I-K-I Manufacturing Company, Inc. - Executive Summary
I-K-I Manufacturing Company is a specialized contract aerosol packaging facility located in the Maple Court Industrial Park, Edgerton, Wisconsin. Most outdoor facility areas, other than a parking lot and shipping and receiving docks, are secured by building walls and a chain link fence. The individual processes and storage facilities are scattered over 22.3 acres so that an incident at one will not involve another process. |
I-K-I is committed to being a good custodian to both our employees and community. In the design and operation of the processes within the facility, a prime consideration is the evaluation of the chemical hazards inherent in the products packaged. As a result, we ensure that all equipment used to process, store, or handle highly hazardous chemicals is designed, constructed, installed, and maintained in order to minimize the risk of chemical release. We have also established and implemented written procedures to maintain the ongoing mechanical integrity of our process
equipment. In addition, we ensure that the frequency of our mechanical inspections is consistent with applicable manufacturer's recommendations, and that each test and/or inspection is thoroughly documented. Safety and good health are of primary importance to the management and employees of I-K-I Manufacturing.
The Edgerton I-K-I facility is complying with the OSHA Process Safety Management of Highly Hazardous Chemicals standard (PSM), Title 29 CFR 1910.119, to deal with the risks involved with the storage, handling, and processing of highly hazardous materials. In this way we promote overall plant and worker safety.
Our PSM enables the facility to prevent the occurrence, and minimize the consequences, of significant releases of toxic substances as well as fires, explosions, and other types of catastrophic accidents. Overall, the PSM prevents accidental fatalities, injuries and illnesses and avoids physical property and environmental damage.
Safety and health considerations, inclu
Properties of, and hazards presented by, the chemicals used in the process;
Precautions necessary to prevent exposure, including administrative controls, engineering controls, and personal protective equipment;
Control measures to be taken if physical contact or airborne exposure occurs;
Quality control for raw materials and control of hazardous chemical inventory levels.
Administrative controls include: smoking is prohibited on all I-K-I property and clothing of personnel in production areas must be at least 65% cotton to reduce the occurrence of static electric discharge. These administrative controls are in place because of the flammable nature of most of our processes.
Engineering controls range from facility layout, to the design of the buildings and processes to NFPA standards. Processes are designed to include process area detectors, interlocks, and emission abatement systems, where appropriate.
Our operating procedures describe tasks to be performed, data to be r
ecorded, operating conditions to be maintained, samples to be collected, and safety and health precautions to be taken. Our procedures are technically accurate, understandable to employees, and revised periodically to ensure that they reflect current operations.
The employee training program at our facility helps our employees understand the nature and the causes of problems that may arise from process operations; our program helps reduce the number and the severity of incidents arising from process operations.
The intent of our training program is to increase employee awareness of process hazards that are associated with a particular process. We train each employee who is involved in operating a process, and each employee who will be involved in a newly assigned process, with an overview and the proper operating procedures of the process. The training programs are reviewed and updated annually, or when a process is modified or a new process introduced.
The facility fills Ethylene O
xide cartridges, which are used in medical sterilization; starting fluids containing Ethyl Ether; and aerosol cans using flammable mixtures (Methyl Ether, Butane, Isobutane, Propane, and Isopentane) as propellants.
Worst-Case Scenarios Summaries
Toxic Gas: Ethylene Oxide
With the use of EPA's OCA Guidance Reference Tables or Equations, and a release rate of 40 pounds/minute for 10 minutes, a wind speed of 1.5 meters/second the gas release of Ethylene Oxide would reach an endpoint of 0.6 miles. Within the 0.6 mile radius endpoint are found the Edgerton Middle School, Edgerton Memorial Hospital, Old Race Track Park, Edgerton Retirement Apartments, Sterling Manor Retirement Home, industrial areas, and residences. The estimated residential population within the distance to the endpoint is 930, using the Landview III Environmental Mapping Software developed by the U.S. Department of Commerce.
Flammable Mixture: Isobutane/Propane
With the use of EPA's OCA Guidance Reference Tables or
Equations, and a release of 110,000 pounds resulting in a vapor cloud explosion the endpoint would be 0.4 miles. Within the 0.4 mile radius endpoint are found the Edgerton Memorial Hospital, Old Race Track Park, Edgerton Retirement Apartments, Sterling Manor Retirement Home, industrial areas, and residences. The estimated residential population within the distance to the endpoint is 330, using the Landview III Environmental Mapping Software developed by the U.S. Department of Commerce, using the Landview III Environmental Mapping Software.
Alternative Release Scenarios Summaries
Toxic Gas: Ethylene Oxide
Assume either a leak in a drum connection fitting or valve packing seal leaking. The drums of Ethylene Oxide are physically checked every half hour; therefore, it is estimated that there would be a maximum loss of 0.5 pounds of Ethylene Oxide. The maximum release time would be 30 minutes, the release rate would be 0.3333 pounds per minute, wind speed of 3 meters/second, air tempera
ture of 77 F, and a toxic endpoint of 0.09 mg/l. Using of EPA's OCA Guidance Reference Tables or Equations, in which the smallest release rate is 1 pound/minute, the toxic end point using Reference Table 20 for 10 minutes of release would be less than 0.1 miles, and using Reference Table 21 for 60 minutes of release the end point would be less than 0.1 miles. Within the less than 0.1 mile radius endpoint are found the Old Race Track Park, industrial areas and residences. The estimated residential population within the distance to the endpoint is 30, using the Landview III Environmental Mapping Software.
Flammable Mixture: Isobutane/Propane
Assume a pump seal failure of 10 gallons per minute for 8 to 9 hours, quantity released 24,000 pounds resulting in a vapor cloud explosion. The maximum release time would be 540 minutes at a release rate of 44.2 pounds per minute, wind speed of 3 meters per second, air temperature of 77 F and a weather stability of D, and a 10% yield factor (10% of
vapor is available for explosion), the distance to an endpoint of 1 psi would be 0.1 miles using EPA's OCA Guidance Reference Tables or Equations. Within the 0.1 mile radius endpoint are found industrial areas and residences. The estimated residential population within the distance to the endpoint is 30, using the Landview III Environmental Mapping Software.
There are no national or state parks, forests, or monuments; officially designated wildlife sanctuaries, preserves or refuges; or federal wilderness areas within either the toxic or flammable mixture endpoints.
In the last five years we have had one incident on June 19, 1997, involving an explosion of Ethylene Oxide, which was confined within the fill vault where the filling, cup placement and crimping (sealing) of the cartridges took place. The explosion involved a maximum amount of 400 grams of Ethylene Oxide. The Wisconsin Department of Natural Resources concluded that there was no release of Ethylene Oxide to the environment
. This incident involved damage to the plant facility. There were no injuries to I-K-I personnel. I-K-I Hazardous Material Response Technicians and the Edgerton Fire Department responded to the incident. There were no offsite damage, evacuation or injuries. This is the only incident involving either toxic chemicals or flammable mixtures in over thirty years.
Emergency Response Plan
I-K-I Manufacturing Company has an Emergency Response Plan (developed in compliance with 29 CFR ' 1910.120, NR 630.22 and NR 158, Wis. Adm. Code, and with ' 144.76, Wis. stats) that is designed to prevent or minimize hazards to human health or the environment in the event of fire, explosion, or any unplanned sudden or non-sudden release of hazardous materials or hazardous materials constituents to air, soil, groundwater, or surface water.
The provisions of this plan will be implemented immediately whenever there is a fire, explosion, or release of hazardous waste or hazardous waste constituents which coul
d threaten human health or the environment.
At all times, there will be at least one employee on the facility premises or on call (i.e., available to respond to an emergency by reaching the facility within a short period of time) with the responsibility for coordinating all internal emergency response measures.
All team members must have completed a Hazardous Material Response Technical Level Training course taught by a State of Wisconsin certified instructor. All members of the HazMat Response Team attend a refresher session every year.
The Emergency Coordinator will contact selected local and regional entities and authorities that may be involved in an emergency situation. Each of these organizations will be given a copy of the Emergency Response Plan and all revisions.
Offsite notification is to be made only by the Emergency Coordinator (or a designated representative).
All employees participate in emergency evacuations drills for tornado and fire annually. This drill also repr
esents a test of the emergency alarm system.