M&M/Mars-Waco - Executive Summary
1. Facility Description and Regulated Substance |
M&M/Mars, a division of Mars, Incorporated (hereinafter "the Company"), operates a production plant in Waco, Texas, at which confectionary products are manufactured. The plant utilizes aqueous ammonia (concentration 28%) as a nitrogen source for its wastewater pretreatment system. The system utilizes more than a threshold quantity of ammonia, as specified in the Risk Management Plan ("RMP") regulations adopted by the Environmental Protection Agency ("EPA").
2. Accidental Release Prevention and Emergency Response Policies
The Company is committed to the safety of all persons that work in its plant, to the protection of the environment and to the community which surrounds the plant, and to the advancement of human health and safety. The Waco facility has committed substantial resources to the engineering and design of the wastewater pretreatment system to minimize the likelihood of accidental releases and to minimize the risk to
the associates (employees), the local community and the surrounding environment. This commitment is also demonstrated by the plant's comprehensive accidental release prevention program. If a release does occur, plant personnel are trained and equipped to provide an almost instantaneous response, and when necessary, to coordinate with the Waco-McLennan County Emergency Planning Committee to control and mitigate the effects of the release.
3. Offsite Consequence Analyses
In accordance with EPA's RMP requirements, the plant's offsite consequence analyses were developed under the hypothetical assumption as required by EPA regulations that no proactive mitigation systems be considered, regardless of the extent of the facility's control systems, the proven nature of technologies employed, and system redundancy.
The worst-case release scenario is the failure of a tank containing 23,000 pounds of aqueous ammonia. The released quantity of substance would be contained in a dike that is co
nstructed to contain the entire quantity of solution. Such a release will result in an airborne mixture of vapor and liquid droplets. The distance to the endpoint from the release extends offsite. Public receptors within the distance to the endpoint include commercial, office or industrial areas only. There are no environmental receptors.
The plant's alternative release scenario is the accidental overfilling of the 23,000 pound vessel that could lead to a ten minute release, resulting in an airborne mixture of vapor and liquid droplets of ammonia. The release will be controlled and minimized by the use of both administrative and mitigation measures, including relief valves and manual shut offs, as well as a dike that will capture any released quantities. The resulting distance to the endpoint extends offsite. Public receptors within the distance to the endpoint include commercial, office or industrial areas only. There are no environmental receptors.
4. Prevention Program
he plant complies with all applicable accident prevention rules and all applicable state and local codes and regulations.
5. Five Year Accident History
The plant's five year accident history is exemplary. During this period, there has not been a release in excess of a reportable quantity or one that has caused serious injury, property damage or adverse environmental consequences.
6. Emergency Response Program
The plant has a written emergency response plan to respond to an accidental release of aqueous ammonia. The plan is designed to minimize the potential for adverse effects of chemical exposure on human health through a combination of containment, control, evacuation procedures, and the use of personal protective equipment. It further directs appropriate personnel to provide any required notifications to regulatory agencies and the public. Employees of the facility have established and maintained a strong relationship with the Waco-McLennan County Emergency Planning Commi
7. Future Safety Plan
Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. The Company is committed to constant improvement in this area. No changes to current plans and procedures are contemplated at this time. Periodic reviews of safety and release prevention and preparedness measures are and will continue to be undertaken.