BAXTER CARIBE, INC. - Executive Summary |
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BAXTER CARIBE, INC., A SUBSIDIARY OF BAXTER HEALTHCARE PRODUCTS, MANUFACTURES ANESTHETICS IN ITS FACILITIES LOCATED IN STATE ROAD 3, KM. 142.5, IN GUAYAMA, PUERTO RICO. ITS STANDARD INDUSTRIAL CLASSIFICATION CODE (SIC) IS 2834. AS PART OF ITS MANUFACTURING PROCESSES, THE FOLLOWING REGULATED SUBSTANCES ARE MANAGED AT THE FOLLOWING COVERED PROCESSES IN THE FOLLOWING MAXIMUM QUANTITIES (IN LBS): 1) HYDROFLUORIC ACID, ANHYDROUS 100% CAS NO. 7664-39-3: THIS SUBSTANCE IS FOUND ABOVE TRESHOLD LIMITS IN THE MANUFACTURING PROCESS KNOWN AS DESFLURANE (1,158 LBS.) AND IN TANK FARM , IN ONE OF TWO 8,000 REFRIGERATED STORAGE TANKS (65,000 LBS.) 2) CHLORINE CAS NO. 7782-505 THIS CHEMICAL IS HANDLED AS A LIQUEFIED GAS IN 2,000 LBS. PRESSURIZED CYLINDERS. CHLORINE ABOVE ITS TRESHOLD LIMIT IS MANAGED AT THE STORAGE RACK WHERE A MAXIMUM OF 72,000 LBS. MAY BE PRESENT, AND AT THE CHLORINATOR ROOM WITH TWO CYLINDERS NORMALLY CONNECTED TO A CHLORINATOR INSIDE A CLOSED ROOM. BAXTER HAS USED THE OFFSITE CONSEQUENCE ANALYSIS GUIDELINES PUBLISHED BY THE USEPA AS OF APRIL 15, 1999 FOR THE REQUIRED ANALYSES. THESE GUIDELINES RECOGNIZE THE OVERPREDICTION BY THE METHODOLOGY USED OF OFFSITE CONSEQUENCES AND THE DISTANCES TO ENDPOINTS, INDICATING THAT DISTANCES ABOVE 6 MILES "SHOULD BE VIEWED AS VERY COARSE ESTIMATES OF CONSEQUENCE DISTANCES". THE WORST-CASE SCENARIO FOR HYDROFLUORIC ACID, ALTHOUGH NOT REPRESENTING THE LARGEST VESSEL ON SITE, SHOULD REFLECT MOST SIGNIFICANT OFFSITE IMPACT, AND INVOLVES THE RELEASE OF THE FULL CONTENTS OF A 5,000 GALS PORTABLE TANK IN 10 MINUTES, WITH A RESULTING RADIUS OF IMPACT OF 14 MILES. FOR CHLORINE, THE RELEASE FROM A 2,000 LBS TANK USING CHEMICAL-SPECIFIC TABLE S RESULTED INTO DISTANCE TO TOXIC ENDPOINT OF 1.3 MILES. FOR ALTERNATIVE SCENARIOS, THE SAME TWO SITUATIONS WERE CONSIDERED, BUT INCORPORATING ACTUAL CONTROLS AND MORE REALISTIC SITUATIONS. THE RESULTING DISTANCES TO TOXIC ENDPOINTS ARE, FOR CHLORINE, 0.1 MILES, AND FOR HYDROFLUORIC ACID, 1.7 MILES. BEING SUBJECT TO PSM REQUIREMENTS UNDER OSHA'S 29 CFR 1910.119, ALL COVERED PROCESSES FALL UNDER THE REQUIREMENTS OF A PROGRAM 3 PREVENTION PROGRAM. THE FOLLOWING ELEMENTS ARE IN EFFECT FOR ALL PROCESSES WITHIN BAXTER, INCLUDING COVERED PROCESSES. STANDARD OPERATING PROCEDURES GOVERN MOST OF THE ACTIVITIES CONDUCTED IN BAXTER. THE ONSITE ENGINEERING DEPARTMENT MAINTAINS A COLLECTION OF DOCUMENTS AND DRAWINGS WHICH CONTAIN INFORMATION ON THE PROCESSES, PROCESS EQUIPMENT AND DESIGN CODES AND PARAMETERS, AMONG OTHERS. MATERIAL BATCH RECORDS (MBR) UNDER THE CUSTODY OF QA/QC PROVIDE SPECIFIC INSTRUCTIONS FOR THE DIFFERENT STEPS IN EACH MANUFACTURING PROCESS. AN SOP GUIDES THE PROCESS HAZARDS ANALYSES USING THE METHODOLOGY OF HAZARD AND OPERABILITY STUDIES (HAZOPS). TRAINING OF PLANT PERSONNEL IS BASED ON CURRICULAE DEVELOPED FOR THE DIFFERENT POSITIONS/RESPONSIBILITIES, USING CONTRACTED OR ONSITE RESOURCES. TRAINING RECORDS ARE MAINTAINED IN HARD COPY AND BY A COMPUTERIZED SYSTEM KNOWN AS "TRIM". AGGRESSIVE PREVENTIVE MAINTENANCE IS CONDUCTED UNDER A FORMAL PREVENTIVE MAINTENANCE PROGRAM WHICH INCLUDES CORRESPONDING SOPS. SHUTDOWNS ARE SCHEDULED THROUGHOUT THE YEAR. MECHANICAL INTEGRITY TESTING IS CONDUCTED BASED ON THE REQUIREMENTS BY APPLICABLE DESIGN CODES, STANDARDS AND REGULATIONS., BY SPECIALIZED CONTRACTORS (I.E., BOILERS AND PROCESS VESSELS) AND BY ONSITE PERSONNEL. STANDARD OPERATING PROCEDURES ARE ALSO IN EFFECT FOR PRE-STARTUP REVIEWS, MANAGEMENT OF CHANGE, HOT WORK PERMITS, INCIDENT INVESTIGATIONS, EMPLOYEES PARTICIPATION AND CONTRACTORS' SAFETY. COMPLIANCE AUDITS FOR RMP PROGRAM ELEMENTS WILL BE IMPLEMENTED NOT LATER THAN 3 YEARS FROM JUNE 21, 1999. ALL STANDARD OPERATING PROCEDURES AND MAINTENANCE PROCEDURES ARE SUBJECT TO 18-MONTHS REVISION CYCLES WHEN THEY ARE AUTOMATICALLY DUE FOR REVISION. FULLY EQUIPPED AND TRAINED EMERGENCY RESPONSE BRIGADES WILL RESPOND TO ALL RELEASE INCIDENTS. THE SPCC PLAN LAST REVISED IN 1998 PROVIDES PROCEDURES FOR RESPONDING TO THESE EMERGENCIES, INCLUDING NOTIFICATIONS TO THE COMMUNITY AND SUMMONING EMERGENCY MEDICAL ASSISTANCE. SOPHISTICATED SYSTEMS OF DETECTORS, ALARMS, AND FIRE FIGHTING EQUIPMENT HELP REDUCE THE EFFECT OF ANY RELEASES. BAXTER HAS BEEN AN ACTIVE PARTICIPANT IN THE LEPC FOR GUAYAMA SINCE ITS APPOINTMENT IN 1987. COORDINATION FOR EMERGENCIES IS ACCOMPLISHED BY MEETINGS WITH STATE FIRE DEPARTMENT AND OTHER EMERGENCY GROUPS. |