Buckman Laboratories, Incorporated - Executive Summary |
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Executive Summary Accidental Release Prevention & Emergency Response Policies (68.155(a)): Environmental Policy Buckman Laboratories, Inc. is committed to conducting its operations in a manner that is compatible with the environment and the communities where we operate, while maintaining compliance with environmental laws and regulations. The Corporation recognizes that environmental matters are important in the operation of its business and that environmental protection is a significant responsibility of its associates. To achieve these goals: 7 Top management provides the leadership and resources necessary for responsible environmental management. 7 Managers are assigned primary responsibility for the environmental performance of the operations within their control. 7 Associates are educated regarding Buckman Laboratories, Inc. environmental policy and their individual responsibilities. 7 Qualified staff is maintained to advance the Corporation's knowledge of environmental pr otection. 7 We operate our facility and measure performance against applicable laws, regulations, and standards. 7 Operating procedures are established and updated to maintain environmental regulatory compliance and ensure responsible environmental management. 7 An environmental audit program is maintained to ensure periodic review of the performance of each operation. 7 We are committed to pollution prevention achieved through continual improvement in operation. 7 We seek to use in order of preference, first, source reduction; second, recycling; third, waste treatment. 7 We ensure that the environmental policy is available to the public. Buckman Laboratories' Environmental Policy Safety Mission Statement Recognizing that excellence in safety is crucial to our long-term success, we will ensure that research, manufacturing, administrative, and marketing activities will be accomplished without harm to our associates, customers, to the public, and to the environment. Our Go lden Principle All occupational injuries and illnesses can be prevented Management Principles These basic principles guide Buckman Laboratories in shaping its safety and health programs and in achieving its related corporate objectives. 7 Managers are ultimately responsible for safety of their people, their customers and the public. 7 Managers will seek involvement of their associates in the elimination of safety hazards in their workplace. 7 Safety education is vital to working safely. Everyone must be trained again and again. 7 Good safety behavior is a condition of employment. 7 Safety will take precedence over expediency or short cuts. 7 Every attempt will be made to reduce the probability of incident occurrence. 7 Safeguards will be provided to ensure safe working conditions. 7 Safety audits are a must. All deficiencies must be corrected promptly. 7 Where appropriate, safe standards will be set. They should be reviewed annually. Buckman Laboratories' Mission State ment: Safety Stationary Source & Regulated Substances Handled (68.155(b)): Mission Statement "We, the associates of Buckman Laboratories, will excel in providing measurable, cost-effective improvements in output and quality for our customers by delivering customer-specific services and products, and the creative application of knowledge." Buckman Laboratories was established in 1945 as a manufacturer of specialty chemicals for aqueous industrial systems. The company was founded on its unique ability to create and manufacture innovative solutions to control the growth of microorganisms. Today, Buckman Laboratories works with industry worldwide providing advanced chemical treatment technologies and extensive technical service to help solve complex industrial problems. Our expertise spans a broad range of specialty chemicals, including microorganism control, scale inhibitors, corrosion inhibitors, polymers dispersants and defoamers. Buckman Laboratories' finished pr oducts and raw materials are successfully applied in a number of industries, including pulp and paper, water treatment, agriculture, wood, leather, and coatings. Buckman Laboratories' established the facility in Cadet, Missouri in the early 1960's. The Cadet Plant manufactures several of the specialty chemicals mentioned above. The manufacturing of these products requires the use of several raw material chemicals regulated by the EPA as regulated substances. The regulated substances handled at the Cadet Plant include the following: X Bromine X Carbon Disulfide X Dimethylamine X Epichlorohydrin X Formaldehyde X Monomethylamine X Phosphorous Trichloride Manufacturing of the specialty chemicals occurs in the production area of the Cadet Plant, which contains 13 process vessels. The process vessels are used to react and formulate the various specialty chemical products. In addition to the process vessels, the manufacturing processes are supported by approximately 70 stora ge tanks, rail car loading and unloading stations, tanker truck loading and unloading stations, and various utility systems. Most of the production processes are monitored and controlled by a Distributive Control System (DCS), an automated computer control system. The DCS allows for the continuous monitoring of thousands of process parameters, and allows for the quick identification of any parameters that may have deviated from their intended range. The DCS is programmed to automatically correct or alarm these parameter deviations, allowing for the safe operation of the various production processes. In addition to the DCS, highly trained Chemical Operators perform the day-to-day tasks required to safely operate the various processes. Worst-Case Release & Alternative Release Scenarios (68.155(c)): Worst-Case Flammables: The worst-case scenario for the regulated flammable substances handled at the Cadet Plant is as follows: The failure scenario involves a railcar c ontaining 162,000 pounds of monomethylamine, which is instantaneously released as a vapor and ignited. The potential resulting explosion could cause a 1 pound per square inch (psi) over pressure (the EPA defined endpoint) up to a distance of 0.4 miles from the location of the release. The impacted area within the endpoint distance does not include any permanent public receptors; however, this area does include Buckman Laboratories privately owned land which occasionally is used for recreational purposes such as fishing and hunting. Worst-Case Toxic: The worst-case scenario for the regulated toxic substances handled at the Cadet Plant is as follows: The failure scenario involves a railcar containing 186,000 pounds of carbon disulfide, which is instantaneously released and forms a pool in a passive mitigation containment system. The presence of the passive mitigation containment system reduces the release rate to the environment to approximately 10% of the unmitigated rel ease rate. The resulting pool is assumed to evaporate at the 3-year maximum daily temperature of 100F. Using approved methodology, the endpoint, as defined by EPA, is approximately 0.78 miles from the release. Please note, however, that carbon disulfide is extremely flammable and would probably be ignited within the Cadet Plant. An explosion of this regulated substance would cause a 1 pound per square inch (psi) over pressure (the EPA defined endpoint) up to a distance of 1,000 feet from the location of the release. Therefore, it is highly unlikely that the carbon disulfide vapors would impact public receptors at levels above the established endpoint. Alternative - Flammables: As required by the EPA, Buckman Laboratories assessed the consequences of a "more-likely" release scenario or alternative release scenario. The alternative release scenario for the regulated flammable substances handled at the Cadet Plant is as follows: The failure scenario involves the fail ure of a gasket, valve, flex line or instrument connection in the transfer line and storage system for dimethylamine or monomethylamine, which results in a liquid leak. The leak forms a pool, which immediately begins to evaporate. The resulting vapor cloud would exceed the lower explosive limit (LEL) - (the EPA defined endpoint) up to a distance of less than 100 feet from the location of the release. The impacted area within the endpoint distance includes only the Buckman Laboratories Cadet Plant. Alternative - Toxic: As required by the EPA, Buckman Laboratories assessed the consequences of an alternative release scenario ("more-likely" release scenario). The alternative release scenario for each of the regulated toxic substances handled at the Cadet Plant is as follows: Bromine: The failure scenario for bromine involves the failure of a flange connection in the bromine transfer line either to the tank or to the plant, during charging. This release forms a pool in a passive mitigation diked area. Upon detection of the leak, the transfer of bromine through the transfer line is ceased and emergency procedures are implemented. Based on approved methodology, the endpoint for this scenario, as defined by EPA, was approximately 0.6 miles from the release. Phosphorous Trichloride: The failure scenario for phosphorous trichloride involves the failure of a flex line during the unloading of a tanker truck. This release forms a pool in a passive mitigation diked area. Upon detection of the leak, the unloading of phosphorous trichloride is ceased and emergency procedures are implemented. Based on approved methodology, the endpoint for this scenario, as defined by EPA, was approximately 0.5 miles from the release. Carbon Disulfide: The failure scenario for carbon disulfide involves the failure of a flex line during the unloading of a railcar. This release forms a pool in a passive mitigation diked area. Upon detection of the leak, the un loading of carbon disulfide is ceased and emergency procedures are implemented. Based on approved methodology, the endpoint for this scenario, as defined by EPA, was approximately 0.4 miles from the release. Formaldehyde - 37% Solution: Please note that the worst-case release scenario for formaldehyde does not impact off-site receptors. Therefore, it was determined that alternative release scenarios would not impact off-site receptors, either. The reason for this is that a spill/release of formaldehyde forms an evaporating pool in a passive mitigated diked area. Due to the low vapor pressure of a 37% formaldehyde solution, the evaporation rate of the material is low. Thus, a large pool would be formed and the limiting factor is the maximum size of the pool. The largest possible pool that can be formed is in the passive mitigated diked area where the formaldehyde solution is stored. Based on approved methodology, the endpoint for this scenario, as defined by EPA, was app roximately 0.2 miles from the release. Epichlorohydrin: Please note that the worst-case release scenario for epichlorohydrin does not impact off-site receptors. Therefore, it was determined that alternative release scenarios would not impact off-site receptors, either. The reason for this is that a spill/release of epichlorohydrin forms an evaporating pool in a passive mitigated diked area. Due to the low vapor pressure of epichlorohydrin, the evaporation rate of the material is low. Thus, a large pool would be formed and the limiting factor is the maximum size of the pool. The largest possible pool that can be formed is in the passive mitigated diked area where the formaldehyde solution is stored. Based on approved methodology, the endpoint for this scenario, as defined by EPA, was approximately 0.1 miles from the release. General Accidental Release Prevention Program & Chemical Specific Prevention Steps (68.155(d)): Buckman Laboratories' Cadet Plant complies wi th the Environmental Protection Agency's (EPA), Accidental Release Prevention Rule, also known as the Risk Management Program, also known as 112(r). In addition to this rule, the Cadet Plant complies with various Occupational Safety & Health Administration (OSHA) regulations, which address accidental release prevention. Specifically, Buckman Laboratories has established a Process Safety Management System for each of the regulated substances mentioned above. The Process Safety Management System complies with 29 CFR 1910.119 and the requirements of 40 CFR 68. In addition to the regulatory requirements, Buckman Laboratories has also installed an emergency release containment system to reduce the consequences of an accidental release. The Process Vessels are equipped with systems to relieve pressures that may build up beyond design limits. The relief systems consist of piping, which leads from each Process Vessel's pressure relief valve to a knock-out tank and quench tank. These t anks allow for the containment of any released pressure and chemical vapor, thus, minimizing the potential release of regulated substances to the ambient air. The process areas and tank farm areas also have passive mitigation systems, such as liquid release containment systems. These systems consist of diked areas, which would contain any spilled material and limit the effects on the environment. The design of these diked areas reduces the total surface area of the spill, thus, reducing the evaporation rate of the spilled material. In most cases, these diked areas may reduce the evaporation rate by a factor of 10, which reduces the distance to the endpoints associated with an accidental release. Chemical specific prevention steps have also been enacted and include the following: Bromine: 7 Storage tank enclosed and located in a diked area to reduce emissions to air in the event of a storage tank failure; 7 Storage tank not vented to atmosphere; sealed vessel; 7 Individua l liquid containment system (dike) constructed; 7 Scrubber system installed to reduce vapor emissions to the air; 7 Ammonia vapor system present to control and eliminate bromine vapor; 7 Overfill protection systems in place; 7 Material for emergency response neutralization present; 7 Storage tank and transfer lines only under pressure during transfer; 7 Check valves installed to mitigate contamination of other systems; 7 ISO 9002 procedures in place governing operations associated with bromine; 7 Compatible materials of construction utilized; 7 Emergency response drills practiced concerning bromine releases; 7 Process included in Mechanical Integrity program; 7 Multiple Process Hazard Analyses completed for bromine systems. Carbon Disulfide: 7 Use of a double-walled tank with a vacuum on the outer-shell to detect failure of tank; 7 Storage tank not vented to atmosphere; sealed vessel; 7 Individual liquid containment system (dike) constructed; 7 Overfill protection systems in pl ace; 7 Maintenance of a water layer in diked are to act as a blanket on any release carbon disulfide (carbon disulfide is much heavier than water, tends to "sink" beneath water; 7 Installation of a liquid carbon disulfide detector in diked area to trigger a DCS alarm; 7 Limited use of flanged connections, reduced chance of leak in transfer lines; 7 Check valves installed to mitigate contamination of other systems; 7 ISO 9002 procedures in place governing operations associated with carbon disulfide; 7 Compatible materials of construction utilized; 7 Process included in Mechanical Integrity program; 7 Use of inert gas for flammable material transfer; 7 Multiple Process Hazard Analyses completed for carbon disulfide systems. Dimethylamine: 7 Storage tank not vented to atmosphere; sealed vessel; 7 Liquid containment system (dike) constructed; 7 Limited use of flanged connections, reduced chance of leak in transfer lines; 7 Check valves installed to mitigate contamination of other s ystems; 7 Check valve installed to minimize release of material in the event of an unloading line failure; 7 ISO 9002 procedures in place governing operations associated with dimethylamine; 7 Compatible materials of construction utilized; 7 Process included in Mechanical Integrity program; 7 Overfill protection systems in place; 7 Multiple Process Hazard Analyses completed for dimethylamine systems. Epichlorohydrin: 7 Storage tank vented to thermal oxidizer air pollution control device; 7 Detonation arrestor installed on vent line to thermal oxidizer; 7 Liquid containment system (dike) constructed; 7 Check valves installed to mitigate contamination of other systems; 7 ISO 9002 procedures in place governing operations associated with epichlorohydrin; 7 Compatible materials of construction utilized; 7 Process included in Mechanical Integrity program; 7 Overfill protection systems in place; 7 Multiple Process Hazard Analyses completed for epichlorohydrin systems. Formaldehyde: 7 Storage tank vented to thermal oxidizer air pollution control device; 7 Detonation arrestor installed on vent line to thermal oxidizer; 7 Liquid containment system (dike) constructed; 7 Check valves installed to mitigate contamination of other systems; 7 ISO 9002 procedures in place governing operations associated with formaldehyde; 7 Compatible materials of construction utilized; 7 Process included in Mechanical Integrity program; 7 Overfill protection systems in place; 7 Multiple Process Hazard Analyses completed for formaldehyde systems. Monomethylamine: 7 Storage tank not vented to atmosphere; sealed vessel; 7 Individual liquid containment system (dike) constructed; 7 Maintenance of a water layer in diked are to absorb released material; 7 Limited use of flanged connections, reduced chance of leak in transfer lines; 7 Check valves installed to mitigate contamination of other systems; 7 Check valve installed to minimize release of material in the event of an unloading line f ailure; 7 ISO 9002 procedures in place governing operations associated with monomethylamine; 7 Compatible materials of construction utilized; 7 Process included in Mechanical Integrity program; 7 Overfill protection systems in place; 7 Multiple Process Hazard Analyses completed for monomethylamine systems. Phosphorous Trichloride: 7 Storage tank enclosed and located in a diked area to reduce emissions to air in the event of a storage tank failure; 7 Individual liquid containment system (dike) constructed; 7 Storage tank not vented to atmosphere; sealed vessel; 7 Limited use of flanged connections, reduced chance of leak in transfer lines; 7 ISO 9002 procedures in place governing operations associated with phosphorous trichloride; 7 Compatible materials of construction utilized; 7 Process included in Mechanical Integrity program; 7 Overfill protection systems in place; 7 Emergency response drills practiced concerning phosphorous trichloride releases; 7 Vapor control foam availabl e to suppress vapors from a spill; 7 Multiple Process Hazard Analyses completed for phosphorous trichloride systems. Five-year Accident History (68.155(e)): The Buckman Laboratories Cadet, Missouri facility has not had an accidental release, as defined under 40 CFR 68.42(a), from a covered process in the most recent five years. Emergency Response Program (68.155(f)): Buckman Laboratories' emergency response program for the Cadet Plant is based upon the National Response Team's Integrated Contingency Plan or "One Plan" developed in 1996 by the EPA, OSHA, DOT, MMS and Coast Guard. The emergency response plan for the Cadet Plant has been distributed to the Washington County Sheriff's Department, the Potosi Fire Department, and the Local Emergency Planning Committee. Several individuals of the Potosi Fire Department are currently associates of Buckman Laboratories and members of the Cadet Plant's Fire Brigade, and can offer invaluable emergency response assistance. Planned Chang es for Improved Safety (68.155(g)): Buckman Laboratories' Cadet Plant routinely provides associate training in safe work practices and process operation, performs process hazard analyses and completes various projects to increase the safeguards present and to reduce the associated risks involved in their operations. During the review of the Chemical Accident Prevention Provisions of 40 CFR Part 68, it was determined that some steps could be taken to reduce the potential off-site impact of a worst-case chemical release. These items included the installation of an enclosure around the bromine storage tank and maintaining a water layer underneath the carbon disulfide storage tank. In addition to these items, Buckman Laboratories is investigating the installation of a continuous monitoring system to detect bromine, phosphorous trichloride, dimethylamine and monomethylamine vapor releases and improvements to the phosphorous trichloride storage and unloading facilities. |