Ganes Chemicals Inc. - Executive Summary |
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In 1970, Ganes Chemicals bought a 146 acre site in Pennsville, NJ and in 1973 began producing active ingredients for the pharmaceutical industry. These ingredients are used in a variety of prescription and over-the-counter drugs used for blood pressure control, weight reduction, decongestant, anti-depressant, anti-nausea and HIV treatment. Over the years, the facility has expanded steadily and now includes three manufacturing buildings, two warehouses, offices, labs, a maintenance shop, a waste treatment facility, and a state-of-the-art milling and blending facility. This year a new dryer facility will come on line. For the near future, we plan another $30 million in projects to upgrade the faciliy's environmental, production and quality control systems. The Pennsville site currently employs 140 people. Ganes has always been committed to operating its facility in a safe and environmentally responsible manner. Over the years, we have continuously improved our safety and environme ntal programs and in the mid 1980s these programs were further enhanced by our compliance with the New Jersey Toxic Catastrophe Prevention Act (TCPA) and later with the Occupational Safety and Health Administration's (OSHA) Process Safety Management Standard. One of the additions to the program was the establishment of an Emergency Response Team made up of trained Ganes employees. When the Environmental Protection Agency (EPA) came out with the requirement to establish a Risk Management Program (RMP) by June 1999, we only had to make some minor adjustments in our in our existing programs. One of the adjustments was with regard to communications between Ganes and the local and county emergency response groups. We are updating our respective emergency plans and are discussing how to improve notification to the community should an emergency occur. Last year, Ganes opened its doors to the neighbors and residents who came and familiarized themselves with the facility. The only chemica l currently subject to the Risk Management Program is Phosgene, which is a toxic gas stored as a liquid under pressure. It is used to make Bethanechol Chloride, which is a compound of the prescription medication Urecholine. This medication is used in the treatment of urinary retention. Worst Case Scenario: The worst case scenario is a catastrophic failure of cylinder of phosgene resulting in the loss of the entire contents (120 pounds) within 10 minutes (per EPA definition). Using the OCA guidance, the distance of the plume to its end point is 3.8 miles. Phosgene cylinders are covered by the Compressed Gas Association and Department of Transportation specifications. The cylinders are tested far in excess of their normal working pressures. Each container is stamped with a serial number, hydrostatic test date and water capacity. All containers are thoroughly checked for leaks and abnormalities prior to shipment by both the supplier and Ganes. Alternate Case Scenario: The alterna tive release scenario is a 1/16" leak from the cylinder stem. Using the OCA guidance, approximately 0.2 pounds of phosgene are released per min for 60 min. The distance of the plume to its end point is 0.31 miles. The detection area monitors would detect a leak at a low concentration, and set off an alarm activating the Emergency Response Team. The trained Emergency Response Team would quickly mitigate the release and control the leaking cylinder. General accidental release prevention and chemical specific prevention: The facility is inspected annually by New Jersey's Department of Environmental Protection annually to verify compliance with the following New Jersey Toxic Catastrophe (TCPA) requirements: 7 Process Safety Information: includes the process design and safe operational limits information. 7 Process Hazard Analysis: to identify and address potential safety hazards. 7 Risk Assessment: to estimate and reduce the likelihood and impact of potential accident scenarios, to i nvestigate State-of-the-Art equipment and procedures. 7 Standard Operating Procedures: detailed procedures ensuring safe operation. 7 Operator Training: annual training qualifying operators to operate the processes. 7 Mechanical Integrity/Preventative Maintenance: program to inspect and maintain equipment and systems to prevent equipment failure. 7 Management of Change: system to ensure that all changes to equipment and procedures are reviewed and properly documented. 7 Pre-start up review: initial review before the batch is started to ensure that all systems are in place correctly. 7 Safety Reviews: annual review of equipment and procedures to ensure systems are current. 7 Compliance Audits: annual audits to verify compliance with the program requirements. 7 Incident Investigation: to identify the root cause of accidents and prevent recurrence. 7 Employee Participation: requires that employees involved with the chemical are included in the program. 7 Hot Work Permit: ensures that hot work is controlled to minimize fires and explosions. 7 Annual Reports: annual reports submitted to the NJDEP verifying compliance and corrective actions. Five-year accident history: Ganes has not had any accidents involving phosgene. In the past, small releases have occured inside the manufacturing building, but they were immediately detected and neutralized by our trained employees. Emergency Resonse Program: There is a comprehensive emergency response plan. The plant has a trained Emergency Response Team. Monthly training sessions ensure that all members meet annual training requirements. Special training is conducted for Phosgene use, equipment, detection systems and response procedures. A dedicated scrubber is used with the process. An ammonia deluge system can be used to neutralize releases during charging operations. The plant has the ability to to contain a release in the production building and control the release with the building scrubber. All employees a re trained annually in basic emergency recognition, alarms, sheltering, headcount and evacuation procedures. Emergency drills are conducted annually to test the emergency response plan and provide hands-on training for both on-site and off-site emergency responders. Planned changes to improve safety: Ganes is reviewing potential upgrades to improve the storage and transfer of the phosgene. |