Genencor International, Inc. - Executive Summary |
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Executive Summary Genencor International Inc., Cedar Rapids Risk Management Plan Introduction to Facility & Regulated Substance Genencor International, Inc.("GCI") is an industrial biotechnology facility which produces industrial enzymes. The facility is located on 40 developed acres on the southwest side of Cedar Rapids. It is immediately bordered by 41st Avenue Drive; C Street SW; a fish-feeding operation; a neighboring power station property; and 40 undeveloped acres owned by GCI. This ISO-9002-certified-facility employs 91 people and operates under a team-based organizational structure. In March of 1999, Genencor initiated an effort to implement an Environmental Health & Safety Management System for the site, guided by sustainable development principles. This effort will continue through 1999. The site manufactures enzymes through a fermentation-based process. Enzymes are chemicals comprised of large proteins, and have been used in the food and detergent manufacturing i ndustries for many years. The sites enzyme products are available in liquid or granular form. The facility operates a continuous 24-hour-per-day process and has on-shift Maintenance and Laboratory support. Staff support includes site Management, Environmental Health & Safety, Engineering, Purchasing, Finance, and Systems personnel. Ammonium hydroxide is the regulated substance under EPA Risk Management criteria. The enzyme manufacturing process requires the use of ammonium hydroxide at 29.9% concentration. Average on-site storage of ammonium hydroxide solution is 37,000 liters, equal to 21,887 pounds of ammonia content. The ammonium hydroxide storage and delivery system is the covered process for the sites Risk Management efforts and is divided into the following sections or "nodes" for the purpose of this program: 7 Truck Unloading (includes delivery truck and suction-side of unloading pump) 7 Truck Unloading (includes discharge-side of unloading pump) 7 Ammonium Hydroxide St orage Tank (49,000 liters capacity) 7 Delivery System (includes discharge line from tank; pump; and recirculation line) 7 Fermentation Vessels Chemical Safety GCIs overall approach to chemical safety is comprehensive. Systems are engineered with safety and environmental aspects in mind, with input from all affected areas of the plant prior to construction or use. The goal is to provide a safe workplace while minimizing any environmental impacts. Release prevention methods are implemented where possible, including computer controls, automation, containment of all outdoor tanks; inside sump areas; and on-site air-scrubbing and neutralization capabilities. Site senior management is committed to the implementation of site environmental health & safety programs and supports the following: The environmental health & safety budget is established to provide: 7 appropriate and adequate personal protective equipment 7 appropriate post-offer and annual medical examinations 7 training 7 ai r monitoring equipment and analysis 7 hazardous waste pick-up for a conditionally-exempt small quantity hazardous waste generator 7 Emergency Response Team equipment and supplies A site Safety Committee operates to ensure that the plant values & visions regarding safety & health are continually reinforced. Cedar Rapids Plant Values: 7 Teamwork Teamwork will be demonstrated by people working together towards a clearly communicated common goal while showing respect for one another, being committed to each others successes and trusting each other to do the right thing. 7 Ownership We believe that ownership is taking accountability to act on things that are within our control. This requires a work team that is empowered to follow through in a competent, caring and compassionate manner. 7 Quality of Life Quality of life will be demonstrated by providing a caring, compassionate balance of personal/family time, health and fitness while acknowledging other needs (customer, business, team s, etc.). Quality of life will also be enhanced by our stable employment. 7 Customer Satisfaction We will acknowledge our customer (internal & external) needs and provide our customers with a high value product, which will result in mutual benefits, fewer customer complaints, a long-term relationship and employment stability. 7 Community Involvement We value a strong commitment to community growth, supported by employee involvement and charitable contributions. 7 Trust and Integrity We will foster an environment in which all team members act openly, honestly and respectfully towards co-workers, customers, suppliers and the community. 7 Product Quality We will consistently deliver a high quality product to our customers by utilizing and maintaining our ISO procedures. 7 Challenge We will provide an environment that encourages innovation and creativity thereby allowing people to grow to their fullest potential. 7 Safety Through proactive safety measures and good housekeeping, we will w ork to ensure freedom from risk or injury to ourselves, fellow workers, suppliers, customers, community and the environment. 7 Good Opportunities Through everyones involvement, we will provide opportunities for performance recognition, career growth, skill development, employment stability, job enjoyment, competitive benefits and success. Cedar Rapids Plant Vision: We are dedicated to being a premier industrial Biotechnology manufacturing facility; consistently providing our customers the highest value products and services at the lowest manufacturing cost. We will accomplish our vision by: ^ Being a proactive, enthusiastic, innovative team committed to each others success ^ Being a safety conscious team ^ Being the role model for technical and social systems; sharing successes and building on one anothers achievements ^ Continuously optimizing our processes and work systems ^ Being focused and in alignment on common goals Thereby maximizing the value to the stakeholders. The GCI corporate EH&S vision and expectations lends guidance to site efforts. Genencor International Environmental Health & Safety Policy: Genencor International is committed to continuous improvement in environmental health and safety performance, and to being a responsible member of the world community. It is the policy of Genencor International to carry out business activities in a manner consistent with sound environmental health and safety practices and to comply with all applicable laws, regulations, and company standards. As a part of our commitment to the environment, Genencor International supports the principles of the International Chamber of Commerces (ICC) "Business Charter for Sustainable Development". The following provides guidance for achieving our environmental health and safety objectives: 7 Incorporate environmental health and safety considerations in all business operations including the development of new products and processes. This includes striving to reduce env ironmental health and safety impacts through the selection of raw materials, process design, and responsible use of resources. 7 Be a responsible community member by operating our plants and facilities in a manner that protects the environment and the health and safety of our employees and the public. 7 Utilize the principles of continuous improvement in the development and implementation of our environmental health and safety programs. 7 Communicate the environmental health and safety policy and programs to our employees, customers, and communities. 7 Foster environmental responsibility among our employees and encourage involvement in achieving our environmental health and safety goals. 7 Provide customers with information regarding environmental health and safety aspects of handling, use, and disposition of our products. New employees attend ~14 hours of initial safety training, which includes chemical awareness training as well as various OSHA and EPA-required information. Job-dut y training is ongoing for each employee and occurs with co-worker trainers utilizing training manuals and SOPs. Genencor believes in being proactive in its training endeavors and strives to encourage employees to attend specific training associated with their job duties that go above and beyond the basic job requirements. Capital projects deemed necessary for environmental, health & safety reasons are implemented and supported through the capital expenditure process. Emergency Response The site Emergency Action Plan addresses how employees shall respond to emergencies, including hazardous weather; fire; medical; building evacuation; hazardous device threat; utility failure; hazardous material spills. All employees are trained in the site Emergency Action Plan as part of the established initial safety training for new employees. The Emergency Action Plan also introduces the Emergency Response Team("ERT") function and what that groups responsibilities are. The ERT members ar e trained in Industrial Incipient Level Fire Brigade; Technical Level Industrial Chemical Spill Response; First Aid/Adult CPR; and Bloodborne Pathogens. Each year, the Emergency Response Team establishes group goals for the year. 1999 ERT goals are as follows: 7 Complete one drill per crew by designated quarter 7 Complete 3 table-top scenarios 7 Have injury-free responses to all incidents 7 Attendance: Have at least 50% attendance at all meetings so as not to have to postpone any meetings 7 EPA Risk Management Program: Review ammonia portion of facility Emergency Response Plan at Septembers ERT meeting 7 Do an educational piece before each ERT meeting (September & December) -Propane informational video to be presented at September meeting This group trains yearly as well as conducts drills and table-top scenarios to prepare for incident-handling. Outside response agencies are included when possible. On 5/3/97, the site ERT drilled with the Cedar Rapids Fire Department for an a mmonium hydroxide chemical spill scenario. This allowed both GCI and local fire department personnel to work together on an incident response and develop better ways of administering a joint incident response. On-site ERT equipment is maintained to support the ERT efforts and includes SCBAs, Level B chemical resistant suits, chemical absorbent materials, pumps & hoses, and an equipment trailer for timely response to an incident. The site Emergency Response Plan for a Hazardous Substance Release is in place to provide ERT guidance for spill operations. The Incident Command System is the designated management system for emergencies and is included in the plan. The plan outlines the responsibility of involved personnel during an incident; discusses the Incident Command System; gives instruction for securing outside emergency assistance; addresses internal and external notifications including the media/public; outlines emergency procedures for general emergency response; addresses spill control, personal protective equipment & first aid; and covers disposal & decontamination. All ERT members are trained in the site Emergency Response Plan for a Hazardous Substance Release. Incident response checklists and incident report forms are used by the GCI Incident Commander and involved personnel during incidents. Release Scenarios GCI prepared one worst-case and one alternative scenario for the ammonium hydroxide process. EPAs Risk Management Program Guidance for Offsite Consequence Analysis was used for completing both scenarios. Passive mitigation is in place in the form of containment basins and was applied to both scenarios. Administrative measures including high level alarms and tank level interlocks ensure that no more than 90% of the contents of the 49,000-liter-tank can be present on-site. Worst-Case Release Scenario The worst-case release scenario starts with a rupture in the ammonium hydroxide storage tank. The result is a release of the entire con tents of the ammonium hydroxide tank. The pool is held within the tank containment basin walls, which is considered as passive mitigation for the sake of the scenario. Data regarding the scenario is as follows: 7 The release rate of the spill, utilizing the containment basin to reduce the size of the pool, is 20 pounds per minute. 7 The distance-to-endpoint (from the spill outward) is 0.1 miles. 7 There are no environmental receptors within the spill radius. 7 The only public receptor that is in proximity of the radius is a commercial fish-feeding operation, located 0.2 miles from the facility. Since this facility was not noted on LandView III (environmental mapping software), the possibility exists that it may be on the edge of the footprint. 7 There are no residences located within the radius. Note that per LandView III, the census data is given per square mile and per "census block group centroids". Although there are no actual residences within the radius, Landview indic ates 14 people within the identified 0.1-mile-radius area surrounding GCI. Using the "Block Group Centroid Method" applied to the same radius, there were no census block group centroids found. A worst case release as described above is extremely unlikely due to a number of computer controls in place that would detect any leaks or level decrease beyond what the process calls for. In addition, computer-controlled valves and pump operation would either interlock or be manually shut in the event of a leak or spill, which would lessen the amount of material spilled into the containment basin. Alternative-Case Release Scenario The alternative-case scenario was chosen based on the results of the sites Process Hazard Analysis "significant" ratings for likelihood and severity of consequences. The raw material truck unloading area showed a "likelihood/severity rating" of "3" for contamination due to the fact that the incoming ammonium hydroxide load is out of GCIs control until it arriv es on-site. The frequency of unloading was also a consideration. The scenario starts as a tanker truck filled with ammonium hydroxide (18,000 liters; 10,648 pounds of ammonia content) pulls onto the contained unloading pad to unload the material. The coupling to the truck is attached and the program for off-loading has begun. It is at this point that the coupling dislodges and aqueous ammonia is released. The Genencor employee and the tanker driver are overcome by fumes and there is no one else in the immediate vicinity to shut off the emergency valve on the tanker. Approximately 18,000 liters of the ammonium hydroxide solution is released to the containment pad surrounding the tanker truck. . The pool is held within the truck unloading containment basin, which is considered as passive mitigation for the sake of the scenario. Data regarding the scenario is as follows: 7 The release rate of the spill, utilizing the containment basin to reduce the size of the pool, is 58 pounds p er minute. 7 The distance-to-endpoint (from the spill outward) is 0.1 miles. 7 There are no environmental receptors within the spill radius. 7 The only public receptor that is in proximity of the radius is a commercial fish-feeding operation, located 0.2 miles from the facility. Since this facility was not noted on LandView III (environmental mapping software), the possibility exists that it may be on the edge of the footprint. 7 There are no residences located within the radius. Note that per LandView III, the census data is given per square mile and per "census block group centroids". Although there are no actual residences within the radius, Landview indicates 14 people within the identified 0.1-mile-radius area surrounding GCI. Using the "Block Group Centroid Method" applied to the same radius, there were no census block group centroids found. The likelihood of the alternative scenario happening is also remote due to the preventative maintenance program in place for rout ine inspections of the ammonium hydroxide unloading line and the standard operating procedures in place for conducting the unload procedure. General Prevention Measures Genencor has a number of measures in place for spill prevention. These include, but are not limited to, an in-depth computer-tracked preventative maintenance program; standard operating procedures which are updated at least annually; employee training; back-up equipment where possible; and computer-monitored level indicators with interlocking systems when process limits are reached. The facility has 24-hour team-based process coverage in the facility, including a full-service maintenance department. The facility also operates under ISO 9002 certification which ensures among other things, that procedures are updated and used for plant operations in addition to proper handling of all documents. The presence of an Emergency Response Team (as outlined earlier) ensures that all incidents are addressed immediately to p revent an escalation of the incident if possible. Five Year Accident History There have been no accidents at the Genencor International, Cedar Rapids facility involving the ammonium hydroxide system that resulted in any on-site or off-site effects. Changes to Improve Safety A Process Hazard Analysis was conducted for the site ammonium hydroxide system in November, 1998. This was led by an experienced outside consultant and completed by a team with members representing the Job #1 and Fermentation/Media Prep process areas; Maintenance; Engineering; site Management; Laboratory; and site Environmental Health & Safety. Twelve recommendations for improvement were generated from the Process Hazard Analysis. Eleven recommended action items are complete and have been implemented; the remaining action item is scheduled for completion during the facility shutdown in August, 1999. Seven additional changes to improve safety were identified in 1998 through the completion of other Risk Mana gement elements. These changes have been completed and implemented. |