Nycomed Inc. - Executive Summary
A Risk Management Program (RMP) has been implemented at Nycomed Inc. for the reduction of accidental releases of hazardous materials. The RMP summarizes the management, administrative, procedural, and technological controls that work together to minimize the risk to the community of hazardous chemical releases. The Risk Management Plan is organized to correspond with specific U.S. Environmental Protection Agency (EPA) RMP definitions and requirements, including: |
7 Facility and regulated substances identification;
7 Hazard Assessment;
7 Prevention Program;
7 Five-Year Accident History;
7 Emergency Response Plan; and
7 Planned changes to improve safety.
Risk management and safety are important concerns at Nycomed; this RMP formalizes and documents these activities. Nycomed is committed to conducting its operations in a safe and responsible manner and to reducing risks to human health and to the environment.
Facility and Regulated Substance Identification
Nycomed, Inc. owns and operates a pharmaceutical plant in Renssaelaer, NY adjacent to the Hudson River and across the river from the state capital (Albany). Chlorine, a regulated toxic RMP substance with a threshold quantity for accidental release prevention of 2,500 pounds, is used at the facility as an ingredient in the manufacture of Sodium Iodine Dichloride. The amount of chlorine present in the system is approximately 5,000 pounds.
Hazard Assessment - Worst Case Scenarios (WCS)
The worst-case toxic accidental release scenario assumes the entire contents of a single one-ton cylinder of chlorine are released during delivery. EPA's RMP Guidance for Wasterwater Treatment Plants show that, under the worst-case weather conditions and a 10-minute release period, the worst-case release could travel 1.3 miles downwind until the toxic endpoint of 8.7 mg/m3 (3 ppm) is reached.
Hazard Assessment - Alternative Release Scenarios (ARS)
The ARS for chlorine assumes that the "pigtail" liqui
d supply line (5/16 inches in diameter) is severed 30 inches from the cylinder valve is released at a rate of 63.3 lbs/min inside the enclosed building. As a result of the building's mitigation, the rate of release to the outdoor atmosphere is calculated to be 12.9 lbs/min. The release is estimated to go 0.08 miles.
A prevention program is in place to minimize the risk of hazardous chemical releases in accordance with the OSHA Process Safety Management (PSM) standard (29 CFR 1910.119) and the EPA Risk Management Program. This prevention program covers the chlorine component of the Sodium Iodine Dichloride process in which chlorine is present above the threshold quantity for both PSM andr RMP rules.
The prevention program provides a structured approach to preventing accidents. Some of the specific activities in the prevention program include:
7 Process safety information is provided to all employees upon hire and is accessible at all times.
7 In-depth process haz
ard analyses are completed every five years by qualified personnel using techniques approved under the PSM standard.
7 Written operating procedures (kept up-to-date) are used for training and guiding the work of operators.
7 Training is provided to all employees upon hire, and refresher training is given annually or upon request.
7 Operators, mechanics, and contractor personnel are qualified, trained in the general hazards in the facility, and informed of any temporary situations affecting safety.
7 Pre-startup safety reviews are conducted to insure that conditions for safe operation have been satisfied prior to starting new or modified equipment.
7 A program is in place to maintain the mechanical integrity of the process, which includes written procedures, training requirements, work orders, scheduled maintenance, and computerized documentation.
7 A hot work permit system assures that work is done safely and properly.
7 A management of change system is in place to ensure that changes
are managed safely.
7 Incidents are investigated and actions are taken as part of a continuous improvement effort.
7 Routine audits are conducted to assure that safe practices are being followed.
This systematic approach to process safety at Nycomed involves employees and strives for continuing improvements in overall safety. The training, qualifications, and safety awareness of our operations, maintenance, and management personnel are a key element in reducing and mitigating accidents.
Chlorine is stored in a room that has chlorine sensors and alarms. A scrubber system is in place which has the capacity to neutralize a one ton cylinder if the need arose. Emergency back up power is also provided to the area.
Five-Year Accident History
There have been no accidents/release of chlorine at Nycomed which led to on-site deaths, injuries or significant damage in the past five years. There are also no reported incidents of off-site consequences from an accidental release of chlorine.
rgency Response Plan
Nycomed has an emergency response plan to ensure that in the event of an emergency the personnel are aware of the appropriate actions to take and authorities to contact in order to mitigate the effects of a release. Response activities are coordinated with the Rensselaer County Local Emergency Planning Committee and the Rensselaer Fire and Police Departments.