Lilly Technology Center - Executive Summary |
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Eli Lilly and Company (Lilly), a global research-based pharmaceutical corporation, is dedicated to delivering innovative pharmaceutical-based healthcare solutions that enable people to live longer, healthier and more active lives. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: 1. Accidental release prevention and emergency response policies 2. The stationary source and regulated substances handled 3. The worst-case release scenario and the alternative release scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario 4. An overview of our accidental release prevention programs 5. A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule 6. An overview of our emergency response program 7. An overview of planned improvements at the facility to help prevent accidental chemical releases from occurrin g and adversely affecting our employees, the public, and the environment 1. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES: The Lilly Technology Center (LTC) is committed to operating and maintaining all processes in a safe and responsible manner. This is especially important for those processes using hazardous substances. The Lilly Technology Center has numerous systems in place to manage these chemicals. Lilly uses a combination of accidental release prevention programs and emergency response planning programs to ensure the safety of employees and the public, as well as protection of the environment. Lilly's accidental release prevention programs and contingency planning efforts help effectively manage the hazards that are posed to employees, the public, and the environment by the use of these chemicals. The Lilly Technology Center has a Plant Emergency Manual that contains procedures on how to handle emergencies that occur. The emergency response plan includes p rocedures for notification of local authorities and notification of any potentially affected neighbors. The Lilly Technology Center plays an active roll in its Local Emergency Planning Committee (LEPC). A primary goal of the LEPC is to protect local citizens by developing and maintaining a coordinated emergency response plan and working with industry to minimize the impacts of chemical hazards. Through the LEPC, citizens can obtain information about hazardous substances handled at local facilities and about emergency planning efforts designed to successfully cope with accidents if they occur. The LEPC maintains a coordinated emergency response plan for the community detailing operational procedures to be followed in the event of an accident involving hazardous materials. The plan is available for public inspection. The Lilly Technology Center actively supports local community outreach efforts through Community Advisory Panels and neighbor groups. These panels provide useful feed back from the community and advise Lilly on community issues. Lilly also hosts plant tours and informative evening programs for nearby neighbors. 2. THE STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED: Eli Lilly produces a variety of pharmaceutical products using a variety of chemicals and processing operations. The Lilly LTC Site, which is comprised of 225 acres, is bound by Morris Street on the North, Harding Street on the West and Raymond Street on the South. LTC North was originally opened in 1946 and LTC South in 1968. The facility has applied for, but not yet received, a CAA Title V permit. TOXICS Chemical Quantity Use Chlorine 12,000 lbs caustic scrubber system Ethylenediamine 63,000 lbs solvent used during purification Ammonia 12,000 lbs fermentation feed stock FLAMMABLES None 3. THE WORST-CASE RELEASE SCENARIO AND THE ALTERNATIVE RELEASE SCENARIOS, INCLUDING ADMINISTRATIVE CONTROLS AND MITIGATION MEASURES TO LIMIT THE DISTANCES FOR EACH REPORTED SCENARIO: Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of these chemicals. EPA's RMP rule requires that we provide information about the worst-case release scenario and alternative release scenario for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: Worst-case Release Scenario - Regulated Toxic Chemical - Chlorine Lilly uses chlorine to feed a caustic scrubber system for the insulin process. The worst case scenario is a puncture hole that releases the entire cylinder as a gas in 10 minutes.. According to the EPA RMP Comp and EPA's standard weather conditions, the distance to the toxic end point is 1.3 miles. Approximately 1,775 residents may be affe cted by this release. The Site emergency response team has trained on the mitigation of this scenario with the use of a chlorine B kit. Alternative Release Scenario(s) - Chlorine This scenario is similar to our worst case scenario and assumes a one ton chlorine cylinder with a release time of 18 minutes. According to the CHARM (Complex Hazardous Air Release Model) model using typical weather conditions for Indianapolis, the distance to the toxic end point is 1.6 miles. Approximately 2200 residents may be affected by this release. The Site emergency response team has trained on the mitigation of this scenario with the use of a chlorine B kit. In most cases other than during the storage and handling of the cylinder, the chlorine is stored in an enclosed building designed to scrub and contain the chlorine from releasing to the environment. Alternative Release Scenario(s) - Anhydrous Ammonia Lilly uses anhydrous ammonia in the insulin fermentation process. The scenario assumes a valve breaking off a 9000 lbs tank releasing the ammonia over an 18 minute time frame. According to the CHARM (Complex Hazardous Air Release Model) model using typical weather conditions for Indianapolis, the distance to the toxic end point is 1.0 mile. Approximately 1700 residents may be affected by this release. The Site emergency response team has trained on the mitigation of this scenario. In determining worse case offsite impacts, the RMP regulations assume that all safety systems must fail. In reality our restricted flow valves and the water deluge system for both the ammonia tank and the delivery truck should keep ammonia from going offsite. Worst-case Release Scenario(s) - Regulated Flammable Chemicals Lilly LTC has no flammable chemicals that meet the regulatory criteria. Alternative Release Scenario(s) - Regulated Flammable Chemicals Lilly LTC has no flammable chemicals that meet the regulatory criteria. 4. THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND THE SPECIFIC PRE VENTION STEPS: The Lilly Technology Center is subject to OSHA's Process Safety Management requirements, as well as other OSHA requirements. The facility is also subject to regulation by other agencies, including the Indiana Department of Environmental Management and the United States Environmental Protection Agency. Specific prevention programs include conducting pre-startup and design hazard assessments, proactive maintenance programs, routine vessel inspections, emergency response training, safe to work programs, employee and contractor safety programs, and accident investigation programs. As a member of the Chemical Manufacturers Association (CMA), Lilly participates in a program known as Responsible Care . . The purpose of Responsible Care . is to commit companies to performance improvement in health, safety, and environmental quality. The Responsible Care . initiative is driven by the following guiding principles: o respond to community concerns o develop chemicals and prod ucts that have a safe life cycle o make health, safety and environment a priority for new processes o report hazards to employees, customers and the public o counsel customers on safe use, transportation and disposal of products o operate plants in an environmentally safe manner o increase knowledge of product and process safety o solve historical contamination problems o participate in government regulation development o promote Responsible Care . with other chemical companies In order to participate in CMA's Responsible Care . program, Lilly has committed to meet these guidelines and incorporate them into the way it does business. All Lilly sites regulated by the Environmental Protection Agency (Indiana and Puerto Rico sites) participate in this national program. Similar programs have also been initiated in European and Canadian plants. The heart of the Responsible Care . initiative is the six Codes of Management Practices: COMMUNITY AWARENESS & EMERGENCY RESPONSE Goal: Ensure emer gency preparedness and foster community right-to-know EMPLOYEE HEALTH AND SAFETY Goal: Protect the health and safety of employees and people visiting company sites POLLUTION PREVENTION Goal: Promote efforts to protect the environment by generating less waste and reducing emissions PROCESS SAFETY Goal: Prevent fires, explosions and accidental releases DISTRIBUTION Goal: Reduce the risk to public carriers, customers, contractors, employees and environment posed by the transportation and storage of chemicals PRODUCT STEWARDSHIP Goal: Promote the safe handling of chemicals and products from initial manufacture to distribution, sale and ultimate disposal Lilly is proud to participate in this forward-looking industry initiative. It is one way Lilly can demonstrate its commitment to ensuring the safety of its employees and the community and to protecting the environment. We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals. Our management systems address each of the key features of successful prevention programs including: o Process safety information o Process hazard analysis o Operating procedures o Training o Mechanical integrity o Management of change o Pre-startup review o Compliance audits o Incident investigation o Employee participation o Hot work permit o Contractors These individual elements of our prevention program work together to prevent accidental chemical releases. Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. 5. FIVE-YEAR ACCIDENT HISTORY: We keep records for all significant accidental chemical releases that occur at our facility. Based upon the criteria in EPA's RMP rule, we have had no chemical releases of these three chemicals during the past five years. 6. THE EMERGENCY RESPONSE PROGRAM: E MERGENCY MANAGEMENT AT LILLY TECHNOLOGY CENTER The Lilly Technology Center emergency response plan is linked to the plans of the Marion County Emergency Planning Committee. The site's response is coordinated by plant security using the plant's emergency response teams and equipment. The emergency response plan spells out the "hows" of emergency response and the roles and responsibilities of the incident response and management response teams. It includes response procedures for each building/area of the plant. Regular drills test readiness and help employees practice responses to alarms and incidents. The emergency response plan has been written based on the "one-plan" EPA guidance and covers all topics based on that guidance. COMMUNITY ALERT NETWORK (CAN) SYSTEM The Lilly Technology Center has implemented an innovative community emergency notification system in 1996. The Community Alert Network, or CAN, is an automated phone messaging system. Within ten minutes it can send a recorde d message to everyone who lives or works within one mile of the plant site. The system calls every number up to three times if there is no answer initially. It also generates a report advising what phones were not answered. In conjunction with the Marion County emergency planning organizations, Lilly tests the CAN system annually. EMERGENCY RESPONSE TEAMS Emergency Management Site emergency response teams undergo regular training by emergency response coordinators and the curriculum team. These trainers attend and receive certification from the best emergency response schools in the country. On site training facilities and simulators facilitate the training process. In an emergency situation, one of the site emergency coordinators or his designate becomes the incident commander. The emergency response staff has the responsibility for maintaining the emergency response equipment. Vehicles on site include an ambulance, a command van, a response trailer, a hazardous materials response truck, a rescue truck and an on site medical facility. o HAZARDOUS MATERIAL (HAZMAT) TEAM -Team members are employees who hold full-time jobs in other parts of the plant. Around 110 people from various work shifts make up the team. -Professionally-trained responders are always on site, and all responders wear pagers when not at work. -Hazardous material response includes responding to hazardous spills or vapor releases. Responders are trained to use proper equipment and techniques to stabilize a hazardous area and rescue employees who may need help. -Team undergoes rigorous monthly training in hazmat response. -About 1/3 of the hazmat team are also members of the confined space rescue team. o CONFINED SPACE RESCUE TEAM This group specializes in rescue from tanks, pits and other confined areas. They are trained to use ropes and mechanical rescue techniques. Team members are also certified first responders or Emergency Medical Technicians. o MEDICAL FIRST RESPONDERS First Responders a re trained to give emergency medical aid. Some members are also trained in confined space rescue. All are certified in CPR, first aid and defibrillation. In addition some of the first responders have received additional training to the level of emergency medical technician (EMT). 7. PLANNED CHANGES TO IMPROVE SAFETY: The Lilly Technology Center is committed to ongoing safety improvement. A system to conduct Process Hazard Assessments is in place. The system will assure Process Hazard Assessments are conducted for each of the appropriate process at the Lilly Technology Center. The mechanical systems are routinely tested to insure proper operation and performance. Any problems found are corrected and opportunities for improvement are noted and evaluated. |