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 is serious about safety. 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 manage the incident. All warehousing operations involving regulated chemicals are considered a single "covered process" for regulatory purposes. The following regulated chemicals were identified to exceed the threshold quantity (TQ) for regulation under the federal Clean Air Act Accident Release Prevention rule (CAA ARP) or the associated California Regulation (CalARP). Federal - chloroform - 20,972 lbs ethyl ether - 9,252 lbs CalARP - ammonium hydroxide - 13,055 lbs chloroform - 20,972 lbs formaldehyde solution - 913 lbs hydrochloric acid (>37%) - 10,179 lbs hydrofluoric acid - 405 lbs nitric acid - 4,106 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. Environmental Protection Agency (EPA), was used to determine the farthest distance from the facility that toxic or flammable effects may be anticipated, following the chemical releas e. This is known as the distance to the "toxic" or "flammable" endpoint. Results of the analysis indicate that all distances to endpoints are relatively small. For example, the distance to endpoints for nitric acid and hydrochloric acid is equal to 0.2 miles. The distances to toxic or flammable endpoints for all other chemicals are less than 0.2 miles. 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 distances to endpoints for all regulated chemicals are equal to one-tenth of one mile (0.1 mile) or less. For example, the analysis indicates that the distance to a toxic endpoint for hydrochloric acid, hydrofluoric acid, nitric acid and formaldehyde (formalin) are all equal to 0.1 mile. The distances to toxic or flammable endpoints for all other chemicals are less than 0.1 miles. Administrative controls and active mitigation measures were n ot included as a factor of consideration during the worst case or alternative release 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 regulatory 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. However, flammable chemicals are stored and handled in specially designed rooms with electrical fixtures and equipment that are designed to prevent sparks. In the event a container is damaged, there is special low-level ventilation to capture flammable vapors that may be heavier than air, and eliminate the vapors before an explosive concentration can accumulate. In the unlikely event of an explosion there are special blow-out panel s in the roof skylights of the flammable, corrosive, oxidizer and poison storage rooms that will direct the force of an explosion away from other chemicals. 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. VWR has developed a detailed emergency response program that addresses small- and large-scale incidents, including coordination with outside agencies and responders. |