Griffith Micro Science - Los Angeles-1 - Executive Summary |
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Introduction Facilities that use or store more than 10,000 lbs. of ethylene oxide are required to prepare and submit a Risk Management Program (RMP) to U.S. EPA. The RMP consists of several elements, including an evaluation of potential accident scenarios and a comprehensive program to prevent accidental releases of regulated chemicals. The RMP summarizes the management, administrative, procedural, and technological controls that work together to minimize the risk of hazardous chemical releases to the community . The RMP includes the following information: 7 Introduction; 7 Facility identification and regulated substances; 7 Policies to protect health, environment, and safety; 7 Hazard Assessment; 7 Prevention Program; 7 Five-Year Accident History; 7 Emergency Response Plan; and 7 Planned Changes to improve safety Facility Identification and Regulated Substances Griffith Micro Science, Inc. (GMSI) operates a contract sterilization facility located in Vernon/Los Angeles, Califor nia. The facility is engaged in the sterilization of medical equipment and spices using ethylene oxide. Ethylene oxide is listed as a regulated toxic substance under U.S. EPA's Risk Management Program regulations (40 CFR 68). Policies to Protect Health, Safety and the Environment Risk management and safety are important concerns at GMSI - Los Angeles. This RMP formalizes and documents these activities. GMSI is committed to conducting its operations in a safe and responsible manner and to reducing risks to human health and the environment. Prevention Program An Accidental Release Prevention Program is in place to minimize the risk of hazardous chemical releases in accordance with the EPA Risk Management Program Level 3 requirements (40 CFR 68). The prevention program provides a structured approach to preventing accidents. Some of the specific activities in the prevention program include: 7 Process safety information is accessible at all times. 7 A hazard review was conducted as part of the preparations for RMP compliance. 7 Computerized process controls prevent unsafe conditions in the sterilizers. 7 Written operating procedures are used for training and guiding the work of operators. 7 Training is provided to all employees that operate the system. 7 A program is in place to properly maintain the system and equipment. 7 Incidents are investigated and actions are taken as part of a continuous improvement effort. 7 Routine audits are conducted to assure that safe practices are being followed. 7 A thorough Preventative Maintenance Program helps ensure equipment is in proper working condition. The sterilization process subject to the Risk Management Program at the Los Angeles/Vernon facility is designed with extensive safeguards to protect against the accidental release of ethylene oxide. Examples of safety equipment in place include pressure relief devices, leak detection and alarm systems, electronic interlock safety systems for sterilization chambers, and explosion proof electrical systems. In addition, process operators receive extensive training in the safe operation of the process, and are required to follow detailed operating procedures to help ensure safety. GMSI has also implemented a mechanical integrity program to monitor the physical condition of process equipment, and replace or repair equipment before it fails. In the unlikely event of a spill or release involving a hazardous material, GMSI has developed an emergency response plan providing procedures to be followed to minimize the potential impacts of a fire or release from the facility. Hazard Evaluation Under the EPA regulations, GMSI is required to evaluate the potential consequences of a worst case release and an alternate release scenario. The following paragraphs provide a description of the worst case and alternate scenarios for the facility. The RMP regulations define a worst-case release as "the release of the largest quantity of a regulated substance fro m a vessel or process line failure that results in the greatest distance to an endpoint defined in Sections 68.22 (a)" (40 CFR 68.3). The worst-case scenario for toxic gases is assumed to be the total release of the single largest container in the process over a 10 minute time period. Thus, for the Los Angeles/Vernon facility, it is assumed that 400 lbs. of ethylene oxide is released over a 10 minute time period. In this scenario, 100% of the ethylene oxide is released into the air in the enclosed staging area. The staging area is contained within a permanent structure, therefore a 55% mitigation factor was taken into account, as per the U.S. EPA Offsite Consequence Analysis Guidance Document (OCAG Document). The release rate from the building to the outside atmosphere was then calculated and the distance to endpoint was determined. In accordance with the U.S. EPA OCAG Document, the alternate scenario evaluated was assumed to consist of a leaking valve on a cylinder of ethylene oxid e. The leaking valve results in a release of ethylene oxide to the inside of the building, and the vapor cloud is assumed to travel outside and downwind. This release is assumed to result from a quarter-inch diameter leak from the valve on a 400-lb. vessel pressurized at 50 psig. The release rate was determined based on Equation 7-1 in the EPA's OCAG document. The staging area is contained within a permanent structure, therefore a 55% mitigation factor was taken into account. The release rate from the building to the outside atmosphere was then calculated and the distance to endpoint was determined. Five-Year Accident History Only accidents occurring in the past five years meeting the following requirements must be included: 1. The release must be from a covered process and involve a regulated substance held above its threshold quantity in the process. 2. The release must have caused at least one of the following: 7 On-site deaths, injuries, or significant property damage; or 7 Kn own offsite deaths, injuries, property damage, environmental damage, evacuations, or sheltering in place. On Friday November 28, 1997 there was a fire and subsequent explosion in the inlet to the catalytic oxidizer at the GMSI Los Angeles 50th Street plant. The explosion resulted from an operator error that routed a non-explosive high ethylene oxide concentration stream through the sterilizer chamber backvent. This ethylene oxide stream mixed with the oxygen rich emissions from an adjacent aeration room. This combined mixture was within the explosive range and was routed to the catalytic oxidizer's open flame. The mixture was ignited and the flame front then propagated back through the ductwork to the fuel source. In the ductwork, the mixture eventually exploded. There was not a release to the atmosphere. The weather conditions at the time are unknown. Severe damage was experienced to the inlet to the catalytic oxidizer and the vent ductwork. There were no on-site injuries an d no known off-site impacts. 911 was called and the City of Vernon Fire Department responded. Emergency Response Plan The RMP regulations require that "response actions be coordinated with local emergency planning and response agencies" (40 CFR 68.12(b)(3)). Emergency response activities at the Los Angeles/Vernon facility are coordinated with the Local Emergency Planning Committee and Vernon County Fire Department. Depending on the quantity and chemical involved in a "reportable spill," GMSI also notifies certain local, state, and federal emergency planning and response agencies. Planned Changes to Improve Safety Safety and Emergency Preparedness is a part of GMSI activities. Exposure risks to employees and the public have been minimized through ongoing inspections and regulatory requirements. At this time, no further improvements have been identified. GMSI is in the process of upgrading their safety procedures and training programs. |