Lonza Inc. - Executive Summary |
|
1.0 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES At Lonza Inc., we are committed to operating and maintaining all of our processes in a safe and responsible manner. We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment. This document provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including a description of our facility and use of substances regulated by EPA's RMP regulation, a summary of results from our assessment of the potential offsite consequences from accidental chemical releases, an overview of our accidental release prevention programs, a five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule, an overview of our emergency response program, an overview of planned improvements at the facility to help prevent acc idental chemical releases from occurring and adversely affecting our employees, the public and the environment, the certification that EPA's RMP program requires us to provide, and the data elements about our risk management program. 2.0 STATIONARY SOURCES AND REGULATED SUBSTANCES Our facility manufactures fine organic chemicals. These chemicals are primarily used as active ingredients in the manufacturing of pharmaceutical products. This facility is a multipurpose, batch chemical processing plant that typically runs numerous different chemical processes per year on a campaign basis. Various process equipment, including reactors, centrifuges complete with sumps, dryers, vacuum pumps, and condensers are used to manufacture these products. In our processes, we use the following chemicals that EPA has identified as having the potential to cause significant offsite consequences in the event of a substantial accidental release: anhydrous ammonia and 27% ammonia solution. Our acci dental 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. 3.0 RELEASE SCENARIOS AND OFFSITE CONSEQUENCE ANALYSES EPA's RMP rule requires that we provide information about the worst-case release scenario and alternative release scenarios for our facility. The following are brief summaries of these scenarios, including information about the key administrative controls and mitigation measure to limit the exposure distances for each scenario. 3.1 WORST CASE RELEASE SCENARIO - REGULATED TOXIC SUBSTANCE The worst case scenario that was selected is having the anhydrous ammonia tank, containing 35,000 pounds of anhydrous ammonia, rupture and lose all its contents within a ten minute period to the atmosphere. Potential public receptors include SmithKline Beecham employees, Philadelphia Inquirer employees, and the surrounding community. The estimated distance to the toxic endpoint is 1.1 miles according to the RMPComp program, and the estimated duration of the release to the atmosphere is approximately 10 minutes. 3.2 ALTERNATIVE CASE RELEASE SCENARIOS - REGULATED TOXIC SUBSTANCES: There are two alternative release scenarios that were selected for this facility. The first scenario that was selected is having a tank wagon containing 27% aqueous ammonia solution lose all its contents to a diked area while filling the 20,000 gallon aqueous ammonia tank. Potential public receptors include SmithKline Beecham employees and Philadelphia Inquirer employees. The estimated distance to the toxic endpoint is 0.1 miles according to the RMPComp program. The second scenario that was selected is a pipe leak from the anhydrous ammonia tank between two closed valves. This would result in a release of about 630 pounds in a ten minute time period. The estimated distance to the toxic endpoint is 0.1 miles, according to RMPComp, whic h would not reach any residences. 4.0 OVERVIEW OF ACCIDENTAL RELEASE PREVENTION PROGRAMS We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. 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 process safety information, process hazard analyses, operating procedures, training, mechanical integrity, management of change, pre-startup reviews, compliance audits, incident investigation, employee participation, hot work permits, and contractor training. 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 control s to ensure that we are meeting our own high standards for accident prevention. 5.0 FIVE YEAR ACCIDENT HISTORY We keep records for all significant accidental releases that occur at our facility. There have been no chemical releases from processes covered under EPA's RMP rule in the last five years. 6.0 EMERGENCY RESPONSE PROGRAM We maintain an integrated contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning. Our program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Furthermore, we coordinate our plan with the community emergency response plan. 7.0 PLANNED CHANGES TO IMPROVE SAFETY All new process equipment that is being installed is run off of a distributed control system (DCS), which includes automatic safety features and interlocks that will bring the equipment to a safe state in the event of a problem. All older process equipment is being upgraded to include these automatic features. Also, more specialized emergency response teams are being developed based on hazards of specific chemicals being used in production. Additionally, we are planning to purchase a PC-based expert advisor designed to make rapid, reliable, and understandable recommendations to plant staff. The action recommendations are incident-specific and based on plant specifications and the knowledge and experience of your emergency response personnel. Critical equipment has been tagged throughout the plant for our sitewide mechanical integrity program. Critical plant personnel have recently participated in Incident Investigation Training and ZHA Training, which is Process Hazard Analysis Training and Software, given by Zurich Insurance Company. |