Document NGQjEbEQX5zXgwL7QEmLYGmxy

Description of Chemical Handling/Transfer to Process Operations: Raw materials, active pharmaceutical ingredients (API), and chemicals are received at the shipping docks on the south side of the facility and stored in the adjacent Raw Materials warehouse (also referred to as the "receiving warehouse" by the facility representatives). Solid/powder and liquid raw materials are stored in their shipping packaging on or below racks in the warehouse. Wastewater treatment chemicals are moved to the wastewater treatment area for use. Other raw materials, API, and chemicals are moved to various manufacturing areas or labs when needed. Potential for Spills or Slug Discharges from Chemical Storage/Handling/Transfer to reach Sanitary Sewer? yes no Describe Spill or Slug Discharge Potential: The facility has identified and taken measures to minimize the potential for spills or slug discharges to the sanitary sewer. The inspectors observed liquids stored in the Raw Materials Warehouse; these included but were not limited to polyethylene glycol, decon spore (biocide), and soybean casein digest broth (TSB). Floor drains in the Raw Materials warehouse connect directly to the Town of Windsor collection system and were equipped with barricades to exclude spilled materials (photos 2 and 3). Similarly, a floor drain in the pilot plant chemical storage area has been covered to prevent discharges to the collection system (photo 19). Chemicals in use and staged for use in the wastewater treatment area, including caustic soda, sulfuric acid, and defoaming agent, were stored in secondary containment (photos 12 - 15 and 17). Three partially full buckets of defoaming agent were stored without secondary containment (photo 13) approximately 50 feet from the nearest floor drain. The facility representative stated that these were old chemicals that were to be removed to a waste storage area. All chemical storage areas included spill kits and the facility's Chemical Spill Response Plan (SOP-00669) includes detailed notification and cleanup procedures for chemical spills. An approximately 200-gallon tank of propylene glycol was stored near the chiller without secondary containment. The tank was stored next to a floor drain that connects directly to the Town of Windsor collection system (photo 18). See Finding 2 in the Summary of Findings at the end of this report. 4 of 15