Pharmacia & Upjohn Caribe, Inc. - Executive Summary

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The previously submitted Risk Management Plan's (RMP) Executive Summary under EPA ID# 1000-0014-8431by Pharmacia & Upjohn Caribe, Inc. (P&UCI), postmarked received on 6/21/1999 is hereby modified by including Hydrochloric Acid as an additional regulated substance handled at our facilities and affected by 40 CFR Part 68.  Therefore, the referred Executive Summary is modified as follows: 
 
DESCRITPION OF STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED [40 CFR 68.155(b)] 
 
P&UCI operates two (2) processes that use RMP-regulated substances which exceed the corresponding threshold quantity.  These two processes are: 
 
1. Clindamycin Phosphate:  Both phosphorus oxychloride and hydrochloric acid are used as ingredients during the manufacture of Clindamycin Phosphate.  This process stores as much as 19,000 pounds of phosporus oxychloride and 24,000 of hydrochloric acid.  Phosphorus oxychloride is stored in 55-gallon drums at the main materials storage warehouse (M-10) and is delivered by finge 
rlift to the production building (M-50).  Hydrochloric acid is stored in a vertical aboveground tank with capacity of 7,500 gallons located on the east side of building M-50. 
 
WORST-CASE/ALTERNATIVE RELEASE SCENARIOS [40 CFR 68.155(d)] 
 
Alternative Release Scenario: 
 
C. Hydrochloric Acid- Hydrochloric acid is used during the Clindamycin Phosphate process.  The alternate scenario evaluated presents a rupture of the storage tank and release of the entire tank contents (7,500 gallons) inside the diked area within 1 minute. 
 
The Comp Ver 1.06 model predicted a distance of 0.2 miles to the toxic end point for hydrochloric acid 
 
Only the above changes related to the inclusion of Hydrochloric acid apply.  The remaining information previously provided remain unaltered.
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