Reckitt & Colman, Inc. - Executive Summary |
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Introduction Reckitt & Colman Inc. manufactures, markets and sells leading household cleaning and food products in North America. The Company's manufacturing facility at 799 Route 206 in Belle Mead, New Jersey produces many of these products and has been in operation for nearly 30 years. ' We're proud of what we do X We produce high quality products at the Belle Mead facility that are preferred by millions of consumers to: clean and disinfect surfaces throughout the home, freshen the air, clean the oven, take care of carpets, polish furniture and help maintain an overall healthy home environment. ' We care X The Belle Mead team, which consists of approximately 280 men and women, works with an emphasis on safety, quality and quantity -- in that order. We accomplish our goals through a commitment to teamwork and recently earned the renowned International Organization of Standardization for Quality Management Systems (ISO 9002) Certification. Attainment of the certification enta ils meeting a comprehensive set of guidelines for areas that affect quality such as production, planning and process controls, and required team members to undergo thousands of hours of training. ' We work hard on preserving the environment, protecting health and ensuring safety X We take seriously our commitment to the environment and design products, processes and packaging to minimize waste through reuse and recycling and ensure materials are safe for disposal. We also spend many hours internally on developing safety procedures, conducting drills, and training personnel. Externally, we coordinate efforts with local emergency responders to ensure safety and proper preparedness. ' We are stakeholders in our community X Many employees and their families live, work, and go to school here. We take pride in contributing to community programs and services, including, among others, our Community Advisory Panel, annual Earth Day efforts and the yearly United Way campaign, in which the Company matches employee donations on a dollar-for-dollar basis, up to $1,000 per employee per calendar year. The Belle Mead facility is also subject to several safety and environmental regulatory programs including: ' Federal & State Employee and Community Right-To-Know requirements; ' OSHA's Process Safety Management and Hazard Communication requirements; ' Federal & State Hazardous Waste Management regulations; ' Federal Clean Air Act requirements & State Air Pollution Control regulations; ' Federal Clean Water Act requirements & State Water Pollution Control regulations; and ' New Jersey's Discharges of Petroleum and Other Hazardous Substances regulations. Continuous compliance with these and other programs is accomplished through well-established environmental management and safety programs led by designated personnel at the facility. The programs enlist the services of corporate and plant management, plant engineering, employees in production and maintenance functions, professional environmental and safety consultants, and local community representatives. In addition to the above-listed environmental and safety regulations listed above, the Belle Mead facility is also subject to requirements of the Chemical Accident Prevention Provisions in 40 CFR Part 68. These regulations, also known as the Risk Management Program Rule (RMP Rule), were promulgated pursuant to Section 112(r)(7) of the US Environmental Protection Agency's (EPA) Clean Air Act Amendments. Industrial facilities must comply with the RMP Rule if they handle, manufacture, or use certain toxic or flammable substances in a quantity greater than specified threshold quantities in a process. A list of regulated toxic and flammable substances and their individual threshold quantities is located in Section 68.130 of the RMP Rule. All regulated facilities are required to submit risk management program information summarizing their Risk Management Programs by June 21, 1999. The Belle Mead f acility is subject to the requirements of the RMP Rule due to the type and amount of regulated flammable substances stored in vessels in a storage tank farm referred to as the ISO Farm (abbreviation for Isobutane stored in an area also known as the "Propellant Storage and Distribution Process"). The ISO Farm qualifies as Program Level 3 under the RMP Rule. The Belle Mead facility has prepared and implemented a Risk Management Program for the ISO Farm in accordance with Program Level 3 requirements and has submitted a Risk Management Plan to the EPA in compliance with 40 CFR Part 68.150 (Risk Management Plan - - Submission). This Executive Summary is required under 40 CFR Part 68.155. The intention of this Executive Summary is to provide general information to the EPA, employees of Reckitt & Colman, and the local community about the regulated flammable substances stored and handled at the Belle Mead facility and the facility's accidental release prevention program and emergency res ponse policies associated with the ISO Farm. Additionally, it describe the required worst-case and alternate release scenarios evaluated as part of the Risk Management Program at the facility and report on the five-year accident history of the Belle Mead facility, as it pertains to the flammable substances stored in the ISO Farm. For the purposes of this Executive Summary and for the facility's Risk Management Program and Plan, the substances, equipment and procedures of focus are the regulated flammable substances, equipment, and procedures associated with the ISO Farm only. This area encompasses the ISO Farm, unloading area, and process piping entering the aerosol propellant gassing operation at the gashouse. Description of Regulated Substances The Belle Mead facility does not handle, manufacture or use any toxic substances over the regulatory threshold. Reckitt & Colman does use blends of liquefied petroleum gas (LPG) in the aerosol propellant gassing operation at the Belle Mea d facility. LPG is a flammable substance and is regulated under the RMP Rule if handled, manufactured or stored in a process at a facility in a quantity greater than its listed threshold quantity. The specified threshold quantity for flammable substances under the RMP Rule is 10,000 pounds. Hazard Assessment: Worst-Case Release Scenario A required element of a Risk Management Program is a hazard assessment using a worst-case release scenario to determine distance (endpoint distance) to affected public and environmental receptors. The hazard assessment is also referred to as the off-site consequence analysis. Despite the RMP Rule's focus on a worst-case release scenario, the probability that such a scenario will occur is extremely unlikely; therefore, this scenario represents a useful planning tool. By no means does it indicates the probability of such an occurrence. In the case of flammable substances, the RMP Rule defines worst-case release scenario as a vapor cloud explosion ( VCE) generated by the release and ignition of the contents of the single largest vessel in a process. In addition, no existing safety, accident prevention, or active mitigation systems can be considered in this scenario. Reckitt & Colman sought the advice of two independent expert explosion-modeling consultants on the appropriate model for the worst-case release scenario involving the flammable substance in the ISO Farm. Both consultants arrived at the same model, and used the same model inputs, taking into account various factors such as the site layout and nature of the flammable substances. The endpoint distance is defined in the RMP Rule as the distance from the point of detonation to a point of an overpressure of 1 pound per square inch (psi). One psi is the amount of pressure generally required to break a typical glass window. The endpoint distance at the Belle Mead facility extends from the point of detonation in the ISO Farm into the wooded area of the Reckitt & Colman pro perty to the north and north-east; to the freight railroad tracks east of the facility; to Hillsborough Road just in front of the truck entrance gate at the facility; and to the facility's manufacturing area to the west. The only publicly accessible receptor identified in the hazard assessment of the worst-case release scenario is the area of Reckitt & Colman property beyond the fence line. Although mostly owned by Reckitt & Colman, the area is subject to uncontrolled public access. Hazard Assessment - Alternate Release Scenario A similar modeling exercise was performed on several alternate release scenarios. Alternate release scenarios represent those that are also unlikely to occur, but may be more likely to occur than the worst-case release scenario. Alternate release scenarios include such incidents such as a pipe break, tank puncture, relief valve failure, or unloading hose rupture. Such a release may result in such events as a pool fire, a vapor cloud fire, a vapor cloud exp losion (as performed for the worst-case scenario), and a boiling liquid evaporating vapor explosion (BLEVE). The EPA allows alternate release scenario models to take into account the use of existing safety, accident prevention, or active mitigation systems present at the facility such as emergency shut-off valves and water deluge systems. The ISO Farm is equipped with state-of-the-art safety systems, including LPG sensing devices that automatically activate emergency shut-off valves when LPG is detected at less than half of its lower flammability limit, a water deluge system, and check valves and excess flow valves that automatically close upon detection of irregular conditions (i.e., backflow). The ISO Farm is also enclosed by a chain-linked fence with restricted access. Vehicles are denied access to the fenced-in area surrounding the storage vessels in the ISO Farm. Modeling of various alternate release scenarios at the Belle Mead facility indicated only one scenario with an e ndpoint distance that may include a potential receptor. This is reported in the Risk Management Plan and involves the release of LPG caused by a pipe rupture over a period of one hour. This alternate release scenario was modeled using three consequences of such a release: a pool fire, a vapor cloud fire, and a VCE. These consequences were selected for the model based on the technical feasibility of their potential occurrence in view of the ISO Farm equipment and the flammable substances involved. Use of these consequences in the modeling does not reflect an indication of the probability that any of them may occur at the Belle Mead facility. Endpoint distance from a pool fire was negligible because the rate of evaporation of LPG over a one-hour period would exceed the release rate; therefore, a liquid pool of LPG would not develop, and no risk of pool fire would occur. The modeling also determined endpoint distances from a vapor cloud fire and a VCE. Both a vapor cloud fire and VCE have potential receptors on Reckitt & Colman property just outside of the facility fence line. Although owned by Reckitt & Colman, the area is subject to uncontrolled public access. These potential receptors are the same as those in the worst-case release scenario but to a shorter distance in all directions from a potential rupture in pipe running between the ISO Farm and the Reckitt & Colman manufacturing building. Accidental Release Prevention and Emergency Response Programs Reckitt & Colman places great importance on the implementation of procedures for responding to and, more importantly, preventing accidental releases of chemicals that have the potential to harm human health or the environment. At Reckitt & Colman, we have adopted a rigorous approach to ensuring that hazardous chemicals and flammable liquids are used and stored safely. One element of that approach is a thorough risk assessment, a formal and exhaustive analysis of chemical processes used to identify and addre ss process hazards. Risk assessments are conducted on a periodic basis for existing processes and immediately before the final design stage of new or modified processes. In a typical risk assessment, team members from a variety of disciplines - engineers, supervisors, plant operators, and maintenance technicians - gather to analyze a chemical process. Every component of the process - pumps, piping, storage tanks, instruments, valves, controls, and safety devices - as well as operating and maintenance practices are evaluated to determine possible causes of failure. Each cause is then reviewed to ensure that one or more levels of safety protection are available in the event a failure occurs. The use of risk assessment by analyzing process hazards became universal with the introduction of OSHA's Process Safety Management regulation in 1993. Although this regulation applies only to certain flammable liquids used at the Belle Mead facility, we recognize the importance and benefits of ri sk assessment to all our operations and have applied it to other processes that have the potential of creating a significant safety hazard. Subject to several Federal and state discharge prevention and process safety requirements for many years, Reckitt & Colman maintains an environmental program that requires continuous evaluation and improvement of facility compliance programs, work practices, employee training programs, first-responder spill response capabilities, equipment maintenance and repair programs, leak detection systems, and other safety measures. In an effort to enhance the effectiveness and organization of the several accidental release prevention programs and emergency response programs maintained at the Belle Mead facility, Reckitt & Colman has recently prepared an Integrated Contingency Plan in compliance with the National Response Team's Integrated Contingency Plan. This plan also provides guidance to include local emergency responders such as police, fire, and res cue as appropriate. Five-year Accident History Facilities subject to the RMP Rule are also required to report accidents and releases occurring in the last five years in which exposure to a regulated flammable substance, overpressure generated by an explosion of the substance, or radiant heat generated by a fire involving the substance led to death, injury, or response or restoration activities at an environmental receptor on-site or off-site. Reckitt & Colman certifies in the RMP submission to the EPA that during the past five years, no accidental releases have occurred involving regulated flammable substances from the ISO Farm according to the EPA's criteria. Conclusion The safety and control systems on the equipment in and associated with the ISO Farm are state-of-the-art and represent the highest degree of safety and accident prevention currently available for unloading, storage, and distribution of flammable substances. We also meet and exceed National Fire Protection Associa tion (NFPA 58) standards for the LPG. As a responsible corporate citizen and neighbor in the community, Reckitt & Colman acknowledges its duty to prevent accidental releases of potentially harmful substances into the environment. Reckitt & Colman's strong environmental management program, including the elements of an effective Risk Management Program, commitment to personnel training and adherence to standard operating procedures ensure continuous environmental compliance and the attainment of Reckitt & Colman's primary goal for the Belle Mead facility: "Safety, Accident Prevention." |