The Gillette Company, AMC - Executive Summary |
|
General Executive Summary of the Risk management Program for The Andover Manufacturing Center of The Gillette Company 1. Accidental Release Prevention and Emergency Response Policies We at the Andover Manufacturing Center of The Gillette Company (Gillette, AMC) are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. Unforeseeably, if such a release does occur, our highly trained emergency response personnel are at hand to control and mitigate the effects of the release. We are also completely coordinated with the Town of Andover Fire department which provides additional emergency response expertise. 2. The Stationar y Source and the Regulated Substances Handled Our facility's primary activities encompass manufacture of personal care products (e.g. aerosol deodorants, antiperspirants and shave preparations; solid deodorants and antiperspirants). We have 4 regulated substances present at our facility. These substances include Isobutane [Propane, 2-methyl], Isopentane [Butane, 2-methyl-], Propane and Difluoroethane (Ethane, 1,1-difluoro-]. All of the regulated substances at our facility are used in the production of personal care products. The maximum inventory of Isobutane [Propare, 2-methyl] at our facility is 220863.65lb while Isopentane [Butane, 2-methyl-], Propane and Difluoroethane [Ethane, 1,1-difluoro-] are present at our facility in quantities of 98905.88lb., 67094.80lb and 45110.46lb., respectively. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenari o To evaluate the worst case scenarios, we have used Equations from Appendix D of the EPA's Offsite Consequence Analysis Guidance. For alternative release scenario analyses, we have also employed Equations from Appendix D of the EPA's Offsite Consequence Analysis Guidance. The following paragraphs provide details of the chose scenarios. The worst case release scenario submitted for Program 2 and 3 flammable substances as a class involves a catastrophic release from Tank Farm in the A-31/152A Storage process. The scenario involves the release of 136698.36lb. of Isobutane [Propane, 2-methyl]. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the maximum distance of 0.41 miles is obtained corresponding to an endpoint of 1 psi overpressure. One alternative release scenario submitted for Program 2 and 3 flammable substa nces involves a release from Tank Farm in the A-46 Storage. The release is assumed to result in a fireball. The scenario involves the release of 118897.68 lb. of Propane in ten minutes. The release is also controlled by active mitigation measures that include deluge system(s) and excess flow valve(s). Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 PSI overpressure is 0.4 miles. Another alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from Tank Farm in the AB70 Storage. The release is assumed to result in a fireball. The scenario involves the release of 94257.19 lb. of Propane in ten minutes. The release is also controlled by active mitigation measures that include deluge system(s). Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 PSI overpressure is 0.4 miles. Another alternative release scenario submitted for Program 2 and 3 flammable substances invol ves a release from Tank Farm in the A-31/152A Storage. The release is assumed to result in a fireball. The scenario involves the release of 136698.36 lb. of Difluoroethane [Ethane, 1,1-difluoro-] in ten minutes. The release is also controlled by active mitigation measures that include deluge system(s). Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 PSI overpressure is 0.4 miles. Another alternative release scenario submitted from Program 2 and 3 flammable substances involves a release from Tank Farm in the Blowing Agent Storage. The release is assumed to result in a fireball. The scenario involves the release of 131874.51 lb. of Isobutane [Propane, 2-methyl] in ten minutes. The release is also controlled by active mitigation measures that include deluge system(s). Under neutral weather conditions, the maximum distance to the flammable endpoint of 1 PSI overpressure is 0.4 miles. 4. The General Accidental Release Prevention Program an d the Chemical Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition. A number of processes at our facility are subject to the OSHA PSM standard under 29 CFR 1910.119. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Gillette, AMC maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is Hazard and Operability Study (HAZOP). The studies are underta ken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of five years. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures For the purposes of safely conducting activities within our covered processes, Gillette, AMC maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Gillette, AMC has comprehensive training programs in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every two years and more frequently as needed. Mechanical Integrit y Gillette, AMC carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Gillette, AMC to manage changes in process chemicals, technology, equipment and procedures. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Gillette, AMC. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Gillette, AMC conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Gillette, AMC promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimu m of 5 years. Employee Participation Gillette, AMC truly believed that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issued and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Gillette, AMC has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History Gillette, AMC has had an excellent record of preventing accidental releases over the last fiv e years. Due to our stringent release prevent policies, there has been no accidental release during this period. 6. Emergency Response Plan Gillette, MAC carries a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notifications of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. __________________________ ___________________________ ____________ are some of the major steps we want to take to improve safety at our facility. These changes are expected to be implemented by ________________________. 8. Certification Statement The undersigned certified that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. Name: Patrick Ladd Signature: Title: Plant Manager Date signed: |