840 J/kg Liquid heat capacity (CPSL) 4294 J/kg-K Liquid density (RHOSL) 682.8 kg/m**3 Saturation pressure constant (SPB) 2132.52 Saturation pressure constant (SPC) -32.98

SPILL PARAMETERS

Initial liquid mass fraction (CMEDO) 0.001 Temperature of the source material (TS) 239.8 K Mass source rate (QS) 110 kg/s Source Area (AS) 1.79114887934983 m**2 Continuous source duration (TSD) 600 s Instantaneous source mass (QTIS) 0 kg Source height (HS) 0.00 m

FIELD PARAMETERS

Concentration averaging time (TAV) 3600 s Maximum downwind distance (XFFM) 100000.00 m Height of concentration calculation (ZP(1)) 0.00 m Height of concentration calculation (ZP(2)) 0.00 m Height of concentration calculation (ZP(3)) 0.00 m Height of concentration calculation (ZP(4)) 0.00 m

METEOROLOGY PARAMETERS

MET CONDITION 1 Surface roughness height (ZO) 0.2 m Ambient measurement height (ZA) 10.00 Ambient wind speed (UA) 1.5 m/s Ambient temperature (TA) 322.4 K Relative humidity (RH) 50 % Stability class (STAB) 6 (F)

-------------------------------------------------------------- OUTPUT RESULTS --------------------------------------------------------------

FOOTPRINT - MET CONDITION 1

Concentration (ppm) Downwind Distance (m)

---------------------------------------------- 217.9 7127.41

CONFIDENTIAL.California

Nevada

Oregon Idaho

Data Source: Population Estimate - LandView 6Aerial - 2005 NAIP

Version: 080608_R1

RISK MANAGEMENT & ENGINEERING LTD.

WORST CASECONSEQUENCE ANALYSIS

FIGURE 1

POTENTIALLY EFFECTED POPULATION: 13,127

Blythe California Retail FacilityHELENA CHEMICAL COMPANY

!A

n

n

n

nn

nn

n

n

n

n

n

n

n

n

n

nn

n n

n

n

n

n

n

n

n

n

n

nn

n

n

n

n

n

n

n

n

n

n

n

n

n

n

n

n

nn

Ripley

Blythe East Blythe

Palo Verde College

-114.659096

-114.659096

-114.630893

-114.630893

-114.602690

-114.602690

-114.574487

-114.574487

-114.546284

-114.546284

33.53

1207

33.53

1207

33.56

1290

33.56

1290

33.59

1373

33.59

1373

33.62

1456

33.62

1456

33.65

1539

33.65

1539

Legendn School!A Source

Distance to Endpoint (Area: 61.7 mi.2 )

4.43 Miles7,127.4 Meters

LandView 6 Census 2000 Population Estimator Home Instructions for using this estimator

Enter Location and Radius

13,127Total population: 279count:Area within radius: 61.7

7,267White alone:1,116

197Black or African American alone:

American Indian and Alaska Native alone:Asian alone: 172

Two or more races: 580

Native Hawaiian and Other Pacific Islander alone: 29Some other race alone: 3,766

Hispanic or Latino: 5,977

Results (based on Census points located within or touching the circle defined by the radius)

sq. mi.

Clear all fields Print this screen Show this radiuson map

Refresh Lat/Longfrom MARPLOT

West EastNorth South

Latitude Longitude

33.591375 -114.602689

hemisphere

CalculatePopulation using

Block points

Decimaldegrees

deg-min-sec

or

5,006Housing Units:Block

Block

SummarizeDemographicProfiles usingBlock Group

points

Most accurate,but limited tothe race &ethnicity fieldsbelow

Less accurate,but provides moredemographicinformation4.43

Radius (miles)

| |v v

============ SLAB REPORT ============

Run: 8/6/2008 7:03:28 PM Project File: C:\Documents and Settings\Weeks\My Documents\Blythe\NH4_AC.slb Generated By: SLAB View - Lakes Environmental Software

-------------------------------------------------------------- INPUT DATA --------------------------------------------------------------

SOURCE PARAMETERS

Source type Horizontal Jet X Coordinate: 0.00 m Y Coordinate: 0.00 m

CHEMICAL PROPERTIES

Chemical Name AMMONIA Molecular weight (WMS) 29 g/mole Vapor heat capacity (CPS) 2170 J/kg-K Boiling point temperature (TBP) 239.8 K Heat of vaporization (DHE) 1370840 J/kg Liquid heat capacity (CPSL) 4294 J/kg-K Liquid density (RHOSL) 682.8 kg/m**3 Saturation pressure constant (SPB) 2132.52 Saturation pressure constant (SPC) -32.98

SPILL PARAMETERS

Initial liquid mass fraction (CMEDO) 0.741264917860582 Temperature of the source material (TS) 239.8 K Mass source rate (QS) 0.43 kg/s Source Area (AS) 0.137496561296768 m**2 Continuous source duration (TSD) 120 s Instantaneous source mass (QTIS) 0 kg Source height (HS) 2.00 m

FIELD PARAMETERS

Concentration averaging time (TAV) 3600 s Maximum downwind distance (XFFM) 100000.00 m Height of concentration calculation (ZP(1)) 0.00 m Height of concentration calculation (ZP(2)) 0.00 m Height of concentration calculation (ZP(3)) 0.00 m Height of concentration calculation (ZP(4)) 0.00 m

METEOROLOGY PARAMETERS

MET CONDITION 1 Surface roughness height (ZO) 0.2 m Ambient measurement height (ZA) 10.00 Ambient wind speed (UA) 3 m/s Ambient temperature (TA) 322.4 K Relative humidity (RH) 50 % Stability class (STAB) 4 (D)

-------------------------------------------------------------- OUTPUT RESULTS --------------------------------------------------------------

FOOTPRINT - MET CONDITION 1

Concentration (ppm) Downwind Distance (m)

---------------------------------------------- 217.9 20.68

CONFIDENTIAL. ArizonaCalifornia

Nevada Utah


Version: 081008_R1


ALTERNATIVECONSEQUENCE ANALYSIS

FIGURE 2

POTENTIALLY EFFECTED POPULATION: 0


!A

Legend!A Source

Distance to Endpoint (Area: 1,346.1 m2 )

r = 67.8 Feet

r = 20.7 Meters

TAB 2 – OTHER CHEMICAL MODELING RESULTS

08/08/08 12:28:04 *** SCREEN3 MODEL RUN *** *** VERSION DATED 96043 ***

WORST CASE OUTDOOR SPILL OF LiQU PEST (VYDATE C-LV, MODELED AS AREA SOURCE)

SIMPLE TERRAIN INPUTS: SOURCE TYPE = AREA EMISSION RATE (G/(S-M**2)) = .303000E-03 SOURCE HEIGHT (M) = .0000 LENGTH OF LARGER SIDE (M) = 9.8200 LENGTH OF SMALLER SIDE (M) = 7.7100 RECEPTOR HEIGHT (M) = .0000 URBAN/RURAL OPTION = RURAL THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED. THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED.

ANGLE RELATIVE TO LONG AXIS = .0000

BUOY. FLUX = .000 M**4/S**3; MOM. FLUX = .000 M**4/S**2.

*** STABILITY CLASS 6 ONLY *** *** ANEMOMETER HEIGHT WIND SPEED OF 1.50 M/S ONLY ***

********************************* *** SCREEN DISCRETE DISTANCES *** *********************************

*** TERRAIN HEIGHT OF 0. M ABOVE STACK BASE USED FOR FOLLOWING DISTANCES ***

DIST CONC U10M USTK MIX HT PLUME MAX DIR (M) (UG/M**3) STAB (M/S) (M/S) (M) HT (M) (DEG) ------- ---------- ---- ----- ----- ------ ------ ------- 10. 4757. 6 1.5 1.5 10000.0 .00 0. 20. 2568. 6 1.5 1.5 10000.0 .00 0. 30. 1821. 6 1.5 1.5 10000.0 .00 0. 31. 1770. 6 1.5 1.5 10000.0 .00 0. 32. 1722. 6 1.5 1.5 10000.0 .00 0. 33. 1676. 6 1.5 1.5 10000.0 .00 0. 34. 1632. 6 1.5 1.5 10000.0 .00 0. 35. 1590. 6 1.5 1.5 10000.0 .00 0. 36. 1550. 6 1.5 1.5 10000.0 .00 0. 37. 1511. 6 1.5 1.5 10000.0 .00 0. 38. 1474. 6 1.5 1.5 10000.0 .00 0. 39. 1438. 6 1.5 1.5 10000.0 .00 0. 40. 1404. 6 1.5 1.5 10000.0 .00 0. 50. 1115. 6 1.5 1.5 10000.0 .00 0. 60. 902.0 6 1.5 1.5 10000.0 .00 0. 70. 741.2 6 1.5 1.5 10000.0 .00 0. 80. 618.0 6 1.5 1.5 10000.0 .00 0. 90. 522.4 6 1.5 1.5 10000.0 .00 0. 100. 447.1 6 1.5 1.5 10000.0 .00 0.

*************************************** *** SUMMARY OF SCREEN MODEL RESULTS *** ***************************************

CALCULATION MAX CONC DIST TO TERRAIN PROCEDURE (UG/M**3) MAX (M) HT (M) -------------- ----------- ------- ------- SIMPLE TERRAIN 4757. 10. 0.

*************************************************** ** REMEMBER TO INCLUDE BACKGROUND CONCENTRATIONS ** ***************************************************

CONFIDENTIAL.California

Nevada

Oregon Idaho


Version: 081008_R1


WORST CASE LIQUID PESTICIDE (OUTDOOR SPILL)

FIGURE 3

POTENTIALLY EFFECTED POPULATION: 0


!A

Legend!A Source

Distance to Endpoint (Area:3,421.2 m2 )

r = 108.3 Feetr = 33.0 Meters


ALTERNATIVE CASE OUTDOOR SPILL OF LIQ PEST (VYDATE L, MODELED AS AREA SOURCE)

SIMPLE TERRAIN INPUTS: SOURCE TYPE = AREA EMISSION RATE (G/(S-M**2)) = .906000E-03 SOURCE HEIGHT (M) = .0000 LENGTH OF LARGER SIDE (M) = 1.1000 LENGTH OF SMALLER SIDE (M) = .8600 RECEPTOR HEIGHT (M) = .0000 URBAN/RURAL OPTION = RURAL THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED. THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED.






DIST CONC U10M USTK MIX HT PLUME MAX DIR (M) (UG/M**3) STAB (M/S) (M/S) (M) HT (M) (DEG) ------- ---------- ---- ----- ----- ------ ------ ------- 10. 946.9 6 1.5 1.5 10000.0 .00 0. 20. 308.1 6 1.5 1.5 10000.0 .00 0. 30. 154.5 6 1.5 1.5 10000.0 .00 0. 40. 94.05 6 1.5 1.5 10000.0 .00 0. 50. 64.00 6 1.5 1.5 10000.0 .00 0. 60. 46.59 6 1.5 1.5 10000.0 .00 0. 70. 35.63 6 1.5 1.5 10000.0 .00 0. 80. 28.24 6 1.5 1.5 10000.0 .00 0. 90. 23.02 6 1.5 1.5 10000.0 .00 0. 100. 19.17 6 1.5 1.5 10000.0 .00 0.


CALCULATION MAX CONC DIST TO TERRAIN PROCEDURE (UG/M**3) MAX (M) HT (M) -------------- ----------- ------- ------- SIMPLE TERRAIN 946.9 10. 0.



WORST CASE INDOOR SPILL OF LIQ PEST (VYDATE C-LV, MODELED AS VOLUME SOURCE)

SIMPLE TERRAIN INPUTS: SOURCE TYPE = VOLUME EMISSION RATE (G/S) = .481000E-01 SOURCE HEIGHT (M) = .0000 INIT. LATERAL DIMEN (M) = 4.8800 INIT. VERTICAL DIMEN (M) = 3.6600 RECEPTOR HEIGHT (M) = .0000 URBAN/RURAL OPTION = RURAL

THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED. THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED.





DIST CONC U10M USTK MIX HT PLUME SIGMA SIGMA (M) (UG/M**3) STAB (M/S) (M/S) (M) HT (M) Y (M) Z (M)DWASH ------- ---------- ---- ----- ----- ------ ------ ------ ----------- 10. .0000 0 .0 .0 .0 .00 .00 .00 20. 455.5 6 1.5 1.5 10000.0 .00 5.60 4.00NO 30. 412.2 6 1.5 1.5 10000.0 .00 5.97 4.15NO 40. 374.2 6 1.5 1.5 10000.0 .00 6.33 4.31NO 50. 341.4 6 1.5 1.5 10000.0 .00 6.70 4.46NO 60. 313.1 6 1.5 1.5 10000.0 .00 7.06 4.62NO 70. 288.3 6 1.5 1.5 10000.0 .00 7.42 4.77NO 80. 266.5 6 1.5 1.5 10000.0 .00 7.77 4.93NO 90. 247.2 6 1.5 1.5 10000.0 .00 8.13 5.08NO 100. 230.0 6 1.5 1.5 10000.0 .00 8.48 5.23NO

DWASH= MEANS NO CALC MADE (CONC = 0.0) DWASH=NO MEANS NO BUILDING DOWNWASH USED DWASH=HS MEANS HUBER-SNYDER DOWNWASH USED DWASH=SS MEANS SCHULMAN-SCIRE DOWNWASH USED DWASH=NA MEANS DOWNWASH NOT APPLICABLE, X<3*LB

***************************************

*** SUMMARY OF SCREEN MODEL RESULTS *** ***************************************




ALTERNATIVE CASE INDOOR SPILL OF VYDATE L (MODELED AS VOLUME SOURCE)







DIST CONC U10M USTK MIX HT PLUME SIGMA SIGMA (M) (UG/M**3) STAB (M/S) (M/S) (M) HT (M) Y (M) Z (M)DWASH ------- ---------- ---- ----- ----- ------ ------ ------ ----------- 10. .0000 0 .0 .0 .0 .00 .00 .00 20. 17.04 6 1.5 1.5 10000.0 .00 5.60 4.00NO 30. 15.43 6 1.5 1.5 10000.0 .00 5.97 4.15NO 40. 14.00 6 1.5 1.5 10000.0 .00 6.33 4.31NO 50. 12.78 6 1.5 1.5 10000.0 .00 6.70 4.46NO 60. 11.72 6 1.5 1.5 10000.0 .00 7.06 4.62NO 70. 10.79 6 1.5 1.5 10000.0 .00 7.42 4.77NO 80. 9.972 6 1.5 1.5 10000.0 .00 7.77 4.93NO 90. 9.250 6 1.5 1.5 10000.0 .00 8.13 5.08NO 100. 8.608 6 1.5 1.5 10000.0 .00 8.48 5.23NO


*************************************** *** SUMMARY OF SCREEN MODEL RESULTS ***

***************************************




WORST CASE OUTDOOR SPILL OF SOLID PART (IMIDAN 70-W) AS VAPOR

SIMPLE TERRAIN INPUTS: SOURCE TYPE = AREA EMISSION RATE (G/(S-M**2)) = .460000E-06 SOURCE HEIGHT (M) = .0000 LENGTH OF LARGER SIDE (M) = 18.9900 LENGTH OF SMALLER SIDE (M) = 14.9100 RECEPTOR HEIGHT (M) = .0000 URBAN/RURAL OPTION = RURAL THE REGULATORY (DEFAULT) MIXING HEIGHT OPTION WAS SELECTED. THE REGULATORY (DEFAULT) ANEMOMETER HEIGHT OF 10.0 METERS WAS ENTERED.






DIST CONC U10M USTK MIX HT PLUME MAX DIR (M) (UG/M**3) STAB (M/S) (M/S) (M) HT (M) (DEG) ------- ---------- ---- ----- ----- ------ ------ ------- 10. 17.79 6 1.5 1.5 10000.0 .00 0. 15. 10.59 6 1.5 1.5 10000.0 .00 0. 20. 7.897 6 1.5 1.5 10000.0 .00 0. 22. 7.221 6 1.5 1.5 10000.0 .00 0. 24. 6.669 6 1.5 1.5 10000.0 .00 0. 25. 6.429 6 1.5 1.5 10000.0 .00 0. 26. 6.207 6 1.5 1.5 10000.0 .00 0. 27. 6.003 6 1.5 1.5 10000.0 .00 0. 28. 5.814 6 1.5 1.5 10000.0 .00 0. 30. 5.474 6 1.5 1.5 10000.0 .00 0. 40. 4.279 6 1.5 1.5 10000.0 .00 0. 50. 3.546 6 1.5 1.5 10000.0 .00 0. 60. 3.038 6 1.5 1.5 10000.0 .00 0. 70. 2.654 6 1.5 1.5 10000.0 .00 0. 80. 2.346 6 1.5 1.5 10000.0 .00 0. 90. 2.088 6 1.5 1.5 10000.0 .00 0. 100. 1.868 6 1.5 1.5 10000.0 .00 0.



***************************************************

** REMEMBER TO INCLUDE BACKGROUND CONCENTRATIONS ** ***************************************************


WORST CASE INDOOR SPILL OF SOLID PEST (THIMET 20G, MODELED AS PARTICULATE)







DIST CONC U10M USTK MIX HT PLUME SIGMA SIGMA (M) (UG/M**3) STAB (M/S) (M/S) (M) HT (M) Y (M) Z (M)DWASH ------- ---------- ---- ----- ----- ------ ------ ------ ----------- 10. .0000 0 .0 .0 .0 .00 .00 .00 20. 18.46 6 1.5 1.5 10000.0 .00 5.60 4.00NO 30. 16.71 6 1.5 1.5 10000.0 .00 5.97 4.15NO 40. 15.17 6 1.5 1.5 10000.0 .00 6.33 4.31NO 50. 13.84 6 1.5 1.5 10000.0 .00 6.70 4.46NO 60. 12.69 6 1.5 1.5 10000.0 .00 7.06 4.62NO 70. 11.69 6 1.5 1.5 10000.0 .00 7.42 4.77NO 80. 10.80 6 1.5 1.5 10000.0 .00 7.77 4.93NO 90. 10.02 6 1.5 1.5 10000.0 .00 8.13 5.08NO 100. 9.326 6 1.5 1.5 10000.0 .00 8.48 5.23NO 150. 6.775 6 1.5 1.5 10000.0 .00 10.24 5.97NO 200. 5.179 6 1.5 1.5 10000.0 .00 11.96 6.68NO 250. 4.108 6 1.5 1.5 10000.0 .00 13.67 7.37NO 350. 2.794 6 1.5 1.5 10000.0 .00 17.02 8.70NO

400. 2.372 6 1.5 1.5 10000.0 .00 18.67 9.35NO 450. 2.042 6 1.5 1.5 10000.0 .00 20.30 9.98NO 451. 2.036 6 1.5 1.5 10000.0 .00 20.33 9.99NO 452. 2.030 6 1.5 1.5 10000.0 .00 20.37 10.01NO 453. 2.025 6 1.5 1.5 10000.0 .00 20.40 10.02NO 454. 2.019 6 1.5 1.5 10000.0 .00 20.43 10.03NO 455. 2.013 6 1.5 1.5 10000.0 .00 20.46 10.04NO 460. 1.985 6 1.5 1.5 10000.0 .00 20.63 10.11NO 461. 1.979 6 1.5 1.5 10000.0 .00 20.66 10.12NO 462. 1.974 6 1.5 1.5 10000.0 .00 20.69 10.13NO 463. 1.968 6 1.5 1.5 10000.0 .00 20.73 10.14NO 464. 1.963 6 1.5 1.5 10000.0 .00 20.76 10.16NO 465. 1.957 6 1.5 1.5 10000.0 .00 20.79 10.17NO






ALT CASE INDOOR SPILL OF SOLID PEST (THIMET 20G, MODELED AS PARTICULATE)







DIST CONC U10M USTK MIX HT PLUME SIGMA SIGMA (M) (UG/M**3) STAB (M/S) (M/S) (M) HT (M) Y (M) Z (M)DWASH ------- ---------- ---- ----- ----- ------ ------ ------ ----------- 10. .0000 0 .0 .0 .0 .00 .00 .00 20. .1136 6 1.5 1.5 10000.0 .00 5.60 4.00NO 30. .1028 6 1.5 1.5 10000.0 .00 5.97 4.15NO 40. .9334E-01 6 1.5 1.5 10000.0 .00 6.33 4.31NO 50. .8518E-01 6 1.5 1.5 10000.0 .00 6.70 4.46NO 60. .7810E-01 6 1.5 1.5 10000.0 .00 7.06 4.62NO 70. .7192E-01 6 1.5 1.5 10000.0 .00 7.42 4.77NO 80. .6648E-01 6 1.5 1.5 10000.0 .00 7.77 4.93NO 90. .6167E-01 6 1.5 1.5 10000.0 .00 8.13 5.08NO 100. .5739E-01 6 1.5 1.5 10000.0 .00 8.48 5.23NO 150. .4169E-01 6 1.5 1.5 10000.0 .00 10.24 5.97NO 200. .3187E-01 6 1.5 1.5 10000.0 .00 11.96 6.68NO 250. .2528E-01 6 1.5 1.5 10000.0 .00 13.67 7.37NO 350. .1720E-01 6 1.5 1.5 10000.0 .00 17.02 8.70NO

400. .1459E-01 6 1.5 1.5 10000.0 .00 18.67 9.35NO 450. .1257E-01 6 1.5 1.5 10000.0 .00 20.30 9.98NO 451. .1253E-01 6 1.5 1.5 10000.0 .00 20.33 9.99NO 452. .1250E-01 6 1.5 1.5 10000.0 .00 20.37 10.01NO 453. .1246E-01 6 1.5 1.5 10000.0 .00 20.40 10.02NO 454. .1242E-01 6 1.5 1.5 10000.0 .00 20.43 10.03NO 455. .1239E-01 6 1.5 1.5 10000.0 .00 20.46 10.04NO 460. .1222E-01 6 1.5 1.5 10000.0 .00 20.63 10.11NO 461. .1218E-01 6 1.5 1.5 10000.0 .00 20.66 10.12NO 462. .1215E-01 6 1.5 1.5 10000.0 .00 20.69 10.13NO 463. .1211E-01 6 1.5 1.5 10000.0 .00 20.73 10.14NO 464. .1208E-01 6 1.5 1.5 10000.0 .00 20.76 10.16NO 465. .1205E-01 6 1.5 1.5 10000.0 .00 20.79 10.17NO



CALCULATION MAX CONC DIST TO TERRAIN PROCEDURE (UG/M**3) MAX (M) HT (M) -------------- ----------- ------- ------- SIMPLE TERRAIN .1136 20. 0.



WORST CASE INDOOR SPILL OF SOLID PEST (IMIDAN 70W) AS VAPOR







DIST CONC U10M USTK MIX HT PLUME SIGMA SIGMA (M) (UG/M**3) STAB (M/S) (M/S) (M) HT (M) Y (M) Z (M)DWASH ------- ---------- ---- ----- ----- ------ ------ ------ ----------- 10. 3.763 6 1.5 1.5 10000.0 .00 4.02 3.83NO 20. 3.296 6 1.5 1.5 10000.0 .00 4.40 4.00NO 30. 2.929 6 1.5 1.5 10000.0 .00 4.77 4.15NO 40. 2.617 6 1.5 1.5 10000.0 .00 5.14 4.31NO 50. 2.356 6 1.5 1.5 10000.0 .00 5.51 4.46NO 60. 2.134 6 1.5 1.5 10000.0 .00 5.88 4.62NO 70. 1.944 6 1.5 1.5 10000.0 .00 6.24 4.77NO 80. 1.781 6 1.5 1.5 10000.0 .00 6.60 4.93NO 90. 1.638 6 1.5 1.5 10000.0 .00 6.96 5.08NO 100. 1.513 6 1.5 1.5 10000.0 .00 7.32 5.23NO


***************************************

*** SUMMARY OF SCREEN MODEL RESULTS *** ***************************************




WORST CASE INDOOR SPILL OF SOLID PEST (THIMET 20G, MODELED AS VOLUME SOURCE)







DIST CONC U10M USTK MIX HT PLUME SIGMA SIGMA (M) (UG/M**3) STAB (M/S) (M/S) (M) HT (M) Y (M) Z (M)DWASH ------- ---------- ---- ----- ----- ------ ------ ------ ----------- 10. .0000 0 .0 .0 .0 .00 .00 .00 20. 936.5 6 1.5 1.5 10000.0 .00 5.60 4.00NO 30. 847.5 6 1.5 1.5 10000.0 .00 5.97 4.15NO 40. 769.3 6 1.5 1.5 10000.0 .00 6.33 4.31NO 50. 702.0 6 1.5 1.5 10000.0 .00 6.70 4.46NO 60. 643.7 6 1.5 1.5 10000.0 .00 7.06 4.62NO 70. 592.7 6 1.5 1.5 10000.0 .00 7.42 4.77NO 80. 547.9 6 1.5 1.5 10000.0 .00 7.77 4.93NO 90. 508.2 6 1.5 1.5 10000.0 .00 8.13 5.08NO 100. 473.0 6 1.5 1.5 10000.0 .00 8.48 5.23NO 150. 343.6 6 1.5 1.5 10000.0 .00 10.24 5.97NO 200. 262.7 6 1.5 1.5 10000.0 .00 11.96 6.68NO 250. 208.4 6 1.5 1.5 10000.0 .00 13.67 7.37NO 350. 141.7 6 1.5 1.5 10000.0 .00 17.02 8.70NO

400. 120.3 6 1.5 1.5 10000.0 .00 18.67 9.35NO 450. 103.6 6 1.5 1.5 10000.0 .00 20.30 9.98NO 451. 103.3 6 1.5 1.5 10000.0 .00 20.33 9.99NO 452. 103.0 6 1.5 1.5 10000.0 .00 20.37 10.01NO 453. 102.7 6 1.5 1.5 10000.0 .00 20.40 10.02NO 454. 102.4 6 1.5 1.5 10000.0 .00 20.43 10.03NO 455. 102.1 6 1.5 1.5 10000.0 .00 20.46 10.04NO 460. 100.7 6 1.5 1.5 10000.0 .00 20.63 10.11NO 461. 100.4 6 1.5 1.5 10000.0 .00 20.66 10.12NO 462. 100.1 6 1.5 1.5 10000.0 .00 20.69 10.13NO 463. 99.83 6 1.5 1.5 10000.0 .00 20.73 10.14NO 464. 99.55 6 1.5 1.5 10000.0 .00 20.76 10.16NO 465. 99.27 6 1.5 1.5 10000.0 .00 20.79 10.17NO






ATTACHMENT E

SAFETY SPECIFICATIONS


ATTACHMENT F

FACILITY SAFETY INFORMATION


ATTACHMENT G

HAZARD REVIEW


ATTACHMENT H

OPERATING PROCEDURES


ATTACHMENT I

TRAINING


ATTACHMENT J

MAINTENANCE PROCEDURES


ATTACHMENT K

COMPLIANCE AUDITS


ATTACHMENT L

ACCIDENT INVESTIGATION


ATTACHMENT M

CONTINGENCY PLAN