Exel Logistics - BASF Northeast Distribution Centr - Executive Summary |
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Risk Management Plan Executive Summary This Risk Management Plan ("RMP") has been completed by Regulatory Compliance Services, Inc. for Exel Logistics in compliance with the Environmental Protection Agency ("EPA") Clean Air Act, Section 112(r). Exel Logistics operates a warehouse facility with hazardous substances that are covered under 112(r). Regulatory Compliance Services, Inc. ("RCS, Inc.") has been retained by Exel Logistics to investigate this facility's need to implement a Risk Management Plan. RCS, Inc. reviewed Material Safety Data Sheets (MSDS) for all the products stored at Exel Logistics. After the product review, eighteen (18) products stored at the facility contained constituents that were listed under RMP. The second stage in completing this plan was to investigate the storage history for each constituent. After review of the inventories, two products, cyclohexylamine and vinyl ethyl ether, exceeded thresholds outlined by the EPA. This plan was created to reflect these two substances. The RMP requirements were designed to facilitate communication to responders and the public in the event of a catastrophic release of the listed substances. These requirements also insure the continuing improvement and safety of each identified process. Major facilities needing to comply with 112(r) may be defined as; a facility that is used to store large volumes of highly hazardous substances for use in manufacturing, treatment processes or bulk storage. Some of the requirements are not applicable to a closed container non-bulk facility. All items that are not applicable are provided with an explanation in the attachments to this plan. The RMP has three different models to follow when completing a plan. The models are based on types of products, processes, quantities, etc. This plan meets the requirement of Program 3. Program 3 is required if the facility is covered by Occupational Safety and Health Administration's ("OSHA") Process Safety Management ("PSM") , 29 CFR 1910.119. Exel Logistics does not exceed thresholds of highly hazardous chemicals listed in 1910.119, and does store listed chemicals in this warehouse. Inventories may fluctuate to above and below threshold levels so a PSM is warranted. 1) The accidental release prevention and emergency response policies at the stationary source. Exel Logistics operates a private, contract warehouse for BASF Corporation. The facility is located in a semi-rural area in Northeast New Jersey, 175 Raritan Center Parkway, Edison, New Jersey. Product stored in the warehouse exceeds threshold requirements outlined in the Code of Federal Regulations ("CFR") Title 40, Part 68. In fully demonstrating compliance with the standards set forth in Section 112(r) of the 1990 Clean Air Act, Exel Logistics is implementing a Risk Management Program through this Risk Management Plan. The facility is a closed-container distribution facility for appropriately marked, labeled, and packaged non-bulk product s. Some products contain substances that are considered extremely hazardous by the Environmental Protection Agency ("EPA"). These products are stored within specially designed and designated areas of the warehouse. These designated areas have been designed to store certain products, following guidelines established by Building Officials Code Association ("BOCA") 1996 Guidelines, and National Fire Protection Association ("NFPA") Guidelines. Exel Logistics is dedicated to providing a safe, publicly aware, environmentally friendly solution to logistics management. All procedures at the facility have been written to ensure employee and public safety. Procedures are continuously scrutinized and revised based on employee suggestion and management review. Employee discovery of a release of a hazardous substance would result in implementation of the emergency response procedures developed at Exel Logistics. The first step for an employee would be to immediately notify his or her supervisor. The supervisor will immediately contact the Primary Emergency Coordinator. Upon notification of a release, the Primary Coordinator will immediately contact the local fire department, the police department, the BASF Hotline, the Community Emergency Planning Committee, the New Jersey Department of Environmental Protection ("NJDEP") Emergency Hotline, and the outside response contractor. Evacuation of the facility due to a release will occur whenever directed by an alarm signal, direction from facility management or by the local response officials. The emergency coordinator will direct all incoming vehicles to the facility, for normal operations of the facility, including but not limited to shipping and receiving, away from the facility. Those vehicles will avoid roads used for emergency vehicles and the entrance to the facility to wait for further direction. 2) The stationary source and regulated substances handled. Exel Logistics is a closed container warehouse for BASF Corpor ation product. The facility does not manufacture, package, transfer, or otherwise deal with raw product. Therefore, the facility only has one process that deals with hazardous substances regulated by the Risk Management Program. The process includes the entrance of trucks containing containerized product, unloading the trailers using motorized forklifts, storage of the product in designated areas within the warehouse, loading the trailers with motorized forklifts, and the exit of the trucks from the property. The products that are stored at this facility are varied in concentrations, physical states, and constituents. Only a small amount of the products in the warehouse contain regulated hazardous substances. Due to the constant change in inventory driven by the industry demand for BASF product, Exel Logistics does not have a steady amount of regulated substances in the warehouse. To determine the maximum amount of the regulated substances stored in the building, a review of product inventories was conducted to achieve a historical maximum storage. The maximum storage was used to calculate possible quantities that may be released. During a review of all the products, including constituents and concentrations, it was determined that cyclohexylamine, CAS # 108-91-8 and vinyl ethyl ether, CAS # 109-92-2 are above the thresholds designated by the EPA. The quantity of cyclohexylamine is 31433.95 pounds and the quantity of vinyl ethyl ether is 27337.02 pounds. 3) Worst-case release scenario and the alternative release scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario. Cyclohexylamine is governed under the toxic substance category in the RMP. The worst case scenario would be a comprehensive incident, an "act of God" that is not controlled by Exel Logistics. In this worst case scenario, the only mitigating measures would be the internal containment of the building. Each room has a containment of 37, 000 gallons, with an overflow capacity of 150,000 gallons within the building. If the product vaporized and could escape the confines of the building structure, under worst case weather conditions it would travel 1.4 miles before dispersing enough to no longer pose a hazard to the public. The endpoint distance was calculated using the EPA's Offsite Consequence Analysis (OCA) guidance. The alternative release scenario for toxic substances would be a comprehensive incident, an "act of God' that is not controlled by Exel Logistics. This may cause for destruction of forty 55-gallon drums in co-location. In this alternative release scenario, no mitigating measures are present to contain the release. The dispersion cloud would travel 0.19 miles before dispersing enough to no longer pose a hazard to the public. The endpoint distance was calculated using the EPA's Offsite Consequence Analysis (OCA) guidance. Vinyl ethyl ether is governed under the flammable substance category in the RMP. The worst case scenario would be a comprehensive incident, an "act of God" that is not controlled by Exel Logistics. In this worst case scenario, the only mitigating measures would be the internal containment of the building. Each room has a containment of 45,000 gallons, with an overflow capacity of 150,000 gallons within the building. If the product vaporized and could escape the confines of the building structure, under worst case weather conditions it would travel 0.22 miles before dispersing enough to no longer pose a hazard to the public. The endpoint distance was calculated using the EPA's Offsite Consequence Analysis (OCA) guidance. The alternative release scenario for flammables would be a comprehensive incident, an "act of God" that is not controlled by Exel Logistics. This may cause for destruction of forty 55-gallon drums in co-location. In this alternative release scenario, no mitigating measures are present to contain the release. The dispersion cloud would travel 0.17 mile s before dispersing enough to no longer pose a hazard to the public. The endpoint distance was calculated using the EPA's Offsite Consequence Analysis (OCA) guidance 4) The general accidental release prevention program and chemical specific prevention steps. Exel Logistics is compliant with The Occupational Safety and Health Administration's ("OSHA") Process Safety Management ("PSM") rule, and Environmental Protection Agency's ("EPA") Risk Management Plan ("RMP"). In addition, this facility does extensive training, procedural reviews, and complies with the requirements of this rule. Upon hiring, and every year there after, each employee is given Department of Transportation ("DOT") hazardous materials training, OSHA Hazard Communication ("HAZCOM") training, and EPA Right-To-Know ("RTK") training. In addition, all new employees are given additional training regarding Personal Protection Equipment ("PPE") use and maintenance, loading and unloading, handling of material, forklift ope ration, emergency response, and evacuation procedures. This facility has also developed a safety committee. The safety committee is comprised of workers and management that meet once a month. The purpose of the safety committee is to review any incidents that may have occurred and discuss safety related issues in the facility. All issues are addressed and discussed until a viable solution is derived. All safety committee information is documented and recorded. 5) The five-year accident history. Exel Logistics has been operational since October 1996. Due to the nature of the processes, extensive training, and thorough operating procedures, this facility has not had a release in the past five years. 6) The emergency response program. Exel Logistics has an emergency response program in place. This plan describes the procedures to be implemented as a result of a release. Twice per year, the facility runs mock evacuations based on a release or fire. All mock evacuations are reviewed for effectiveness. In addition, Exel Logistics has developed and implemented a Discharge Prevention Control and Countermeasures/Discharge Cleanup and Removal ("DPCC/DCR") plan. This plan is registered with the State of New Jersey. 7) Planned changes to improve safety. Exel Logistics is continually reviewing and altering procedures and processes to improve performance and safety. At this time, the facility will not be planning drastic changes to building structure, grounds, or mitigation systems. |