VWR Scientific Products Corp. - Executive Summary |
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VWR Scientific Products (VWR) is a distributor of high-quality chemicals and laboratory supplies. The chemical products sold by VWR are received from manufacturers in U.S. Department of Transportation (DOT)-approved containers (typically ranging from 1 gallon to 55 gallons in volume). VWR does not manufacture, formulate or otherwise engage in direct handling of chemicals outside of the containers in which the chemicals are received. VWR operations consist of warehousing and distribution activities, and the risk of a serious chemical-related emergency is low. However, VWR has a strong commitment to the safety and well-being of its employees, the environment and the surrounding community. The company has established a management system, consisting of policies, procedures, training, inspection, maintenance and other elements that are designed to prevent incidents from occurring. In the event a minor or major emergency does occur, facility personnel have been trained to effectively m anage the incident. All warehousing operating involving regulated chemicals are considered a single "covered process" for regulatory purposes. The VWR facility is considered to be covere under the Program 2 eligibility requirements (per 68.10(c)) because VWR is not covered by one of the SIC codes listed under Program 3 nor OSHA's Process Safety Management requirements. At the present time, only Ethyl Ether exceeds the Threshold Quantity (TQ) for that substance under federal Clean Air Act 112(r) with a maximum quantity in 1999 of 12,000 lbs as compared to the 10,000 lb TQ. The worst case release scenario is based on a hypothetical incident in which the single largest container stored at the site, a 20 liter metal can/drum, is pierced by a forklift and/or the contents are otherwise spilled on the floor of the distribution center. RMP Comp, a software program furnished by the U.S. Environmental Protection Agency (EPA), was used to determine the farthest distance to the "flammable end point". Results of this analysis indicate that all distances to be less than approximately two one-hundredths (0.02) of a mile (about 106 feet). There are no residences, schools, hospitals or environmentally sensitive areas within that distance. The alternative release scenario is based on a more realistic hypothetical incident in which a single one-gallon container of ethyl ether is dropped on the floor. According to the analysis, the distance to the flammable endpoint was also equal to one-tenth of a mile (0.1 mile) or less. The alternative release scenario endpoint was calculated based on EPA's vapor cloud fire release type. Administrative controls and active mitigation measures were not included as a factor of consideration during the worst case or alternative release scenarios. However, both release scenarios considered indoor releases contained by dikes or berms in the flammable storage room. VWR's prevention program consists of several key elements, including: * Safety Information - includes detailed information about the hazards of the regulated chemicals, maximum intended inventory, facility design features, applicable standards, equipment use and maintenance. * Hazard Review - a process of evaluating facility operations, using warehouse industry checklists, to identify and control potential hazards. * Standard Operating Procedures - written SOPs to guide employees in safely conducting normal, temporary and non-routine/emergency operations. * Training - includes training commensurate with the types of activities employees are expected to perform during normal and emergency situations. * Maintenance - required maintenance activities are performed by trained employees or qualified workers. * Compliance Audits - conducted at least once every three years to verify compliance with regulatory requirements for Accidental Release Prevention. * Incident Investigation - conducted whenever an incident occurs that results in, or could have resulted in, a catastrophic release (i.e., a release that presents an imminent and substantial endangerment to public health and the environment). The need for chemical specific prevention steps is very limited because chemicals are contained within sealed DOT-approved containers, and the containers are not opened during handling. Additionally, all chemicals are segregated and stored by hazard class to ensure that incompatible chemicals are not stored together. There have been no accidents in the previous five years that have resulted in any deaths or significant property damage on-site, or any off-site deaths, injuries, property damage, environmental damage, evacuations, or in-place sheltering from regulated substances or otherwise. However, VWR has developed a comprehensive emergency response program that addresses small and large-scale incidents, including coordination with outside agencies and responders. |