Boulder Scientific Company - Executive Summary |
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Boulder Scientific (BSC) operates a small specialty chemical production facility in Mead, Colorado. Ethyl ether is used in large quantities in some reaction processes, and therefore is stored in a 10,000-gallon tank on site. Because the quantity of ethyl ether on site can exceed the 10,000-lb threshold for the RMP rule, Boulder Scientific prepared and submitted this plan. The storage and transfer of ethyl ether is also regulated under OSHA's Process Safety Mangement Standard (PSM), and BSC developed a number of safety protocols and procedures when the PSM standard was implemented in 1996. In addition to the normal safeguards associated with handling flammable liquids, BSC implemented detailed written procedures for all ethyl ether transfers. These procedures were reviewed in great detail by the PSM committee to systematically identify potential hazards and eliminate or reduce the risk associated with each hazard. All personnel handling ethyl ether receive special training in handl ing flammable liquids and the unique hazards assoicated with ethyl ether. In over twenty years of operating with ethyl ether, BSC has never had a significant incident involving ethyl ether. In addition to the proecedure and operating equipment safety reviews, accident risk is further reduced by locating of the storage tank in a diked area to prevent migration of spilled liquids and by fire protection from a high-volume sprinkler system. The equipment covered under the PSM standard (and the RMP rule) includes the storage tank, transfer piping, and two reactors connected to the storage tank. Under the RMP rule, each facility is required to develop a worst case scenario which assumes that the maximum quantity in the process (all the contents of the storage tank) are instantly vaporized and explode. The analysis of this worst-case scenario indicates a radius of impact of 0.28 miles, which extends to the west of the property boundary into a residential area in the town of Mead. As EP A points out in their guidance documents, these distances do not represent the likely reults of an accident because they are so conservative. The more realistic (but still quite conservative) alternative scenarios of a leaking tank followed by a pool fire or vapor cloud fire produce impact distances of less than 0.1 miles, which are completely contained on the property to the south, west, and north. Potential off-property impact to the east is minimal since this property is currently agricultural land. There were no alternative scenarios that produced impact distances of greater than 0.1 miles. In the event of an emergency release, BSC has written and tested a comprehensive Emergency Response Plan. Coordinated through Mountain View Fire Department, the Plan describes what steps are to be taken in the event of a major fire or chemical release. BSC maintains OSHA-certified responders on each production shift and coordinates practice responses on an ongoing basis with the Fire Depar tment. To summarize, ethyl ether has been handled without incident at the BSC site for over twenty years. BSC's ongoing program of risk minimization for ethyl ether storage and transfer is reflected in four types of safeguards: 1) Location of the storage tank and piping far enough from the property line to eliminate potential off-property impact, 2) Risk reduction through safety and hazard analysis, proper employee training, and the PSM program 3) Passive mitigation of spilled liquids with concrete dikes 4) Active mitigtaion of fires with a high-flow sprinklier system |