Bayer Miles Avenue Complex - Executive Summary |
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MILES AVENUE COMPLEX: Executive Summary Release prevention and emergency response policies Personnel at this Bayer Corporation (Bayer) facility take a very active approach in maintaining and improving chemical safety. Building on well-established corporate policies, this facility has developed and follows an OSHA process safety management plan that complies with 29 CFR 1910.119. Thus, even before the development of this risk management plan, this facility was in compliance with the level 3 prevention program requirements. Bayer demonstrates its management's commitment to safety through the efforts of corporate and facility safety personnel. Through safety committee meetings, internal audits, and monitoring of new regulatory and industry developments, Bayer meets or exceeds process safety requirements. For compliance with 40 CFR 68, Bayer established an ammonia RMP planning committee (ammonia is the regulated substance at this facility), comprised of representatives of Bayer faci lities coast-to-coast. The activities of the committee ensure that, in addition to merely achieving compliance, Bayer is consistent in its approach to safety at all of its plants. Facility and regulated substance Bayer's Miles Avenue complex includes R&D facilities for the Diagnostics Division and manufacturing facilities for the Consumer Care Division. The complex is located on a 130-acre site. Heating and cooling for the many buildings located onsite are provided by a centrally located utilities generating plant, supported by chiller buildings. Both underground piping and overhead pipe racks connect the various buildings to the generating plant and chiller buildings. For cooling, a refrigeration system charged with anhydrous ammonia is used. It provides cooling in one of two ways. In some cases, the ammonia is sent to direct expansion HVAC units in the buildings that require cooling. In others, the ammonia is used to cool glycol which is then distributed throughout th e facility, cooling the air via HVAC glycol cooling coils. The ammonia refrigeration system is constructed of several components which may be operated individually or simultaneously. There are two main systems, one located in the Building 6/6C/6E complex and the other in the Building 55/55A complex. The systems are connected via hard piping and provide supplemental refrigeration capacity as demand on the system changes. The ammonia refrigeration system as a whole contains as much as 100,000 pounds of anhydrous ammonia. Worst-case and alternative release scenarios The worst-case release scenario involves the largest ammonia-containing vessel in the system, the 6E Accumulator. It can contain up to 48,000 pounds of ammonia. The rule for worst-case release analysis assumes all of the contents are released in 10 minutes. The 6E accumulator is inside the 6E building and such a release would also occur inside the same building. Thus, an enclosure was assumed as passive mitigation in the event of the worst-case release. Furthermore, rainout of ammonia-containing droplets and attenuation of the release to the outside air was assumed. Taking these into account and using appropriate EPA guidance, the release rate to the atmosphere was assumed to be 40% of an unmitigated release (1,920 vs. 4,800 pounds per minute). No other mitigative measures were considered. However, in the event of an actual significant release of ammonia in this building, a water spray system is present and designed to operate when signaled to do so by sensors. The alternative release scenario was based on a methodical analysis of accident history, process hazard analysis, experience at other similar company facilities, and industry experience. The result was that a blowing 1-inch relief valve at the Building 55/55A liquid receiver, either due to a system overpressure condition or failure of the relief valve, was chosen as the most likely alternative scenario that would have an offsite impact . Even this is not very likely in that system overpressure conditions result in a brief release of ammonia gas, just enough to reduce system pressure below valve set point. When this occurs, the system overpressure condition is quickly corrected to prevent further releases from the relief valve. However, such brief bursts of gas would not have an offsite effect. Therefore, a blowing of the 1-inch relief valve for at least one minute was chosen because it was the only relief valve scenario that would have an offsite impact, however improbable that scenario might be. Because the release would be directly to atmosphere, no enclosure factors were considered. No other mitigative measures were considered. For both analyses, the EPA's Risk Management Program Guidance for Ammonia Refrigeration was used. The results were verified using RMP*Comp, which is based on the formulae used in the guidance document. The distance to endpoint for the worst-case release was 1.7 miles, taking into a ccount rainout and attenuation. For the alternative release, the distance was less than 0.1 mile. Accidental release prevention program The facility's prevention program complies with the OSHA 29 CFR 1910.119 process safety management standard and the corresponding sections of the EPA 40 CFR 68 rule for program level 3 processes. To achieve and maintain this compliance, Bayer has in place many procedural and technological safeguards. The procedural safeguards include an extensive employee training program and detailed operating and maintenance procedures for those employees involved in operating the covered process. The technological safeguards include level controls, sensors, alarms, relief valves, and redundant systems. All of these serve to prevent unintended releases of ammonia, or at least minimize the effects of a release. Five-year accident history This facility has had one unintended release of ammonia, which meets the criteria of Section 68.42 of the rule, in the last f ive years. This occurred in 1996 and the quantity released was calculated to be 885 pounds. The cause was the cutting of an ammonia line thought to be empty. It did not result in serious injury to anyone and had no offsite consequence. Emergency response program The facility has a well-developed, written emergency preparedness and action plan that is coordinated with local emergency responders and the Elkhart County LEPC. The Elkhart Fire Department is the primary responder and staffs a fire station adjacent to the Bayer facility. By company policy, Bayer employees handle only incidental releases of ammonia and therefore the facility is not required to have an emergency response plan. The emergency preparedness and action plan includes procedures for reporting emergencies internally, notifying responders, evacuating the plant, shutting systems down, and for post-response, or cleanup, activities. The plan clearly defines the actions that employees should take when an emergency occurs. The lines of internal notification and authority are clearly stated. All detection and alarm devices are monitored through a supervised fire command system located at the Site Security office, which is staffed continuously. The system alerts Site Security personnel when a detection device alarms. Planned changes to improve safety The maintenance and improvement of safety is an ongoing job at this facility. Training in matters of safety takes place throughout the year. Safety-related recommendations from employees, whether made during formal sessions like process hazard analyses or made upon observation of a potential hazard, are always considered carefully for implementation. This process is continuous and even at times when no major process changes are anticipated, existing safety systems and procedures are fine-tuned as a matter of course. |