W.M. Barr and Company, Inc. - Executive Summary
RISK MANAGEMENT PROGRAM - EXECUTIVE SUMMARY |
WM Barr Facility and Operations
WM Barr and Company, Inc., an employee-owned company, operates two manufacturing facilities in an industrial area in Memphis, Tennessee. WM Barr has two distinct business divisions, Branded Sales and Custom Manufacturing (CM) Sales. Through the Branded Sales division, we manufacture products with formulas owned by WM Barr, and, in the CM Sales side, we manufacture products with customer-owned formulas. Although the two sales divisions are distinct, they share manufacturing processes.
Manufacturing at WM Barr consists primarily of chemical blending and packaging. Raw materials are received on-site via barge, rail and truck and stored in above ground storage tanks. The materials are then piped into the plants, blended in batch tanks to formula specifications, and packaged into small containers (pint, quart, gallon, etc.) for ultimate shipment to customers or customer designated consumers. WM Barr has a
warehouse and distribution center for storage of finished goods and shipment.
The manufacturing facility located at 2170 Buoy St. requires a Risk Management Program. The RMP flammable substances at the affected facility are dimethyl ether and n-butane (propane is waiting further regulatory review). All of these flammables are stored in the aerosol tank farm in bulk and are used as propellant for aerosol products. Though only one WM Barr facility currently requires an RMP, the safety and response programs, employee training, and other features of the Program are present at all WM Barr facilities.
WM Barr Safety Policy
WM Barr's safety policy is to ensure that no activity takes place unless it can be completed in a safe manner. The President/CEO has ultimate responsibility for the safety and health of employees and others affected by our operations. It is his function to individually assume leadership and direction of the safety and health program. Consistent with good man
agement practice, he delegates authority and responsibility for safe operation through all management levels and designates members of his staff or others to serve as a Central Safety Committee to review and monitor safety affairs. There is a staff of three (3) safety professionals who administer the safety and health program on a full time basis.
WM Barr's safety pledge is that people, methods and safety awareness make all accidents preventable. No job is so important and no production so urgent that we cannot perform our work safely. All employee-owners must be responsible and accountable for performing their tasks safely and are encouraged to exercise good judgment and use their common sense at all times in all places.
Safety audits and accident investigations are used to identify and correct unsafe conditions, unsafe acts, and to promote safety awareness. Corrective action is taken where needed. WM Barr is committed to providing the resources and ongoing safety training nec
essary to prevent accidents and industrial illness, and to maintain an orderly and clean workplace. It is the company's desire to make safety such a part of our culture that it becomes a way of life at work and at home.
Worst-Case and Alternate Release Scenarios
Aeropres AB-70, a liquified petroleum gas containing a mixture of 50.72% propane and 49.28% n-butane, is used in the manufacturing of various types of aerosol products that are packaged and sold in consumer quantities. These products include primer sealers, lubricating/penetrating oils, and woodcare products.
The scenario with the greatest potential impact to local receptors involves the release of the entire contents of this substance from it's storage tank. The tank capacity is 6,800 gallons, but written operating procedures and regular monitoring prevent the tank contents from exceeding 90% capacity, or no more than 6,120 gallons. Based upon this, the estimated maximum amount of mixture that could be released is
27,968 pounds which comprises 14,185 pounds of propane and 13,783 pounds of n-butane. Such a release, if ignited, could result in a vapor cloud explosion. The explosion would result in maximum impact to the immediate area and potentially impact receptors for a distance of up to 0.24 miles from the explosion point. Persons outside of the one-quarter mile radius can expect no noticeable impact.
This worst case scenario, though theoretically possible, is extremely unlikely. WM Barr believes that a more realistic accident scenario would be the release of this mixture due to the premature pull-away of a hose during tank loading operations. A pull-away occurs when the driver fails to remove the hoses that are connecting the vehicle to the tank lines. Based upon EPA's RMP Guidance Documents, this type of accident would result in the release of approximately 4.1 pounds of mixture. The impact radius from an explosion of this amount of mixture is only 0.01 mile, or approximately 53 fee
t. Although the explosion would impact the immediate area in much the same way as the worst case scenario, the quantity of chemical released is much less so the impact area is smaller.
Release Prevention Program
All employees who work in and around the processes where regulated chemicals are present, and all other processes, are thoroughly trained in the safe and proper manner to perform job duties. All work procedures and instructions are documented and employees are periodically trained. All documented work procedures and instructions incorporate a safety component which addresses the steps or precautions (such as PPE or hot work permits) of which an employee performing a particular task should follow. Safety training is also incorporated into job position requirements. It is notable that WM Barr has never had an accident or unpermitted release involving any RMP regulated substance.
The process that contains RMP regulated substances has multiple safety features built into i
t to prevent a release. The tank farm operator performs all unloading of tanker trucks. The tank farm loading area has a manual cutoff switch to stop the flow into storage tanks. The piping to storage tanks is routed through a bulkhead to prevent it from being displaced where it attaches to the tank (and thereby causing a rupture of the tank). Piping into storage tanks from the loading area and from the tanks and into the manufacturing facility is equipped with backcheck and excess flow valves. Storage tanks have fusible links, which close valves if fire is detected. All storage tanks were certified by a qualified engineer when installed.
The aerosol tank farm where the substances are stored has a 12 feet high chain link fence with barbed wire. The facility's perimeter is also fenced and access is controlled by security personnel. Plant equipment is inspected regularly and receives timely maintenance as part of the company's Preventative Maintenance Program. In addition to th
e PM Program, routine audits of operating processes are conducted by WM Barr and third parties and any necessary corrective action taken.
Propellant is piped from the storage tank into the aerosol production area. This area is separated from the rest of the plant by a fire wall and it is equipped with sensors to detect the presence of propellant in the air. If the level of propellant reaches 20% of LEL, exhaust fans activate and the filling process shuts down. If the level reaches 40%, the entire process shuts down: production ceases, tank valves seal to prevent additional propellant from entering the process, and an accelerated exhaust system engages. This production area is also equipped with a robust fire extinguishing system that is designed to flood the entire area with a massive amount of water.
Emergency Response Program
Our people and processes give us a high level of confidence that the occurrence of an emergency involving an RMP regulated substance is highly unlike
ly. However, we have contingency plans in place to manage such events. Employees working in and around the processes where regulated chemicals are present, and all other processes, are trained to respond to emergencies. Furthermore, WM Barr has an Emergency Response Team (ERT), comprised of trained and experienced cross-functional group that meets and drills regularly. Response training is conducted periodically. An internal communications system is in place to notify ERT members of an emergency and its location. The ERT is available to respond 24 hours a day.
WM Barr also works closely with other industry and the local fire department (which has a Hazmat Team) and is an active member of the LEPC. This will allow for a seamless coordination of response efforts. In the event that there is an incident which WM Barr's ERT is incapable of handling, there is a fire station located in the industrial park 2-3 miles from the farthest WM Barr facility. A community-wide Emergency Noti
fication System is in place (recently acquired with funds donated by WM Barr and other members of local industry) which allows for the rapid notification of the affected community of the emergency and its nature, and also contacts emergency personnel needed for response activity. It bears repeating however, that there are no public receptors affected even by our worst case scenario.
At WM Barr, we take safety very seriously. Our employees have an above average commitment to safety because of our safety program and training, and because our employees own the company. We are 100% employee-owned through our Employee Stock Ownership Plan (ESOP). Furthermore, we have taken all reasonable precautions to ensure that we handle all chemicals safely and responsibly. We have had no releases of any RMP regulated substance in our company's 50 year history of manufacturing. We believe that a large release, such as that described in the worst case scenario above, is extremely un
likely, and we are properly staffed, equipped and organized to prevent lesser releases and, in the unlikely event of a small release, to promptly respond and contain it.