The Dodge Company - Executive Summary |
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The Dodge Company is located in Cambridge Massachusetts and has been in business for over 100 years. Senior management is committed to protecting the health of its employees and the general public and is actively developing comprehensive safety management plans to achieve these objectives. The Dodge Company provides embalming chemicals for mortuary services. Raw materials are compounded or mixed at the Cambridge facility, bottled, and shipped to customers. The first floor of the facility includes the warehouse, the compounding room, chemical storage areas, truck bays and a shipping room. Administrative areas, offices, and laboratory space is contained on the second floor. The amount of liquid formaldehyde regulated under the risk management plan (RMP) rule that is typically stored at the Cambridge location is 12,000 gallons. The facility operates Monday through Thursday 8:00-5:15 with approximately 50 employees. The off-site consequence analysis under the RMP considers a worst case and an alternative release scenario for the regulated substance. The worst case scenario is defined by the Environmental Protection Agency (EPA) as the "largest quantity of a regulated substance that results in the greatest distance from the point of release to a specified endpoint". The endpoint is the distance from the point of release where the airborne chemical will be at or below its endpoint concentration. The endpoint concentration for formaldehyde is 0.012mg/l and represents the EPA's Emergency Response Planning Guideline Level 2 (ERPG-2). This is defined as the "maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms that could impair an individual's ability to take protective action". The worst case release scenario requires that the maximum quantity in the largest storage vessel be released in 10 minutes due t o an unspecified failure. The RMP rule specifies that only passive mitigation factors (building enclosures, dikes, containment walls), and no active mitigation factors (sprinkler systems, flares, emergency shut-off valves), can be used in modeling a worst case release. Furthermore, the regulations stipulate a wind speed of 1.5 meters/second, a stability class of F (most stable weather conditions) and an ambient air temperature of 250C. The worst case scenario for the Dodge Company included a release of 6,000 gallons of liquid formaldehyde from a tank in a diked area (a passive mitigation factor which reduces the surface area for volatilization) of the compounding room and was modeled using EPA's RMP*Comp air dispersion model. The model estimated an endpoint radius of 0.2 miles from the Dodge Company, which based on US Census data, could potentially affect a population of 12 (residents only). The assumptions in the worst case scenario may be unrealistic because: 7 It is highly unl ikely that the entire contents of the tank would release in10-minutes given the tanks' location at the facility and the limited access to them by equipment capable of causing the kind of damage that would result in such a release. The alternative release scenario is considered "more likely to occur than the worst case scenario" by the EPA. This scenario affords greater flexibility in modeling the release by allowing site specific information, the use of local meteorological conditions, and the incorporation of passive as well as active mitigation factors. The alternative release scenario assumed a < inch hole in the main process line allowed formaldehyde to be pumped out at a rate of 1.37 pounds per minute for 10 minutes. No active or passive mitigation factors were included in the model. The meteorological conditions applied were consistent with EPA guidance and included a wind speed of 3 meters/second, a stability class of D (moderately unstable conditions), and an ambient air temperature of 250C. The RMP*Comp model generated an endpoint distance of 0.1 miles, potentially affecting a population of 3 residents. There are several measures in-place at the Dodge Company that serve to prevent/mitigate the release of liquid formaldehyde in the compounding, bottling, warehouse and shipping areas: 7 Fire extinguishers are located throughout the processing and warehouse areas and personnel that work in these areas have been trained on their proper use. 7 Personal protection equipment and spill kits are located throughout the processing and warehouse areas and personnel that work in these areas have been trained on their proper use. 7 Mixing of formaldehyde only occurs in the compounding room when two or more personnel are present and observing operations. 7 Shut-off valves at the storage tank and throughout the production line can immediately prevent chemical flow at several points in the process stream. 7 An emergency response plan has been established with the Cambridge Fire Department. There have been no reportable releases of formaldehyde at the Dodge Company since it began operations in 1893. |