II-VI INCORPORATED - Executive Summary
FACILITY AND THE REGULATED SUBSTANCES HANDLED |
II-VI Incorporated, with over 600 employees located at manufacturing facilities in Saxonburg, PA, New Port Richey, FL, Singapore and Suzhou, China is a fully integrated manufacturer of laser optic materials, optics, components, electro-optical products and radiation detection devices from gamma ray to far infrared wavelengths.
Founded in 1971, II-VI Incorporated and our VLOC Subsidiary provide a complete range of products and services for industrial, commercial, military and medical lasers. Our customers include the leading manufacturers of high power industrial lasers, medical/scientific lasers and military systems worldwide. Our eV Division services industry and the medical profession with a wide variety of industrial and medical radiation detection devices from gamma ray to far infrared wavelengths.
At our headquarters located in Saxonburg, Pennsylvania, II-VI Incorporated has been a pioneer in the growth of infrared materials (I
R) since 1971. Today, we are the world's leading producer of Zinc Selenide and Zinc Sulfide materials used in the manufacture of infrared (IR) optical components and systems. II-VI Incorporated is one of only three companies in the United States that produces Zinc Selenide. This process represents a niche business for our company.
These materials are grown by a chemical vapor deposition process that requires the chemical Hydrogen Selenide as a raw material. Hydrogen Selenide is a regulated, acutely toxic and flammable substance subject to requirements of 40CFR Part 68 (the Rule) under the Clean Air Section 112(r). Hydrogen Selenide has a threshold quantity (TQ ) value of 500 pounds. The maximum daily amount of the chemical stored at the Saxonburg site is less than 6000 pounds. Therefore, Hydrogen Selenide must be included in a Risk Management Program for all operations which store, deliver or use this chemical.
Hydrogen Selenide is a liquefied gas under its own vapor
pressure. It is stored in approved cylinders at a maximum quantity of 160 pounds per cylinder. Each cylinder is equipped with protective devices for storage and delivery purposes. At room temperature and atmospheric pressures, Hydrogen Selenide is a colorless gas.
The major Clean Air Act Section 112(r) requirements with which II-VI Incorporated must comply for use of Hydrogen Selenide include:
7 Management System development and documentation
7 Hazard Assessment for each affected process
7 Prevention Program completion
7 Emergency Response Program coordination and
7 Risk Management Plan submittal.
In addition, II-VI Incorporated recognizes its' responsibilities under Section 112(r) ("the general duty clause") to handle all Extremely Hazardous Substances safely to prevent an accidental release and to minimize the consequences of any such release. II-VI follows a prevention program including the use of process safety information, operating procedures, employee training, mecha
nical integrity, management of change, pre-start up review, incident investigation, compliance audit, "safe work practices" and contractor safety programs.
II-VI Incorporated is subject to a number of regulatory laws from numerous agencies due to the complexity of its' operations. As such, a holistic approach to regulatory program management has been developed. Management has assigned Program Administrators who have expertise in a specific area and/or because a particular regulation mainly applies to one function unit. This diversified structure is coordinated through a Senior Programs Administrator. An organization chart has been prepared to identify the responsible personnel and lines of authority for implementing any and all programs.
The Hazard Assessment portion of the 112(r) rule requires facility owners or operators to prepare "worst-case" and "alternative" release scenarios as appropriate for our operations. From the rel
ease scenarios, facilities are then to determine offsite impacts using specified offsite consequence analysis (OCA) parameters for worst-case releases and more realistic parameters for alternative releases.
The worst-case scenario involves the release of the largest quantity of a listed toxic substance that is estimated to generate the greatest distance in any direction to a toxic endpoint defined in the 112(r) regulation. The probability that a worst-case release might occur or the possible causes of such a release are not considered. The alternative scenario involves an accidental release that is "more likely" to occur than the worst-case scenario.
II-VI Incorporated has carefully reviewed its operations involving Hydrogen Selenide and contracted a credible engineering consulting firm (ENSR) to prepare worst case scenario analysis and alternative scenarios based on the requirements of the 112(r) rule. In each case, an offsite consequence analysis (OCA) was performed using app
ropriate air dispersion analysis and modeling techniques.
Worst-Case Release Scenario:
- The worst-case scenario is assumed as a rupture of a single storage cylinder containing 160 pounds of Hydrogen Selenide, and is released over a period of 10 minutes using conservative atmospheric release conditions. The DEGADIS (DEnse GAs DISpersion) model was selected to determine the maximum possible area potentially impacted by the unlikely worst case scenario. The modeling distance to the toxic endpoint of 0.00066 mg/l (0.2 ppm) was determined to be 3.0 miles. Due to strict adherence to proper cylinder testing, transport and handling procedures, this scenario is not considered likely.
Alternative Release Scenario:
- An alternative "more likely" scenario is assumed to be the a release of Hydrogen Selenide from a single
vertical cylinder equipped with a low flow device. The ENSR AIRTOX model was selected to determine the maximum possible area potentially impacted in this event sc
enario. The modeling distance to the toxic endpoint of 0.00066 mg/l (0.2 ppm) was determined to be 0.156 miles for the proposed "more likely" accident scenario. No residential receptors are within this 0.156 mile radius. All cylinder storage and delivery systems are continuously monitored for the presence of even low levels of Hydrogen Selenide. This early warning device, emergency shut off systems, established procedures and trained operators serve to reduce the probability of even the "more likely" accident from occurring.
II-VI Incorporated continuously works to ensure that all regulated substances are safely stored, used and handled. If a chemical release were to occur, the Prevention Program is to ensure that procedures and equipment are established to detect and mitigate the impact of such a release. II-VI Incorporated is governed by the Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) requirements
ee Participation is considered critical to our prevention program. Employee representation and active participation is evident in the writing of operating procedures, process hazard analysis, pre-start up reviews as well as other elements of the process safety management elements.
The II-VI program provides that Process Safety Information be compiled for all operations prior to conducting any process hazard analysis as required by the Rule. This information serves as the basis for employee awareness and training on safely operating our processes.
Process Hazard Analysis (PHA). A written PHA system has been developed which provides that PHAs be developed and implemented, as appropriate. Under the program, PHA teams consisting of engineering, knowledgeable staff and employee representatives work to identify, assess and control the hazards involved in our processes. II-VI has identified four PHAs for its complex processes. In reviewing its program, II-VI has completed upgrades
to two of its PHAs and has committed to completing PHAs for the remaining two components. Therefore, in order to fully implement its program, II-VI anticipates completion/revision of RMP-quality PHAs for the remaining two of its four components within the next fifteen months.
Operating Procedures are developed by our own operators and reviewed by engineering to ensure our processes are operated within identified safe operating conditions. Normal, shut-down and emergency shut down procedures are readily accessible to all operators.
Training: All operators are trained on procedures and safe work practices for our operations. Verification of operator training is confirmed by oral testing, by demonstration and observation.
Mechanical Integrity: Process maintenance activities, inspection and testing of critical equipment is performed. Further, mechanical integrity checks are incorporated into operating procedures to confirm operations are within safe operating conditions prior
to proceeding. The department maintains a maintenance group experienced in maintaining the process equipment and trained operators to ensure our systems integrity.
Management of Change procedures have been developed and implemented. Appropriate employees are informed of and trained in the change prior to startup of the process or affected part of the process.
Pre-start up Reviews have been completed for covered processes and for significantly modified processes at II-VI Incorporated. Such reviews confirms that prior to the introduction of regulated substance, that the process is constructed and equipment is in accordance with design specifications. All process and maintenance employees are trained on the revised procedures and equipment changes prior start up.
Compliance Audits: The II-VI program provides that compliance audits be completed to verify that the procedures and practices developed under the prevention program are effective. The most recent audit results are
on-file with the company. Furthermore, as part of the evaluation occasioned by the RMP program, II-VI is upgrading its audit program and anticipates that the changes occasioned by this review will be fully implemented within the next fifteen months.
Incident Investigation. II-VI Incorporated investigates each incident that results in or could reasonable result in a catastrophic release of a regulated substance. All responses are logged and posted within the facility for employee awareness.
Hot Work Permit: The II-VI program provides that Hot Work Safe practices be followed for hot work activities that could pose a hazard to the process. As part of the evaluation occasioned by the RMP program, II-VI is upgrading its Hot Work Permit program and anticipates that the changes occasioned by this review will be fully implemented within the next four months.
Contractors: II-VI Incorporated recognizes the responsibility of ensuring the contractors selected to work on or adjacen
t to covered processes work safely and in compliance with the standards contained in the Rule. Prior to contractors performing any work, contractors within restricted areas are informed of known potential hazards related to the contractors' work and the affected process, as well as applicable sections of the company's Emergency Response Plan. An employee escort is provided to ensure the approved scope of work is maintained and that acceptable safe work practices are followed. Furthermore, as part of the evaluation occasioned by the RMP program, II-VI is upgrading its contractor safety management program, including those portions pertaining to adjacent work areas, and anticipates that the changes occasioned by this review will be fully implemented within the next nine months.
II-VI Incorporated is prepared to prevent and mitigate accidental release by safe process and equipment design, maintenance of equipment, operating safely and monitoring our operations. Our process system de
signs include significant redundant equipment and procedures for accessing this equipment as needed. Further, all our operations and emergency monitoring systems are on emergency back up generator power with Uninterruptable Power Supply (UPS) for critical process monitoring systems.
FIVE YEAR ACCIDENT HISTORY
No reportable quantity accidental releases of Hydrogen Selenide have occurred off-site that resulted in deaths, injuries, significant property damage or environmental damage in the operating history of this company. Further, no reportable quantity accidental releases of Hydrogen Selenide have occurred onsite that resulted in deaths, injuries, significant property damage or environmental damage in the last five years.
EMERGENCY RESPONSE PROGRAM
A II-VI Incorporated off-site response plan has been developed in accordance with the provisions of Superfund Amendments and Reauthorization Act of 1986 (SARA) Title III, by the Local Emergency Planning Committee (LEPC) for the e
mergency planning district of Butler County, Pennsylvania. The original plan and future revisions are written in conjunction with the emergency planners at II-VI Incorporated and represents the cooperative efforts of both the community and industrial planners in response to a hazardous emergency at our facility. An on-site community emergency warning system is an integral part of the adopted response program. The LEPC Plan is currently under review with revisions to be completed by fall, 1999.
In-plant emergency response standard operating procedures have been developed. In-plant response consists of training and planning to prepare for, prevent, respond to, and recover from emergencies. Emergency First Responder procedures include actions to be taken for small releases. Emergency Response Team members have been trained on the Incident Command System (ICS) which will be followed for emergencies including small releases of Hydrogen Selenide. Protocols for response
to production area emergency monitoring systems have been developed. All facility employees may be notified of emergency situations via a plant-wide paging system. A chain of command is practiced to assess and respond to emergency situations.
In addition to facility emergency response standard operating procedures, a system has been established to notify outside local township, county and regulatory personnel as required. Depending upon the severity and type of event, facilities/agencies to be notified include but are not limited to Clinton Township official, Local Emergency Planning Committee (Butler County), Pennsylvania Emergency Management Association (PEMA) and the Department of Environmental Resources (Meadville Office).
PLANNED CHANGES TO IMPROVE SAFETY
Excerpts from II-VI Incorporated's Commitment to Health, Safety and The Environment Policy:
" At II-VI Incorporated, the health and safety of our employees is a primary concern. We know that all our lives hav
e immeasurable value, both to the company and to our families, and we must all work together to ensure that our working environment is as safe as it can be."
"We feel that by taking the steps necessary to ensure that our employees are safe, the benefits of our efforts will encompass the community and the environment"
"While we follow our conscience regarding the implementation of safety and environmental programs, the local, state and national governments of II-VI Incorporated and our subsidiaries have provided us with guidelines to make sure that we are taking the proper precautions with the health and safety of our employees and the community, as well as with the maintenance of the environment. We commit to maintaining the highest regard for health, safety and the environment wherever we operate worldwide."
II-VI Incorporated has a voluntary employee driven Environmental, Health and Safety Committee. Their mission statement reads: " We pledge to uphold the commitment that II-V
I Incorporated has made to ensure that our working environment is as safe as it can be. An active role in the environmental, health, and safety programs at II-VI will serve to continually improve the quality of working conditions, preserve the environment, and positively influence our community. Our goals are: 1) to increase communication among and between our committee, fellow employees, and management with regard to EHS issues. 2) Actively address any concerns brought to our attention, and 3) Promote a safety conscious culture at II-VI Incorporated."
II-VI Incorporated has adopted a 'Continuous Improvement' Performance Management System for all employees. Performance Management is a process to gain employees' commitment to achieving desired performance in key areas and to coach and assess all employee's actual performance against expected performance. Through our Corporate Policy, II-VI has clearly identified safety for the workforce, community and concerns for the environme
nt as a key area covered by our continuous improvement philosophy and requires all employees to react responsibly in these areas.