Biokyowa, Inc. - Executive Summary |
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Executive Summary Risk Management Program 40 CFR part 68 BioKyowa, Inc. BioKyowa, Inc. is a manufacturing firm located on Nash Road in Cape Girardeau, Missouri and began operations in 1984 with the production of L-lysine. L-lysine is just one of the many amino acids that are building blocks of proteins, and can not be sufficiently produced in the body. It is essential for the proper growth of animals, and can only be supplied through dietary supplement. The production of L-lysine is accomplished through a fermentation process that requires the use of many other chemicals to successfully manufacture this product. These chemicals are stored and used in varying concentrations and amounts at BioKyowa. From small bottles that contain chemicals used for analytical testing, to large storage tanks that contain chemicals for product formulation, purification and cleaning. Some of these chemicals if not handled properly, or released to the environment could under certain circums tances pose a threat to both our employees and the community. With the usage and storage of such chemicals comes a large responsibility, the responsibility of safety. This is a responsibility that BioKyowa has always taken seriously and has been committed to since operations began. There are many programs and regulations that are issued by government agencies, such as the Environmental Protection Agency (EPA), the Occupational Safety and Health Administration (OSHA) and the Missouri Department of Natural Resources (DNR) that help industry with providing safe working conditions and protecting the environment. BioKyowa has always, and will continue to comply and adhere to these policies for making a safe work environment for our employees and the community. One such new program issued by the EPA is the risk management program. This program establishes a list of chemicals that, under certain circumstances, pose a threat to the community if released to the environment. BioK yowa stores and uses one chemical (anhydrous ammonia) in the production of L-lysine that appears on this list. Anhydrous Ammonia is a common chemical that is used as an agricultural fertilizer, in large refrigeration systems, as well as a chemical component in the manufacturing of other products. Ammonia is a colorless gas with a very sharp odor. The odor is familiar to most people because ammonia is used in household cleaners and window cleaning products in low concentrations. BioKyowa uses Anhydrous Ammonia at its full concentration, 99-100%. The ammonia is stored in 2 storage tanks, along with other tanks of acids and bases, in a segregated part of the plant known as a tank farm. Each of the ammonia storage tanks has a liquid capacity of 29,995 gallons. At BioKyowa we limit the maximum amount stored in the ammonia tanks to 80% of capacity, or approximately 24,000 gallons each. The ammonia storage tanks are surrounded by a concrete containment wall that in the event of mu ltiple tank ruptures would reduce the risk of different chemicals mixing. This also limits the pool area, which reduces the square footage of surface area for vaporization. An earthen dike, to further limit and contain an accidental spill or tank rupture also surrounds the entire tank farm. The ammonia storage tanks and piping system were constructed using all applicable engineering standards for the construction of this type of process. The facility was also designed to take into account the possibility of an earthquake, and was built to seismic zone 3 standards. Anhydrous ammonia is stored in the tanks as a liquid under pressure. As the temperature of ammonia increases, the vapor pressure will also increase, as the temperature decreases the vapor pressure is reduced. Because of this characteristic of ammonia, the tanks and piping are fitted with pressure safety valves. These valves are designed to relieve excessive pressure on the tanks or lines, thus reducing the chance of a rupture and an uncontrolled release. BioKyowa has many programs, administrative measures, maintenance and engineering criteria that have been developed to reduce the risk of accidental exposure. OSHA's process safety management program, which was enacted in 1995, deals specifically with chemical safety. This program established guidelines for the safe storage and handling of certain chemicals, of which ammonia is one of, by requiring certain procedures and elements to be met. BioKyowa has met all of the requirements of this program and continues to look for ways to improve upon chemical safety. Our chemical storage facilities are inspected regularly to determine if there is a potential problem or repairs are needed to prevent any release. Along with scheduled and preventative maintenance, we feel our chemical storage area is kept safe for both our employees and the public. Despite all of the considerable effort that goes into the prevention of a chemical release, ther e is still a possibility of an ammonia release. It is this possibility, that is the basis for the environmental protection agencies, risk management program. It is also a possibility that BioKyowa had already considered and planned for, by developing emergency response plans, training our employees for emergency response activities, purchasing and maintaining equipment to deal with a release, and installing systems to help with mitigation in the event of a release. If an anhydrous ammonia release were to occur, a significant portion of it would vaporize (changing from a liquid state to a gaseous state) as it was released into the atmosphere. A white cloud of ammonia vapor would form and be carried in the direction of the prevailing wind. The concentration and size of the ammonia cloud would be dependent on the amount of the release, duration, wind speed, humidity and temperature. It is impossible to calculate every possible release scenario that exists, with that in mind the en vironmental protection agency set criteria to use as a standard, such as wind speed and temperature. It also established that industry should calculate at least 2 scenarios, a worse case, which would be the rupture of a storage tank, and an alternative scenario, which could be a line break or other similar failure. The EPA also established the criteria for which to calculate an end point, or concentration level, to determine a distance from the release that would be affected. In the case of ammonia the calculated endpoint is 0.14 mg/l or 200 parts per million. This effectively states that for every liter of air present, 0.14 milligrams of ammonia would be contained within it. To calculate a distance from the source of a release to the endpoint, computerized air dispersion modeling is used. This modeling takes into account the wind speed, temperature, amount of release and duration of the release to determine to what distance it would be carried. For a worse case release scenario , which would be the release of the entire contents of one, ammonia storage tank, the modeling determined that the endpoint would be a distance of 6.9 miles from the plant site. This does not take into account any response activities that may be used, but rather an uncontrolled release. For an alternative release scenario, a break in a branch pipeline was used. The modeling determined that if left uncontrolled for 30 minutes, the distance to the endpoint would be 0.5 miles. The direction that a release would be carried would be dependent upon wind direction. These distances were also determined using a wind speed of 3.4 mile per hour and a temperature of 77 degrees F. With a stronger wind speed, the ammonia cloud would disperse more rapidly thus reducing the distance to the endpoint. Although, with preventative measures we believe that there is only a faint chance of a release of anhydrous ammonia, it is a remote possibility. BioKyowa maintains specialized equipment necessary t o deal with this type situation and trains employees how to respond to a release. We maintain self-contained breathing apparatus' and total encapsulating suits that allow response personnel to enter an area of a release fully protected and stop a leak if it were to occur. Firewater hydrants located throughout the plant and water cannons with fog nozzles located around the tank farm are maintained, to aid in the dispersion of an ammonia vapor if a release were to occur. Employees are trained on how to use this equipment and how to respond to an incident, if one should occur. Coordination with the local emergency response committee and the fire department in the past and in the future will always be an integral part of our emergency response activities. Since BioKyowa first began operations in 1984, we have never had a major ammonia incident. BioKyowa and our parent company, Kyowa Hakko Kogyo Ltd., are committed to safety for both our employees and the community. We continue to look for ways to improve all aspects of safety, through new technology, administrative controls, training and education, and alternative solutions. |