Fisher Scientific Company - Somerville Site -USEPA - Executive Summary |
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BACKGROUND Fisher Scientific is the world leader in serving science. Fisher began its operations in Somerville in early 1970. Today, the Somerville Site receives, repackages, and distributes chemical products to research, healthcare, industrial, educational, and government facilities. Fisher is also a leading supplier of occupational health and safety products and maintenance, repair and operating materials. The Somerville Site consists of two main buildings situated on 41 acres. The site consists of offices, maintenance shops, quality control laboratories, repackaging systems, and warehouse storage areas. The facility operates 24 hours per day, 5 days per week, and employees 160 people. FACILITY OVERVIEW The Somerville Site has two primary functions: to receive and repackage chemical products, and; to distribute those products to its customers. The receiving and repackaging area is known as the Bridgewater Packaging Facility. The Repackaging Facility receives chemical produ ct in various containers, ranging from 55-gallon drums to rail car quantities. Product is repackaged into containers of various sizes, ranging from milliliter size to drum and tote containers. Repackaged product is then stored in, and distributed from the National Distribution Center. The Distribution Center consists of warehouse storage, including fire-rated concrete storage vaults, used for flammable material storage. Product is shipped primarily by tractor-trailer. The Somerville Site handles hazardous materials as defined by both the US Environmental Protection Agency (USEPA) and the New Jersey Department of Environmental Protection (NJDEP). The NJDEP and USEPA regulations are designed to minimize the potential for an accidental release associated with handling hazardous materials. Additionally, the US Occupational Safety and Health Administration (OSHA) implements accident prevention regulations designed to protect employees. The Somerville Site handles eight materials that are regulated substances under the NJDEP and USEPA regulations. This submission includes a "predictive filing" for ammonium hydroxide (29%). While the site currently has an inventory less than the threshold quantity, this registration lists the threshold quantity in the event inventory increases. For this USEPA submission, ammonium hydroxide (CAS # 1336-21-6) is registered as ammonia (conc. 20% or greater, CAS # 7664-41-7), since the correct CAS # (1336-21-6) is not on the USEPA list of covered materials. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Fisher Scientific has established a number or safety and environmental programs designed to ensure safe operation of the Somerville Site. Existing environmental policies address accident prevention, spill control and containment, and air and water pollution control. Safety policies exist to ensure the safety of our employees and to minimize the potential for accidental releases. The Somerville Site's emergen cy response plan specifies plans to follow in the event of a plant emergency. Our emergency response activities are coordinated with local response agencies to help ensure a coordinated response, and thereby maximize community safety. POTENTIAL RELEASE SCENARIOS NJDEP and USEPA accident prevention regulations require companies to analyze what is defined as a worst-case release scenario. We are also required to analyze an alternative release scenario. The worst-case scenario as defined by the NJDEP and USEPA, is the sudden loss of containment of all of the product in the largest tank or vessel at our facility. At the Somerville Site, this scenario postulates the sudden release of chloroform from a catastrophic rail car failure, or the sudden release of ethyl ether from a catastrophic tank truck failure. We are required to assume that the numerous safety and alarm systems we have in place fail to operate as designed. We must also assume that this hypothetical release occurs durin g the least likely weather conditions minimizing the effects of wind to dissipate the vapor cloud, meaning very low wind speeds and a stable, or stagnant atmosphere. This worst-case scenario therefore assumes that several highly unlikely events as described below occur simultaneously: 7 Catastrophic failure of a vessel; 7 Failure of all automated safety and alarm systems; 7 Failure of our trained and experienced operators to respond appropriately; and 7 The event occurs during least likely, stagnant meteorological conditions. We are required to analyze such a release and to estimate the potential affect on the surrounding community. A release of this nature, while highly unlikely, could potentially reach offsite endpoints and nearby public receptors. The likelihood of the worst case release scenario is believed to be low, because it is expected that at least some of the protective equipment and measures will function as designed, and our trained operators would respond in a timel y fashion. Alternative release scenario must also be considered to depict a potential release that theoretically has a greater possibility of occurring, but will likely have a less severe impact than the worst-case scenario. Alternative release scenarios at the Distribution Center considered container failures in the warehouse area. Other alternative release scenarios considered were line leaks during material transfer from the chloroform rail car and the ethyl ether tank truck. The alternative scenarios have a significantly reduced affect on the surrounding community. FIVE-YEAR ACCIDENT HISTORY There have been no significant releases of any of the regulated materials in the last five years of plant operation. A significant release would include a release resulting in some type of offsite impact including injuries, evacuations, or environmental damage, or onsite injuries or significant property damage. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAMS Our Site Operations Mana ger has the overall responsibility for ensuring that the facility operates in a safe and reliable manner. This responsibility includes overseeing the implementation of our risk management program (RMP). Fisher has developed programs to comply with all required environmental, health, and safety standards. We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our process management systems address each of the key features of successful accident prevention programs, including: - Process safety information - Pre-startup review - Process hazard analysis - Compliance audits - Operating procedures - Accident investigation - Training - Employee participation - Mechanical integrity - Hot work permit - Contractor safety - Management of change These individual elements of our risk management program work together to prevent accidental chemical releases. CHEMICAL SPECIFIC PREVENTION STEPS In addition to our management programs, we have design ed both passive and active mitigation systems to control, prevent, detect, and mitigate potential accidental releases. Passive mitigation includes those design features that are essentially "fail-safe". In other words, they will successfully operate to control or contain a potential release, without the need for electrical power or worker intervention. Passive mitigation includes our state-of-the-art spill control and containment system: our rail car area, tank truck area, and storage tanks are protected with secondary containment to contain and divert potential spills to a controlled area. Our active mitigation systems include level controllers on our storage tanks and automatic shutoffs to prevent vessel overfilling. Our property is protected by firewater and sprinkler systems, inspected annually by an outside independent company. EMERGENCY PREPAREDNESS AND RESPONSE Fisher has a fully developed emergency response plan detailing procedures to respond to accidental releases and other emergencies. Our plan is tested on a regular basis through exercises and drills. Our plan has been shared with the Bridgewater Fire Department to help ensure a coordinated response. In the event of an emergency affecting our local community, Fisher works closely with local, county, and state agencies to help ensure public safety. These agencies take the lead in informing the public on appropriate actions in the event of an emergency. For additional information on what actions to take in the event of an emergency, contact the Bridgewater Fire Department. PLANNED CHANGES TO IMPROVE SAFETY Fisher Scientific has created a culture that strives for continuous improvement of its safety program. We train our employees to safely perform their assigned tasks. We also encourage our employees to suggest changes or improvements that will help improve safety and performance. We perform preventive maintenance to minimize the potential for unanticipated failure of operating equipment. Our systems and programs are audited annually, typically by an outside company, to evaluate their effectiveness. We have recently reviewed and modified our prevention program elements, including written operating procedures, mechanical integrity programs, management of change program, and our emergency response plan. We are presently reviewing recommendations identified during process hazard analyses of our equipment and procedures, performed by an independent expert with the participation of our facility personnel. |