FAR Research, Inc. - Executive Summary |
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FAR Research, Inc. (FAR) is a manufacturer of pharmaceutical intermediates and fine organic chemicals. Bromine and trimethylchlorosilane (TMCS) are two of the chemicals used by FAR that are stored in sufficient quantity to require development and submission of a Risk Management Plan (RMP). This summary describes FAR's activities and safeguards which have been instituted to protect employees, the public, and the environment. FAR has operated at the Palm Bay, Florida facility since 1983. FAR synthesizes pharmaceutical intermediates, bulk active pharmaceuticals, and fine organic chemicals. These chemicals are sold to the pharmaceutical, cosmetic, electronics, and general chemical industries. Over the years, FAR's products have been used in compounds designed to fight Aids, Hepatitis B, and other diseases. Other FAR products have been used to facilitate the manufacture of electronic chips; others have been used by the space industry. One FAR product has improved the efficiency of the manu facture of nylon. FAR and its employees are committed to continue to safely manufacture organic compounds that make a positive difference. FAR consists of employees and the physical facility. The technical, operations, and support groups are committed to the safe development and manufacture of the products synthesized. The typical "path" for a new product at FAR begins with a customer need, followed by a thorough literature search for safety and process information. Upon completion of the background work, a synthesis route is proposed and the laboratory work commences. Chemists and technicians complete process development on a small, glassware scale to ensure that the synthesis can be completed safely. The next step includes the writing of a proposed, detailed procedure to be completed at the pilot scale. A process safety review meeting is then scheduled. The review participants include the process development chemist, the manufacturing manager, the technical director, and the site ma nager. Other staff may be involved if warranted. The review includes verification that proper development procedures have been followed and that available safety and health information has been obtained, checked, and included with the batch record. Any recommended changes made by the committee must be completed prior to scale-up of the process. The review committee may also require that special operator training sessions be held prior to running certain compounds or chemistries. Equipment Summary: Process equipment at FAR is designed for the intended use. Process vessels are glassteel or grade 316 stainless steel. The vessels are ASME Code rated and are protected with rupture discs and/or relief valves. If corrosion is of concern, testing may be completed prior to running in a given vessel. Glassteel vessels may be spark tested to verify integrity. Alloy vessels are tested using ultrasonic wall thickness testing devices. Key vessels and equipment are checked for maintenance annually. The materials triggering filing of the RMP are bromine and TMCS. Liquified bromine is stored in a 2,000-gallon storage tank and a 1,500-gallon receiving vessel/reactor. TMCS is stored in a 5,000-gallon pressure rated carbon steel tank. The maximum quantities of bromine and TMCS inventoried are 56,000 pounds and 35,000 pounds, respectively. FAR's policy is to minimize inventory of all raw materials. The materials are delivered by bulk tank wagon in quantities of approximately 30,000 pounds. Orders are not placed unless inventories are less than 15,000 pounds for bromine and 2,000 pounds for TMCS. Bromine inventory is verified by tank load cells, receiving and usage records. TMCS inventory is verified by level gauge, receiving and usage records. The RMP requires that FAR propose a worst case scenario. As a calculation algorithm, FAR used the EPA's Offsite Consequence Analysis Guidance (OCAG) and associated reference tables. Of the two chemicals, TMCS would have the greatest impact o n the surrounding area in the unlikely event of a release. The worst case scenario for TMCS involves a rupture of the storage tank and subsequent vaporization of the TMCS within a diked area. The containment dike reduces the surface area of the spilled TMCS which effects the distance to the toxic endpoint (i.e., the point at which a chemical dissipates to the extent that serious injuries from short-term exposures are no longer likely). Nevertheless, the toxic endpoint for this scenario extends to a 2.2-mile radius around the FAR facility. The estimated population affected is 18,191 (1990 Census). Public receptors included within the endpoint are residences, schools, commercial areas, recreation areas, and wildlife sanctuaries. In the unlikely event that this worst case scenario is realized, the FAR Contingency Plan would be implemented. This plan includes measures which would mitigate any TMCS release. However, these measures are not allowed to be included in the worst case scenario. I n addition, this case is unlikely as there are written procedures designed to minimize TMCS incidents. Also, scheduled maintenance is completed in order to ensure the integrity of the storage tank. An alternative release scenario is also required by RMP guidelines. Since the alternative case scenarios for bromine and TMCS would equally affect the surrounding area, FAR has selected a case involving valve failure of the bromine reactor resulting in a spill of the entire content of a maximum bromine charge (4,200 pounds). The spill would be released within a 48 ft x 48 ft building where it would be released to the atmosphere via evaporation. The method used to evaluate the area affected is the EPA's OCAG and associated reference tables. Based upon the parameters of this method, the area within a 0.5-mile radius of the building would be involved above the toxic endpoint. A total of 105 people could be affected in addition to people located in nearby schools, residences, commercial areas, recreation areas, and wildlife sanctuaries. Both the passive mitigation of the building and the active mitigation of the local emergency response efforts were also considered for this method. No accidental releases of bromine have occurred in the past five years. FAR plans to continue to safely handle bromine and TMCS and will incorporate procedures which will further reduce the possibility of a chemical release. |