Bayer Corporation - Berkeley California - Executive Summary |
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Accidental Release Prevention and Emergency Response Policies: We at Bayer Corporation are strongly committed to employee, public and environmental safety. This commitment is the basis of having a comprehensive accidental release prevention program in place that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. If such a release does occur, we are prepared to work closely with the Berkeley Fire Department which provides highly trained emergency response personnel to control and mitigate the effects of the release. The Stationary Source and the Regulated Substances Handled: Our facility's primary activities encompass biotechnological pharmaceutical manufacturing and research. We have one regulated substance present at our facility, anhydrous ammonia that is used for refrigeration. T he maximum inventory of anhydrous ammonia at our refrigeration facility is 15000 pounds. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario: To perform the required offsite consequence analysis for our facility, we have used the look-up tables and equations provided by the EPA in the Risk Management Program Guidance for Ammonia Refrigeration, EPA 550-B-98-014. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 3 toxic substances as a class involves a catastrophic release from the ammonia refrigeration process. The scenario involves the release of 4100 lbs. of ammonia in a gaseous form over 10 minutes. Passive mitigation controls, the building enclosure was taken into account to calculate the consequences of the scenario. Under worst case weather conditions, namely Class F atmosphe ric stability and 1.5 m/s windspeed, a maximum distance of 0.4 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. The alternative release scenario involves the release of the 14000 pound ammonia inventory through a condenser tube failure into the cooling water. This release occurs over 9.5 minutes. This cooling tower water acts as a mitigation creating a dilute aqueous ammonia solution. This solution, though dilute is able to produce an ammonia source term at the cooling tower. Under prescribed weather conditions, namely Class D atmospheric stability and 3.0 m/s windspeed, a maximum distance of 0.1 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. Though this scenario yields the the greatest alternative release distance to endpoint it is not beyond the facility and has no impact on any public receptors or residential population. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps: Our facility has taken all the n ecessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. The anhydrous ammonia refrigeration process at our facility is subject to the California OSHA PSM standard under 8 CCR 5189. The following sections briefly describe the elements of our release prevention program currently in place at our stationary source. Process Safety Information: Bayer Corporation maintains a detailed record of written safety information that describes the chemical hazards, operating parameters and equipment designs associated with the anhydrous ammonia refrigeration process. Process Hazard Analysis: Our facility conducts comprehensive studies to ensure that potential hazards associated with the anhydrous ammonia refrigeration process are identified and controlled. The methodology used to carry out these analyses is a Hazard and Operability Study (HAZOP). The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are regularly revalidated every three years. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures: For the purposes of safely conducting activities within our covered process, Bayer Corporation maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved with the processes. Training: Bayer Corporation has a comprehensive training program in place to ensure that employees that are operating the covered process are completely competent in the operating procedures associated with this process. New employees receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently. R efresher training is provided at least every year and more frequently as needed. Mechanical Integrity: Bayer Corporation carries out highly documented maintenance checks on process equipment to ensure proper functions. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change: Written procedures are in place at Bayer Corporation to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are prompt ly made aware of and offered training to deal with the modification. Pre-startup Reviews: Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Bayer Corporation. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits: Bayer Corporation conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation: Bayer Corporation promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to t he incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of 5 years. Employee Participation: Bayer Corporation truly believes that process safety management and accident prevention is a team effort. Company employees express their views concerning accident prevention issues and recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation to the RMP rule and participate in all aspects of the program. Contractors: On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Bayer Corporation has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response s hould an accidental release of a regulated substance occur. Five-year Accident History: Bayer Corporation has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. Emergency Response Plan: Bayer Corporation carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. City of Berkeley, a CUPA, acts as the Local Emerg ency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. Planned Changes to Improve Safety: Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Closing the recommendation found within the seismic assessment performed by EQE International are some of the major steps we want to take to improve safety at our facility. These changes are expected to be implemented by 9/30/1999. |