Aldrich Chemical Company, Inc.-Sheboygan - Executive Summary |
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Aldrich Chemical Company-Sheboygan Site Risk Management Program (RMP) Plan Executive Summary Site and Process Description Aldrich Chemical is a batch manufacturer and repackager of fine organic chemicals for use in research and industry. Our Sheboygan facility consists of a series of one to five story masonry and steel buildings encompassing 332,000 square feet on a 513 acre site. These buildings house a variety of manufacturing, packaging, warehousing and administrative operations. Also present at the site are tanks for the outside storage of liquid nitrogen and various solvents. There are six major chemical operations conducted at the site. Each major operation is housed in its own building and is described below. Production II Building - (Pro II) batch manufactures fine organic chemicals. A majority of these products are for human use and are made under strict Good Manufacturing Practices (GMP). Process equipment in Pro II ranges in size from 1 liter to 2,000 gallons. Th ere is a warehouse associated with Pro II used for staging starting materials and storing product. Production III Building - (Pro III) is the site for production of "air sensitive" materials. Air-sensitive materials must be handled under an inert atmosphere (nitrogen or argon) since they react rapidly with oxygen and/or moisture in the air. Pro III produces about 370 different products in vessels ranging in size from 30 to 800 gallons. Pro III also has large scale distillation, drying and workup capabilities. There is a warehouse associated with Pro III used for staging starting materials and storing product. Production IV Building - (Pro IV) This operations main function is to produce and package organic solvents. The production area uses a variety of techniques to purify crude organic solvents, such as acetone and toluene by removing impurities and/or water. Pro IV produces about 430 solvent listings in stills ranging in size from 100 to 1,000 gallons. There is a warehouse as sociated with Pro IV used for staging starting materials and storing product. Packaging III Building - (Pac III) enables the Packaging Department of have filling, labeling, overpacking and warehouse facilities under one roof. Filling procedures are performed in separate areas: a Bulk Fill Room for handling large containers, an Air-Sensitive Solids room, Air-Sensitive Fill Rooms, Gas Filling, and a Corrosive Fill Room. Containers of up to 850 liters are handled during filling operations. The Quality Control, Shipping/Receiving, and Administrative Departments are also housed in this building. Lab 1 Building - (Lab 1) is responsible for the production and development of new products. Overall, approximately 930 products are manufactured in glassware ranging from 1 liter to 50 liters in volume. Mini-BulkTM operations repackage larger quantities of chemicals from ISO Tanks and Tank Trucks into smaller containers, which range up to 800 liters in size. The Mini-BulkTM facility was a dded onto the Pro IV warehouse and is designed to accommodate up to 5,000 gallon ISO Tanks/Tankers. Summary of Major Hazards Under RMP Aldrich Chemical has identified 11 processes which are potentially major hazards. Analysis of the worst-case release scenario for each process shows no offsite consequences as defined under RMP. A brief description of these processes is given below. Processes 1-8 involve toxic chemicals and processes 9-11 involve flammable chemicals. 1) Allyl alcohol is repackaged in a Mini-BulkTM operation from an ISO tank (18,000 liter capacity) into smaller containers. The smaller containers can range up to 850 liters in size. Diking and a concrete sump are provided at the tanker unloading area. This limits the exposed surface area of the pool and thus reduces the release rate to 1.75 lbs/minute or less. 2) Acetaldehyde is repackaged in a Mini-BulkTM operation from an ISO tank (18,000 liter capacity) into smaller containers. The smaller containers can r ange up to 850 liters in size. Diking and a concrete sump are provided at the tanker unloading area. This limits the exposed surface area of the pool. 3) Chloroform is stored in the Pro IV warehouse in 55 gallon drums either as a finished product or as a starting material. 4) Ethyl ether is stored in the Pro IV warehouse in 55 gallon drums either as a finished product or as a starting material. 5) Propylene oxide is repackaged in a Mini-BulkTM operation and stored in the Pro III warehouse in containers up to 400 liters. 6) Titanium tetrachloride is stored in Pac III in 118 liter containers. 7) Acrylonitrile is repackaged in a Mini-BulkTM operation from an ISO tank (18,000 liter capacity) into smaller containers. The smaller containers can range up to 400 liters in size. Diking and a concrete sump are provided at the tanker unloading area. This limits the exposed surface area of the pool and thus reduces the release rate to 3.09 lbs/minute or less. The worst-case scenario is t herefore a release from a 400 liter container where there is no sump or diking to contain the acrylonitile. In this case the maximum release rate is 5.35 lbs/minute. 8) Epichlorohydrin is repackaged in a Mini-BulkTM operation from an ISO tank (18,000 liter capacity) into smaller containers. The smaller containers can range up to 850 liters in size. Diking and a concrete sump are provided at the tanker unloading area. This limits the exposed surface area of the pool and thus reduces the release rate to 0.757 lbs/minute or less. 9) Vinylidene chloride is repackaged in a Mini-BulkTM operation from a tanker (5,000 gallon capacity) into smaller containers. The smaller containers can range up to 850 liters in size. Diking and a concrete sump are provided at the tanker unloading area. This limits the exposed surface area of the pool. 10) Hydrochloric acid is stored in the Pro II warehouse in 55 gallon drums. 11) Pentane is stored in the Pro IV warehouse in 55 gallon drums. Five-yea r Accident History During the past five years there have been no accidental releases from any RMP covered process which resulted in deaths, injuries, or significant property damage on-site. There have been no releases off-site. Consequences of Failure to Control the Hazards Analyses have been made for each chemical of the worst-case release scenario in which the entire contents of the largest container are spilled. In all cases the hazard zone was contained onsite. Aldrich employees could be affected if a worse-case release scenario occurs. The effects of any release onsite will be minimized by several factors including: 1) Emergency response team, 2) Site wide alarm & PA system and 3) Employee training (ie. evacuation drills, safety training, contingency plan training). These factors are elaborated upon in the Response Action in the Event of a Release section. Prevention of Releases Aldrich has put in place several measures to improve operations, improve safety and red uce the risk of a release. More Process Hazard Analyses (PHAs) have been conducted than required under OSHA's Process Safety Management (PSM) rule and EPA's RMP. Recommendations from these PHAs have been enacted to reduce the probability of a release. Periodic testing of pipeline thickness and an automated emergency shutdown system for Mini-BulkTM operations are two examples of recommendations which have been enacted. Other measures which Aldrich takes to reduce the probability of a release include: 1) Regularly scheduled maintenance of operating equipment 2) Regular review of operating procedures 3) Regular training of operators 4) Institution and enforcement of hot work & line entry programs There are also systems in place at Aldrich to mitigate a chemical release. All Mini-BulkTM operations are conducted in areas which have dikes and sumps. Chemicals are processed and stored in areas which are electrically rated and have been designed to meet National Fire Protection A ssociation (NFPA) guidelines. Steps Taken to Address Hazards Several steps are being taken by Aldrich to continually improve safety at the Sheboygan site and reduce the risk of a release. The PHAs mentioned above are revisited at least every five years. Routine safety inspections are performed by the operating departments. The site safety committee audits these safety inspections. Aldrich has an incident investigation system in place. Lessons learned from incidents are passed along to the other operating departments. Each department has a set of standard operating procedures (SOPs) written by operators which are reviewed and approved by department management and the safety department. The SOPs are routinely reviewed to ensure they are current and account for any new hazards. Response Action in the Event of a Release Aldrich has an emergency response team to respond to releases. The response team is capable of level A entries and is staffed on all three shifts. Month ly meetings are held for training in response procedures. The response team has equipment housed in a trailer for use anywhere onsite. Extra equipment is kept in each of the operating buildings. A site contingency plan details the actions of the response team, other employees, and visitors during a release or other emergency. The plan provides phone numbers for contacting outside response agencies. Aldrich has coordinated its emergency response procedures by providing the outside response agencies with copies of the contingency plan, drilling with the Sheboygan HazMat team and pledging mutual support with the local fire department. |