Carborundum Corporation Boron Nitride - Executive Summary

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Risk Management Program 
Executive Summary 
The management of the Carborundum Corporation facility is committed to operating the plant in a safe manner to protect our employees, the public and the environment. The plant has operated at the Audubon Industrial Park site in Amherst, New York, since 1987.   
The facility uses anhydrous ammonia in the manufacture of boron nitride powders and formed products with applications in the microelectronics, semiconductor, manufacturing and cosmetics industries. The anhydrous ammonia is stored on site in a 10,000-gallon storage vessel.  The maximum volume to which the vessel may be filled is limited to 8,500 gallons (44,000 pounds).  This is controlled by means of liquid level alarms.  The facility complies with the OSHA Process Safety Management rule.  
No History of Ammonia Releases, Preventive Measures Employed  
Carborundum has operated at this site since 1987 with no reportable releases of ammonia.  A variety of engineered systems, training pro 
grams, preventive maintenance activities and work practices are employed to minimize the potential for a release of ammonia.  The storage vessel meets or exceeds the design codes specified by OSHA, ANSI and ASME for anhydrous ammonia storage vessels.  The vessel was 100 percent stress relieved during manufacturing and is designed to reduce the potential for stress crack corrosion.  A containment dike that was designed to withstand Zone 1 seismic conditions surrounds the storage vessel.  Pressure relief valves have been installed to relieve excess pressure and prevent catastrophic failure.  
Ammonia is delivered to our site by tanker trucks.  A trained, experienced driver who remains with the truck throughout the procedure conducts offloading.  The tanker and the storage vessel are equipped with excess flow valves to prevent a major ammonia release if a hose were to rupture.  During the offloading process, the truck is parked in a loading station that drains to a secure secondary contai 
nment vessel.  
Facility maintenance personnel inspect the tank area, including the containment dike, at least once per day.  All maintenance personnel understand the hazards of ammonia, the function of the ammonia storage vessel and delivery system, the preventive maintenance program and the emergency action plan.   
Worst- Case Scenario Highly Unlikely,  No Off-Site Impact From Other Alternatives Reviewed 
The worst-case release scenario analysis was conducted using the EPA RMP*COMPd model.  This model assumes that the storage vessel fails in a catastrophic manner and that the release occurs over a 10-minute period.  This model further assumes that the greatest amount held in the vessel (44,000 pounds) is released.  Since the vessel is outdoors, the model assumes that all of the vapor and droplets remain airborne, and the release rate is the total inventory uniformly distributed over 10 minutes, as required by the rule.  The results of RMP*COMP indicate a modeled offsite release; how 
ever, this scenario is highly unlikely because of the strong in-place preventive measures and containment features of the system described above. 
A review of several alternative scenarios, which would be more likely to occur than the worst-case scenario, indicated no off-site impacts.  We based our alternative scenario on a frequently occurring activity - ammonia delivery.  For this scenario, we assumed a leak through an excess flow valve for a duration of one minute (assuming the valve closed in 60 seconds; actually, it would close in less than 10 seconds).  Using the EPA RMP*COMPd model, no off-site impacts were predicted.   
Emergency Response Plan In Place 
Included in the facility emergency procedures is a response plan in the unlikely event of an ammonia release.  Any leak that resulted in a continuous release of visible vapor or a liquid stream would require plant evacuation and notification to the local Erie County Emergency Response Team.  Plant personnel would pull an alarm  
box and evacuate to a point upwind of the leak point.  The ammonia supply to the building would be stopped by means of a remote shutoff.  The plant emergency controller would call 911 and report the location and severity of the leak.  The Erie County Emergency Response Team (ECERT) would take control of the site upon their arrival.  Facility personnel conduct annual evacuation drills.  The ECERT has also conducted drills at the facility to simulate a response to an emergency. 
The facility Emergency Procedures are reviewed and updated annually.  The Process Safety Management Program is subject to an internal compliance review and update following any significant change or at least every three years.  This Risk Management Program will be reviewed and updated on a similar schedule.
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