BioLab Incorporated - Executive Summary |
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Risk Management Plan Executive Summary for the Great Lakes Chemical BioLab Adrian Michigan Plant 1. Accidental Release Prevention and Emergency Response Policies We at BioLab Incorporated are strongly committed to employee, public and environmental safety. This commitment is inherent to a comprehensive accidental release prevention program in place 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 Adrian Fire Department which provides additional emergency response expertise. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass sy nthesis of organic chemicals. We have three regulated substances present at our facility. These substances include bromine, chlorine and ammonia. The regulated substances at our facility are involved in several uses. Bromine is used for chemical synthesis. Chlorine is used for chemical synthesis. Ammonia is used for water neutralization and chemical synthesis The maximum inventory of bromine at our facility is 235,000 lb. while chlorine and ammonia are present at our facility in quantities of 180,000 lb. and 70,000 lb. respectively. 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 perform the required off-site consequence analysis for our facility, we have used the look-up tables and equations provided by the EPA in the RMP Off-site Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for the Program 3 toxic substances as a class involves a catastrophic release from the BCDMH Process. The scenario involves the release of 180,000 lb. of chlorine in a gaseous form over 10 minutes. At Class F atmospheric stability and 1.5 m/s wind speed, the maximum distance of >25 miles is obtained corresponding to a toxic endpoint of 0.0087 mg/L. One alternative release scenario has been submitted for each toxic substance present in the Program 3 processes. The alternative release scenario for bromine involves a release from the bromine rail unloading area in the BCDMH process. The scenario involves the release of 263 lb. of bromine. Toxic liquid is assumed to be immediately released to form a pool of height 1 cm, from which evaporation takes place. The entire pool is estimated to have evaporated over 11.53 minutes. The release is also assumed to be controlled by active mitigation measures that include an application of water to the spill an d an emergency shutdown system. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0065 mg/L of bromine is 0.68 mile. The alternative release scenario for chlorine involves a release from the chlorine unloading area in the BCDMH process. The scenario involves the release of 201 lb. of chlorine in a gaseous form over 10 minutes. The release is also assumed to be controlled by active mitigation measures that include an emergency shutdown system. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.0087 mg/L of chlorine is 0.74 mile. The alternative release scenario for ammonia involves a release from the ammonia storage tank in the Wastewater Treatment process. The scenario involves the release of 100 lb. of ammonia. Toxic liquid is assumed to be immediately released to form a pool of height 1 cm, from which evaporation takes place. The entire pool is estimated to have evaporated over 10 minutes. Passive mitigation con trols such as dikes are taken into account to calculate the scenario. The release is also assumed to be controlled by active mitigation measures that include excess flow valves and an emergency shutdown systems. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of ammonia is 0.19 mile. 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 requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with State Building Codes. A number of processes at our facility are 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 B ioLab Incorporated maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all covered processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is, generally a modified what if checklist. 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 years or whenever significant process changes occur. Any findings related to the hazard analysis are subsequently addressed. Operating Procedures For the purposes of safely conducting activities within our covered processes, BioLab Incorporated maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, te mporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to affected operators. Training BioLab Incorporated has a comprehensive training program in place to ensure employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every three years and more frequently as needed. Mechanical Integrity BioLab Incorporated carries out 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 training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipmen t deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at BioLab Incorporated 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 provided 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 at BioLab Incorporated. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits BioLab Incorporated 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 completed. Incident Investigation BioLab Incorporated 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 BioLab Incorporated believes 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, safety performance of the contractor is evaluated. BioLab Incorporated has a strict policy of informing contractors of known potential hazards related to the contractor's work and site processes. Contractors are also informed of emergency response procedures should an accidental release of a regulated substance occur. 5. Five-year Accident History BioLab Incorporated has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan BioLab Incorporated has developed 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 and the public, a s 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 processes that would require a modified emergency response. Lenawee County is the Local Emergency 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 Great Lakes Chemical BioLab Adrian Plant plans to continuously improve and update operating procedures, replace or maintain equipment to original specifications or design codes and develop and implement safety improvement capital projects. These are some of the major steps we want to take to improve safety at our facility. These changes are expected to be implem ented by 12/31/98. 8. Certification Statement The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. Name: Signature: Title: Date signed: |