Richard-Allan Scientific, Wayne, NJ - Executive Summary |
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Richard-Allan Scientific is committed to operating its facilities safely and in compliance with all applicable environmental and safety rules and regulations. This commitment extends to all levels of management, including senior management. To accomplish this, Richard-Allan Scientific has developed numerous programs, including this Risk Management Plan (RMP), to facilitate the safe and efficient operation of the facility, and to ensure that should an accident occur, employees and the surrounding community will not be adversely affected. The Richard-Allan Scientific Health and Safety Policy and Procedures Manual contains all of the company's health and safety policies. The facility is located at 92 Newark Pompton Turnpike in Wayne, New Jersey. The facility is surrounded by a mixture of light industry, retail, and residential properties. The facility is north of I-80 and west of Highway 23. Immediately north of the facility is the company offices of Mycor. Further north and over a 60 to 80-foot precipice are residences and the Ryerson School. Immediately east of the facility are the Lighting Expo, Shotsie's Tattoo, Amber Cyclery, and North Jersey Pool and Spa buildings, and Highway 23. South of the facility are the Bonland operations. West of the facility is the Greenway facility with whom Richard-Allan Scientific shares their facility entrance. Richard-Allan Scientific repackages and manufactures chemical products for the medical and other industries. The chemical of concern for this RMP is formaldehyde. The formaldehyde used is a 37% solution in water. The facility receives the formaldehyde in tanker trucks which are off-loaded in a specially configured bay that is designed to contain any accidental spills or releases during the transfer operation. The formaldehyde received is ultimately mixed with buffering chemicals and then repackaged for customer use. This process does not involve any chemical changes or reactions, but is simply a mixing operati on. The storage vessel for the bulk formaldehyde has a capacity of 5,500-gallons, while the mixing vessel has a maximum capacity of 8,080-gallons. The worst case scenario for the facility is the catastrophic release of the contents of the largest storage vessel for formaldehyde into the facility. Such a release could occur from damage to the tank and/or associated piping and pumps. The tank area is equipped with a lined dike that is capable of containing the entire contents of a tank. In addition, the tank area is completely enclosed within the building structure. In the event of a release, the external doors and the internal fire door can be closed until clean-up operations can be initiated. The diking and complete enclosure within the building will help to minimize the amount of formaldehyde released to the air outside of the facility. All transfer operations from tank trucks are monitored by at least one employee. Spill kits are available near within the unloading bay to ha ndle minor spills, and would be available as needed to combat more extensive releases. Written operating procedures address the proper techniques for connecting transfer equipment to and from the tank truck. In addition, powered forklifts are not allowed within the tank storage area to prevent accidental impacts between the forklifts and the storage vessels. As such, there should be minimal off-site impact. Given the passive controls in place (i.e., diking, enclosures), the release rate to the air is estimated to be 0.113-pounds per minute. The calculated impact distance using the RMP Comp software for the above-described scenario is 0.06-miles, or 316.8-feet. Any off-site impact should be limited to the Mycor facility, portions of the Bonland facility, and the Lighting Expo, Shotsie's Tattoo, Amber Cyclery, and North Jersey Pool and Spa buildings. The property immediately west and out to the 0.06-mile affect radius of the Richard-Allan Scientific facility is wooded and unoccup ied. The alternative scenario would be the release of the contents of the 5,500-gallon formaldehyde tank due to the failure of a transfer line at the tank's base. The aboveground storage tank in question is located in the tank storage area southwest of the unloading bay. The entire room is surrounded by coated concrete diking located within the building itself. The contents of such a release would be contained within the building. In addition to the diking and enclosure, personnel are trained to identify and respond to identified releases. Response can vary from stopping a minor leak to contacting an outside response team to clean up a catastrophic release. Otherwise, the scenario is similar to the worst case scenario described above. Again, using RMP Comp to perform the toxic endpoint distance calculation, it was determined that the area of concern was 0.06-miles from the Richard-Allen Scientific facility. Affected populations outside of the Richard-Allan Scientific facility would be identical to those described in the worst case scenario. This RMP, as required under 40 CFR 68, is designed to take advantage of the accidental release prevention, preventive maintenance and inspection, training, spill response, and risk assessment procedures (among other items) developed for the Richard-Allan Scientific Process Safety Management (PSM) program. The PSM program is required under 29 CFR 1910.119. All procedures are documented to ensure proper and consistent handling of all hazardous chemicals thus minimizing the chance for human error. Preventive maintenance and inspections are conducted to identify and correct problems before there is the potential for off-site impact. All employees are trained in the safe execution of their job duties. Such training is periodically updated and readministered to ensure the employees continued competence. As previously mentioned, the building itself is designed to contain a release of any chemical used at the facility. D iking constructed of coated concrete and complete enclosure of the chemical handling areas help to prevent the release of chemicals off site. A foam fire extinguishing system has been installed to prevent fires from spreading in the chemical storage and transfer areas and potentially exacerbating a release. There have been no accidental releases of formaldehyde or formalin at the Richard-Allan facility since it began operation four years ago. If a release were to occur, its potential severity would be assessed and the appropriate response actions taken. If a release is minor and can be remediated using available personnel and equipment, then it will be cleaned-up without outside intervention. If, however, the release cannot be handled using available personnel and equipment, then more elaborate emergency response procedures would be initiated. In the event of a large release, plant personnel will be evacuated as necessary, the fire department and emergency response contractor con tacted, and neighboring facilities notified by phone or in person of the release and potential risk to their employees and/or building occupants. After notification and upon the arrival of the fire department and/or emergency response contractors, Richard-Allan Scientific personnel will assist as needed in the remediation efforts. All Richard-Allan Scientific personnel are trained on the proper procedures to follow in the event of a release. The training is specific to the responsibilities of the individual employee and is updated annually. No changes are planned in the immediate future to improve the safety of the process. As part of the RMP program, however, all procedures and equipment will be periodically reviewed to ensure that they are suitable for the process and safe to operate. In addition, all employee environmental and safety training is reviewed and readministered annually to ensure that their knowledge is current. If a release should occur, all aspects of the RMP wi ll be reviewed after clean-up to determine their effectiveness. Any deficiencies or improvements in the RMP that are realized after a release will be corrected or inserted immediately, and all necessary changes to supporting procedures and/or training made. Richard-Allan Scientific is conscientious of the public health and well-being, and has invested heavily in personnel, equipment, training, and support to ensure that if a release of formaldehyde or formalin should occur, that the effects of the release to the general public and surrounding businesses would be minimal or non-existent. |