BIC Corporation - Executive Summary

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BIC Corporation 
500 Bic Drive, Milford, Connecticut 
 
Risk Management Plan 
Executive Summary 
 
 
Source and Process Description 
 
BIC Corporation (BIC) manufactures lighters, writing instruments and shavers at its facilities located at 500 BIC Drive, Milford, Connecticut.  BIC's Milford facilities consist of an administrative building and five manufacturing buildings situated on 37 acres.  The lighter manufacturing building is bordered by public roads, commercial and industrial properties.  Operations at the lighter manufacturing facility include plastic and metal component manufacture, product assembly, packaging, storage and shipping.  Lighters are filled with liquefied petroleum gas (LP gas) fuel during the assembly process.  The primary component of the lighter's LP gas fuel is isobutane, a substance regulated under EPA Accidental Release Prevention provisions. 
 
The LP gas is stored in tanks located in secure outdoor tank farms. A Liquid Transfer System pumps the LP gas from these stor 
age tanks through underground pipelines to lighter assembly machines in the building.  The lighter assembly machines are located in specially designed rooms dedicated to lighter assembly.  After assembly, lighters are moved via forklift, pallet-jack or conveyor to quality assurance, storage and packaging operations located elsewhere in the building.  Pallets of packaged lighters are then loaded onto trucks for shipment. 
 
Summary of Major Hazards 
 
The ability to produce a clean burning, stable flame is one of the properties that makes isobutane an ideal fuel for lighters.  Although its flammability can be a useful property, large quantities of isobutane can also pose a safety hazard in the unlikely event of an uncontrolled accidental release during storage or processing.  An uncontrolled release from a container or pipeline may result in an accumulation of flammable concentrations of gas which could result in a fire or explosion if an ignition source is present.  This concern has result 
ed in the development of numerous Federal, State and local government regulations, as well as codes and standards from organizations such as the National Fire Protection Association (NFPA) which are designed to help ensure the safe storage, processing and use of LP gases such as isobutane. 
 
Consequences of Failure to Control the Hazards 
 
In accordance with EPA Risk Management Program requirements, BIC has evaluated the potential consequences of the failure to control the hazard described above.  This evaluation required analyses of a prescribed Worst Case Scenario and a reasonably anticipated Alternative Scenario.  The distance to endpoint and the area affected by each scenario were determined using computer-modeling software provided by EPA and other organizations.  The purpose of these analyses was to assess the off-site impact of these hypothetical events. 
 
As prescribed by EPA, the Worst Case Scenario considers an unmitigated release of the entire contents of BIC's largest isobutan 
e storage tank when filled to its maximum allowable capacity (85%). The Worst Case Scenario then assumes that 10% of the released LP gas participates in a subsequent vapor cloud explosion.  Since the facility is located in a developed area, this computer-modeled Worst Case Scenario would have some off-site effects.  There are no schools, hospitals, recreational areas or environmentally sensitive areas within the affected area (prescribed endpoint).  However, the analysis suggests that a limited number of residential and commercial properties could be affected. 
 
The Alternative Scenario considers an accidental release during the process of filling a storage tank from a tank truck.  This Alternative Scenario assumes that proper procedures are not followed, resulting in severe damage to the fill lines of the storage tank.  This could result in the release of the entire contents of a section of fill piping - about 25 pounds of isobutane.  Excess flow valves installed on the tanks would lim 
it the release to the approximate volume of the pipe.  If the released gas were to mix with an appropriate quantity of air and also encounter an ignition source, a vapor cloud fire could result.  The results of the consequence analysis suggest minimal off-site impact, if any.  Due to a limitation of the computer model used, endpoint distances of less than 0.1 miles cannot be directly calculated.  Therefore, extrapolation of model data were also used which suggest that the effects of this Alternative Scenario do not cross the BIC property line.  There are no residences, schools, hospitals, recreational areas or environmentally sensitive areas within the affected area (prescribed endpoint). 
 
Explanation of How Releases are Prevented and Steps Taken to Address Hazards 
 
BIC Corporation has been manufacturing lighters in the current facility since 1977 without a single incident involving a release of isobutane with off-site consequences.  This is one of many statistics that reflect a contin 
uous corporate commitment to the safety and well-being of BIC employees and the community. 
 
Prevention of accidental releases at the facility is accomplished not only through compliance with EPA's Accidental Release Prevention provisions and other Federal and State regulations, but through application of long-standing corporate philosophies and initiatives which help support safe operations.  For example, BIC's strong commitment to product quality results in continuous improvement of our manufacturing operations including state-of-the-art process design and control and preventative maintenance.  BIC's extensive in-line quality testing of every lighter not only guarantees safe and reliable operation of the product by the consumer, but also provides an additional measure of safety for the manufacturing operations.  In addition, a fundamental Company belief is that our employees are our most valuable resource.  Therefore, employee training and employee involvement are important components 
of the corporate culture; in fact, our award-winning employee suggestion program generates hundreds of safety improvements each year. 
 
BIC's corporate commitment to safety and sound environmental management is translated into action by a full-time staff of several highly trained Environmental, Health and Safety (EH&S) professionals who service all BIC facilities.  BIC's EH&S staff, along with lighter production staff, administer several programs which contribute to release prevention including safe work practices, employee training, preventative maintenance, process design and numerous administrative controls designed to ensure that any safety concerns are identified and addressed. 
 
Safe work practices are documented in written operating procedures for production and maintenance personnel.  Employee training is comprehensive, including targeted training in relevant, job-specific work practices as well as overview and awareness training in the various components of BIC's Risk Managemen 
t Program.  Training, which is often a mix of on-the-job and classroom is conducted and documented by competent, experienced personnel.  Employee competency and understanding is assessed.   
 
Preventative maintenance programs focus on inspection and maintenance of all process components including tanks, pumps, valves, controls, instruments and safety systems.  In addition to helping ensure safe and reliable operation, the results of this program are used to identify opportunities for system improvement. 
 
Numerous safety systems and controls have been incorporated into isobutane processing and lighter manufacturing operations.  These include redundant pressure regulators, various excess flow detection and shutoff devices, an extensive gas detection system, several ventilation systems, fire suppression systems and control of potential electrical ignition sources.  A variety of sensors and interlocks provide process control and rapid, automatic response to releases or threats of releases.  
These responses include fuel shutoff, system shutdown, activation of fire suppression systems and facility evacuation. 
 
Among BIC's administrative safety programs is the Management of Change Program, which requires a very detailed safety assessment and approval process for any significant change to equipment or safety systems associated with isobutane processing.  BIC's Contractor Safety Program is designed to ensure that contractors, including LP gas delivery drivers, are also trained in relevant BIC operating and safety procedures. 
 
BIC conducts a Process Hazard Analysis at regular intervals and as needed.  This detailed, critical analysis of equipment, procedures, process parameters and potential deviations is used to identify opportunities for incremental safety improvements.  As a result of the most recent Process Hazard Analysis, BIC is in the process of upgrading certain process equipment as well as upgrading its preventative maintenance program to increase the number and frequ 
ency of inspections. 
 
Response Action in the Event of a Release 
 
BIC has implemented a written Emergency Plan which establishes detailed procedures for addressing potential emergencies including fires, explosions, accidental releases, power failures, natural disasters, bomb threats, civil disturbances, and medical emergencies. The plan designates a Facility Emergency Coordinator who is responsible for implementing the plan during an emergency.  The plan also provides for emergency specific training of all facility personnel.  Emergency response to fires, explosions, releases and other incidents at the facility have been coordinated with outside agencies through formal agreements.  Site visits and joint training exercises have been conducted with Milford Fire Department firefighters and Hazardous Materials Team in order to familiarize Fire Department staff with BIC facilities and emergency procedures. 
 
Emergency response steps that may be implemented in the event of a release of isobuta 
ne include manual and/or automatic activation of fire suppression systems, shutoff devices, ventilation systems and alarm systems.  Other planned procedural actions range from simple leak repair by maintenance personnel to coordinated evacuation of off-site areas and coordinated response activities with State and City emergency response organizations.  Although not discussed in detail for purposes of this brief summary, BIC maintains numerous safety systems, sensors, process interlocks and emergency procedures designed to provide safe and efficient response to emergencies.
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