Bayer Corporation, Clayton, NC - Executive Summary |
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Accidental Release Prevention and Emergency Response Policies The Bayer Corporation Clayton, NC Plant complies with the guidelines published by the International Institute of Ammonia Refrigeration (IIAR) for equipment specification and operating procedures and the American Industrial Hygiene Association (AIHA) for emergency response. Bayer also complies with the OSHA Process Safety Management (PSM) standard for ammonia. If an emergency were to occur, it is our policy to notify the Clayton Fire Volunteer Department and request that they respond. Stationary Source and Regulated Substances The Bayer facility in Clayton, NC is part of Bayer's Pharmaceutical Division. The Clayton plant produces plasma therapies by a plasma fractionation process. Many of the steps of the process take place at temperatures below freezing and, therefore, ammonia refrigeration systems are needed to cool and/or freeze different steps throughout the process. The Clayton facility is approximately 182 ac res located 2 > miles southwest of downtown Clayton, NC. The main production area of the plant is south of the railroad and the "North Plant"(the main ammonia refrigeration system) is on the north side of the railroad tracks. The facility was inventoried to determine the amount of ammonia typically stored on-site, as well as the amount of ammonia that could be stored in each piece of process equipment. The total system ammonia charge is 27,500 pounds. The largest vessel present in the system is the high-pressure receiver that is 11 feet by 66 inches or approximately 262 ft3 (10, 451 lbs). This vessel is filled to 88% of its capacity by NFPA codes, therefore the maximum quantity if 9,200 lbs. which is the amount used in the worst case release calculations. Worst Case Release Scenario(s) and the Alternate Release Scenario(s) The Worst-Case Release Scenario was determined to be the failure of the high-pressure receiver (10,451 lbs), when filled to the greatest amount (88% or 9,200 lbs). The high-pressure receiver is contained within a building therefore effects of passive mitigation were used in determining the maximum distance to endpoint. Using the EPA's "Risk Management Program Guidance for Ammonia Refrigeration" the distance to endpoint is a circle centered at the location of the North Plant, with a 1.2-mile radius equivalent to the toxic endpoint of 0.14 mg/L. The worst case impact zone contains residential homes with a total population of 860 people (estimated using Johnson Co. parcels data, 1.8 people per parcel @ 477 parcels). The other public receptors located within the worst case impact zone are the Powhatan Church (0.4 mi),New Bethel Church (1.1 miles) and a day care center ( 0.7 mi). No hospitals or environmental receptors were identified to be within the worst case impact zone. For the Alternative-Case Release Scenario, a rupturing of a =" pipe was used. The machine room is equipped with an exhaust/ water curtain system and a fire depart ment emergency dump system. Therefore passive and active mitigation measures were accounted for in estimating the distance to endpoint. The impact zone encompasses a circle with a radius of 0.1 miles. The alternative scenario extends to a neighboring industrial facility and across the railroad tracks. Accidental Release Prevention Program and Chemical Specific Prevention Steps The Clayton facility complies with the EPA's accident prevention rule and all applicable state and local codes and regulations. First and most, important, this facility is designed to promote prevention, both in the building itself and the equipment used as part of the refrigeration process. Written procedures are in place to manage changes in process chemicals, technology, equipment and procedures. Audits are regularly conducted to determine if all safety provisions are being properly implemented. We have a preventative maintenance program and maintenance schedule which includes regular maintenance of co mpressors, pumps, evaporators, condensers, control valves, ammonia detectors, scrubbers and emergency response equipment. Bayer promptly investigates any incident that has resulted in, or could reasonably result in, a catastrophic release of ammonia with prevention as our goal. Bayer employees are encouraged to voice their views on accident prevention issues and to recommend possible changes because we believe that safety management and accident prevention require a team effort. Bayer also is regulated by the OSHA Process Safety Management Rule (PSM). This regulation requires many of the same regulations as the RMP requirements for Program 3 such as; Process Safety Information, Process Hazard Analysis, Operating Procedures, Training, Mechanical Integrity and others. The PSM rule also includes Employee Participation, Pre-Startup Safety Reviews and Trade Secrets. Five Year Accident History Bayer has not had an accidental release involving ammonia greater than 150 lbs (reportable level) in the past five years. Emergency Response Program Bayer has a written emergency response plan that is filed with the Johnson Co. LEPC. The Clayton emergency response team receives training on firefighting, hazardous materials and emergency medicine. The emergency response equipment is regularly inspected and serviced. Bayer closely communicates with local and county response teams such as the Clayton Volunteer Fire Department and the Johnston County LEPC. Planned Changes to Improve Safety Based on this review of the ammonia refrigeration system there are no planned changes to improve safety at this time, however Bayer is dedicated to continuously strive to achieve safety levels that equal or surpass the best in the industry. |