Mallinckrodt Baker, Inc - Executive Summary |
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I. EXECUTIVE SUMMARY ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At Mallinckrodt Baker, Inc., we are committed to operating and maintaining all of our processes in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: * A description of our facility and use of substances regulated by EPA's RMP regulation * A summary of results from our assessment of the potential offsite consequences from accidental chemical releases * An overview of our accidental release prevention programs * A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule * An overview of our emergency response p rogram * An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment * The certifications required by EPA's RMP rule * The detailed information (called data elements) about our risk management program STATIONARY SOURCE AND REGULATED SUBSTANCES Our facility packages high purity laboratory, microelectronic, and bulk pharmaceutical chemicals. Our facility also accomplishes limited purification operations and some aqueous blending operations. The Mallinckrodt Baker facility consists of a single building, approximately 350,000 square feet, and encompasses warehousing and packaging operations as well as unloading facilities for rail cars and tank trucks. In our processes, we use the following chemicals in quantities that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: Toxic s Chloroform CAS # 67-66-3 Maximum Quantity: 46,000 lbs. Flammables Ethyl Ether CAS # 60-29-7 Maximum Quantity: 48,000 lbs. Our accidental release prevention programs, management systems, and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. KEY OFFSITE CONSEQUENCE ANALYSIS SCENARIOS EPA's RMP rule requires that we provide information about the worst-case release scenario(s) and alternative release scenario(s) for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: Worst-case Release Scenario - Regulated Toxic Chemicals - Chloroform The worst case scenario is a catastrophic failure of the bulk receiving vessel, resulting in the loss of the entire contents, 46,000 lbs. in ten minutes. Liquid spilled will be contained in a diked area from which the vapors can be blanketed and the spill cleaned up. Vapors from the evaporating liquid will be dispersed downwind with the plume width being approximately 200 feet. The estimated distance to the 92 ppm exposure endpoint is 0.4 mile (2100 feet). The offsite impact would include approximately 150 individuals located along a street to the west and in a subdivision to the north. Additionally, a business directly across the highway to the south, and farmland to the east would be affected. The unloading area is in a containment area which will hold the entire contents of the vessel and provides an area in which a spill could be covered to minimize evaporation and cleaned up. Pressure testing of the vessels, video surveillance, operator observation, and periodic inspection of the unloading systems minimize the likelihood of this event. Alternative Release Scenario - Regulated Toxic Chemicals - Chloroform The alternative scenario is a leak occu rring at the point where the unloading line is connected to the bulk vessel. This would lead to Chloroform leaking into the containment dike and beginning to evaporate. It is expected that, should this scenario occur, the duration will be a maximum of 1 hour. The distance to the 92 ppm exposure endpoint is estimated to be less than 0.1 mile (528 feet) which will have no offsite impact. Management systems in place requiring the operator to frequently walk the lines to check for leaks as well as the utilization of video surveillance, and positive tie down of the hose fittings minimize the potential for this scenario to occur. Worst-case Release Scenario - Regulated Flammable Chemicals - Ethyl Ether The worst case scenario is a vapor cloud explosion (VCE) following the catastrophic failure of the bulk vessel at its maximum volume of 48,000 lbs. The estimated distance to the 1 psig overpressure endpoint is 0.1 mile which would produce no offsite impact. Based on this analysis, Ethy l Ether is a Program 1 material and no alternative release scenario is required. The unloading vessel is periodically pressure tested in accordance with DOT requirements which will minimize the likelihood of this event occurring. The unloading system is periodically inspected, the area is under video surveillance, the systems are controlled by remote shut off valves for early shutdown, and all electrical systems in the area are hazard rated for the area. These systems for early leak detection and shut off and the electrical systems combine to minimize the potential for a leak occurring undetected and subsequently being ignited to produce a vapor cloud explosion. We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS We take a systematic, proactive approach to preventing accidental release s of hazardous chemicals. Our management systems address each of the key features of successful prevention programs, including: * Process safety information * Process hazard analysis * Operating procedures * Training * Mechanical integrity * Management of change * Pre-startup review * Compliance audits * Incident investigation * Employee participation * Hot work permit * Contractors As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: * Performed Process Hazards Analysis on all components of the bulk unloading system and made appropriate changes to minimize the potential for incidents. * Utilize a preventative maintenance program to help insure proper operation of the systems * Operating procedures are in place and operators trained to make sure all operations are understood and established procedures followed. * All changes which do not involve replacement in kind are managed through a management of change procedure to insure proper review prior to implementation. * Pre - start up safety reviews are conducted for all systems * Surveillance systems are in place to assist with timely identification and remediation for all leaks. * Remote shutdown systems are in place to accomplish quick shutdown should a leak occur, even prior to remediation. These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting the highest standards for accident prevention. FIVE-YEAR ACCIDENT HISTORY Records are kept at our site for all significant accidental chemical releases that occur. During the past 5 years there were no chemical releases involving materials covered under the EPA's Risk Management rule that resulted in injuries, property damage, or environme ntal damage either onsite or offsite. EMERGENCY RESPONSE PROGRAM We maintain a site emergency response plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan. PLANNED CHANGES TO IMPROVE SAFETY The following is a list of improvements that we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases: * Maintain inventory management such that the quantity of material does not substantially change, causing a greater potential offsite impact * Enhance the video surveillance system to provide higher resolution and easier leak detection and shutoff. This is expected to be completed by June 30, 1999. *Enhance the preventative maint enance process for tracking equipment records and status. This is expected to be completed by December, 1999. *Continue to conduct tours with the local emergency responders to help them better understand and be prepared to assist in onsite emergency response. The latest tours were conducted in April, 1999 and are expected to be conducted annually. * Conduct periodic drills for the site Emergency Response Team and participate in county emergency drills as appropriate CERTIFICATIONS For all covered processes, the undersigned also certifies that, to the best of my knowledge, information, and belief, formed after reasonable inquiry, the other information submitted in this RMPlan is true, accurate, and complete. Signature Title: Plant Manager Date: June 21, 1999 RMP DATA ELEMENTS The following pages present additional information about our risk management program that EPA's RMP rule has asked us to provide. This information is categorized as follows: * Registration * Offsite consequence analysis * Five-year accident history * Program 3 prevention program * Emergency response program |