VWR Scientific Products Corp. - Executive Summary

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VWR Scientific Products, Inc. (VWR) is a distributor of high-quality chemicals and laboratory supplies.  The chemical products sold by VWR are received from manufacturers in Department of Transportation (DOT)-approved containers (typically ranging from 1 gallon to 55 gallons in volume).  VWR does not manufacture, formulate or otherwise engage in direct handling of chemicals outside of the containers in which the chemicals are received.  VWR operations consist of warehousing and distribution activities, and the risk of a serious chemical-related emergency is low.  However, VWR has a strong commitment to the safety and well-being of its employees, the environment and the surrounding community.  The company has established a management system, consisting of policies, procedures, training, inspection, maintenance and other elements, that are designed to prevent incidents from occurring, and in the event a minor or major emergency does occur, to enable facility personnel to effectively mana 
ge the incident.  
 
All warehousing operations involving regulated chemicals are considered a single "covered process" for regulatory purposes.  The VWR facility is considered to be covered under the Program 2 eligibility requirements (per 68.10(c)) because New Jersey does not recognize Program 1 and VWR is not covered by one of the SIC codes listed under Program 3 nor OSHA's Process Safety Management requirements.   
 
At the present time, only Hydrochloric Acid solution (>36%) exceeds the Threshold Quantity (TQ) for that substance under the revised New Jersey Toxic Catastrophe Prevention Act (NJ TCPA) with an estimated maximum quantity of 6,184 lbs in 1998 as compared to the NJ TCPA TQ of 5,600 lbs.   
 
The worst case release scenario is based on a hypothetical incident in which the single largest container stored on site, a 55 gallon drum, is pierced by a forklift and the contents are spilled on the floor of the distribution center.  RMP Comp, a software program furnished by the U.S. En 
vironmental Protection Agency (EPA), was used to determine the farthest distance from the facility that toxic effects may be anticipated, following the chemical release.  This is known as the distance to the "toxic" endpoint.  Results of the analysis indicate that all distances to endpoints are relatively small.  The estimated distance to the toxic endpoint for hydrochloric acid was determined to be approxiimately 0.2 miles.  There are no residences, schools or hospitals within that distance, although a few commercial industrial establishments exist within that radius. 
 
The alternative release scenario is based on a more realistic hypothetical incident in which a single one-gallon container of chemical is dropped on the floor.   According to the analysis, the distance to the toxic endpoint was equal to one-tenth of one mile (0.1 mile) or less.  
 
Administrative controls and active mitigation measures were not included as a factor of consideration during the worst case or alternative rel 
ease scenarios.   However, passive mitigation measures (i.e., enclosures and berms) were included.  
 
VWR's prevention program consists of several key elements, including: 
 
* Safety Information - includes detailed information about the hazards of regulated chemicals, maximum intended inventory, facility design features, applicable standards, equipment use and maintenance. 
 
* Hazard Review - a process of evaluating facility operations, using warehouse industry checklists, to identify and control potential hazards. 
 
* Operating Procedures - written procedures to guide employees in safely conducting normal, temporary and emergency operations. 
 
* Training - includes training commensurate with the types of activities employees are expected to perform during normal and emergency situations. 
 
* Maintenance - required maintenance activities are performed by trained employees or qualified vendors. 
 
* Compliance Audits - conducted at least once every three years to verify compliance with regulato 
ry requirements for Accidental Release Prevention. 
 
* Incident Investigation - conducted whenever an incident occurs that results in, or could have resulted in, a catastrophic release (i.e., a release that presents an imminent and substantial endangerment to public health and the environment). 
 
The need for chemical specific prevention steps is very limited because chemicals are contained within sealed, DOT-approved containers, and the containers are not opened during handling.   Additionally, all chemicals are segregated and stored by hazard class, to ensure that incompatible chemicals are not stored together. 
 
There have been no accidents in the previous five years that have resulted in any deaths or significant property damage on-site, or any off-site deaths, injuries, property damage, environmental damage, evacuations, or in-place sheltering from regulated substances or otherwise.  However, VWR has developed a detailed emergency response program that addresses small- and large-scal 
e incidents, including coordination with outside agencies and responders.  This plan has been approved by the State of New Jersey Department of Environmental Protection under its Discharge Prevention, Containment and Countermeasures (DPCC) Plan and Discharge Cleanup & Removal (DCR) Plan requirements.
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