Bayer Corp.-Pharma Division, West Haven CT - Executive Summary |
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General Executive Summary for Ammonia Refrigeration Facilities 1. Accidental Release Prevention and Emergency Response Policies We at Bayer Corporation-Pharmaceutical Division, West Haven, CT are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program 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. Unforeseeably, if such a release does occur, our highly trained emergency response personnel are at hand to control and mitigate the effects of the release. We are also completely coordinated with West Shore Fire Department, which provides additional emergency response expertise. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompa ss manufacturing, research and development of pharmaceutical products. We have (one) 1 regulated substance present at our facility. This substance is Ammonia. The regulated substance at our facility is used for Refrigeration purpose only. The total inventory of Ammonia at our facility is 70,000.00 lb. 3. 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 evaluate the worst case scenarios, we have used the tables in the EPA's RMP Guidance for Ammonia Refrigeration Facilities. For alternative release scenario analysis, we have employed the tables and methods in the EPA's RMP Ammonia Refrigeration Guidance. 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 a storage or receiving vessel in the Refrigeration System . The scenario involves the release of 15,000.00 lb. of Ammonia in a gaseous form over 10 minutes. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 0.80 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. The maximum distance to endpoint was calculated using EPA's Guidance on Effectiveness of Building Mitigation for Worse-Case Scenario (dated November 19, 1998). One alternative release scenario has been submitted for the toxic substance present in Program 3 process. The alternative release scenario for Ammonia involves a release from Central Utilities Plant (CUP) B-45 in the Refrigeration System process. The scenario involves the release of 65.00 lb. of Ammonia in a gaseous form over 2 minutes due to rupture disk/ relief valve opening as a result of overpressure during re-start-up. Passive mitigation controls such as dikes, enclosures, sumps, berms and 24-hour monitoring are taken into account to calculate the scenario. The relea se is also assumed to be controlled by active mitigation measures that include sprinkler system(s), deluge system(s), water curtain(s), scrubbers, neutralization and emergency shutdown systems. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia is 0.04 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirement set out under 40 CFR part 68 of the EPA. A single of process at our facility is subject to the OSHA PSM standard under 29 CFR 1910.119. Our facility is also subject to EPCRA Section 302 notification requirements. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Bayer Corporation-Pharmaceutical Division, West Haven, CT maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all process. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our process is identified and controlled efficiently. The methodology used to carry out these analyses is "HAZOP". The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of five (5) 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-Pharmaceutical Division, West Haven, CT 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 in formation is regularly reviewed and is readily accessible to operators involved in the process. Training Bayer Corporation-Pharmaceutical Division, West Haven, CT has a comprehensive training program in place to ensure that employees who are operating processe are 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. Refresher training is provided at least every one (1) year and more frequently as needed. Employees also actively participate in various safety reviews eg. PHA's, and pre safety startup reviews. Mechanical Integrity Bayer Corporation-Pharmaceutical Division, West Haven, CT carries out highly documented maintenance checks on process equipment to ensure proper operations. 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-Pharmaceutical Division, West Haven, CT 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 promptly 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-Pharmaceutical Division, West Haven, CT. These reviews are conducted to co nfirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Bayer Corporation-Pharmaceutical Division, West Haven, CT 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-Pharmaceutical Division, West Haven, CT 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 the 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-Pharmaceutical Division , West Haven, CT truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. 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-Pharmaceutical Division, West Haven, CT has a strict policy of informing the contractors of known potential hazards related the contractor's work and the process. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five -year Accident History Bayer Corporation-Pharmaceutical Division, West Haven, CT has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, we have not had a Federally reportable release during the past five years. 6. Emergency Response Plan Bayer Corporation-Pharmaceutical Division, West Haven, CT maintains 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 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 process that would require a modified emergency response. West Haven LEPC is the Local Emer gency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. The reduction of Ammonia inventory is one of the major steps we want to take to improve safety at our facility. This change was implemented during December 1998. Our Ammonia inventory was reduced by 30,000.00 lb. and confined to a single building, the Central Utilities Plant (CUP). |