FAR Research, Inc. - Executive Summary

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FAR Research, Inc. is a manufacturer of pharmaceutical intermediates and fine organic chemicals.  Trimethylchlorosilane (TMCS) is one compound handled by FAR Research.  TMCS is stored in sufficient quantity to require development and submission of a Risk Management Plan (RMP).  This summary describes FAR Research's activities and safeguards which have been instituted to protect our employees, the public, and the environment. 
 
FAR Research, Inc. has operated at the Palm Bay, Florida location since 1983.  FAR Research synthesizes pharmaceutical intermediates, bulk active pharmaceuticals, and fine organic chemicals.  These chemicals are sold to the pharmaceutical, cosmetic, electronics, and general chemical industries.  Over the years, FAR's products have become part of compounds designed to fight aids, hepatitis B, and other diseases.  Other materials have been used to facilitate electronic chip manufacture.  In addition, some molecules have been used by the space industry.  One FAR prod 
uct has improved the efficiency of nylon manufacture.  FAR Research, Inc. and its employees are committed to continue to safely manufacture organic compounds that make a positive difference. 
 
FAR Research, Inc. is made up of people and the facility.  Our technical, operations, and support groups are committed to safe development and manufacture of the products we synthesize.  A typical path for a new product at FAR begins with a customer need, followed by a thorough literature search for safety and process information.  Upon completion of the background work, a synthesis route is proposed, then the laboratory work commences.  Chemists and technicians do process development on a small, glassware scale to ensure that the synthesis can be run safely.  The next step is to write up a proposed, detailed procedure to be carried out at the pilot scale.  A process safety review meeting is scheduled.  The review participants include the process development chemist, the manufacturing manager, the 
technical director, and the site manager.  Other staff may be involved if warranted.  The review includes verification that proper development procedures have been followed and that available safety and health information has been obtained, checked, and included with the batch record.  Any recommended changes made by the committee must be completed prior to scale up of the process.  The review committee may also require that special operator training sessions be held prior to running certain compounds or chemistries. 
 
FAR Research's equipment is now summarized.  Process equipment at FAR is designed for the intended use.  Process vessels are glasteel or grade 316 stainless steel.  The vessels are ASME Code rated and are protected with rupture disks and/or relief valves.  If corrosion is of concern, testing may be carried out prior to running in a given vessel.  Glasteel vessels may be spark tested to verify integrity.  Alloy vessels are tested using ultrasonic wall thickness testing de 
vices.  Key vessels and equipment are taken down for maintenance annually. 
 
The material and process triggering filing of the Risk Management Plan (RMP) is trimethylchlorosilane (TMCS).  TMCS is stored in a 5000-gallon pressure rated carbon steel tank.  The maximum quantity inventoried is 35,000 lbs.  FAR's policy is to minimize inventory of all raw materials.  The material is delivered by bulk tank wagon in quantities of 30-32,000 lbs.  Orders are not placed unless TMCS inventory is less than 2,000 lbs.  Inventory is verified by tank level gauge and receiving and usage records. 
 
RMP requires FAR to propose a worst case scenario.  As a calculation algorithm FAR used the EPA OCA Guidance reference tables.  The scenario involves rupture of the storage tank and subsequent evaporation of the TMCS.  FAR Research has placed the TMCS storage tank within a diked area.  This passive mitigation system reduces the effect of TMCS on the area surrounding the plant site.  Nevertheless, the toxic end 
point for this scenario extends to a 2.2 mile radius around the plant.  The estimated population affected is 18,191 (1990 Census).  Public receptors included within the endpoint are residences, schools, commercial areas, recreation areas, and wildlife sanctuaries.  In the unlikely event that this worst case situation is realized, the FAR contingency plan will be implemented.  This plan includes measures which will mitigate any TMCS release.  However, these measures are not allowed to be included in the worst case scenario.  In addition, this case is unlikely as there are written procedures designed to minimize TMCS incidents.  Also, scheduled maintenance is carried out in order to insure the integrity of the storage tank. 
 
An alternative release scenario is required by RMP guidelines.  FAR has selected a case involving breaking off the bottom valve of the storage tank.  It is assumed that the tank would be about half full, containing 17,000 lbs. TMCS.  The model used to evaluate the ar 
ea affected is the set of EPA OCA Guidance reference tables.  Based upon the parameters of this model, a radius of 0.5 miles from the TMCS tank would be involved above the toxic endpoint.  Per the census tables from 1990 a total of 495 people could be affected.  In addition, schools, residences, commercial areas, recreation areas, and wildlife sanctuaries could be involved.  Only the passive mitigation of the tank dike is considered for this model.  However, in the unlikely event that this accident would occur, neutralization, water spraying of the releasing cloud, and scrubbing of the fumes from the release would all mitigate the release and would tend to reduce the affected radius. 
 
A PSM (Process Safety Management) Review has been carried out for TMCS.  Management and technical personnel have evaluated a number of accident scenarios.  Several tank piping changes have been recommended and made.  Operating procedures have been reviewed and updated.  A preventative maintenance plan has 
been put in place.  Specific emergency response actions have been developed for TMCS releases and have been included in the RMP for TMCS.  Supplier safety information is also included. 
 
No accidental releases of TMCS have occurred in the past 5 years. 
 
FAR Research plans to continue to safely handle TMCS and will incorporate procedures which would further reduce the possibility of a TMCS release.
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