PHOTOCIRCUITS CORPORATOIN - Executive Summary |
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a. Photocircuits Corporation ("PC"), strives to meet or exceed federal, state and local environmental health and safety requirements for its facilities. The Photocircuits accidental release prevention policy for chlorine involves systematic approaches that integrates design engineering, standardized corporate policies, process hazard analysis, management oversight and employee participation. The system design of our PSM process and its operational procedures are consistent with those published and approved by the Chlorine Institute. b. Photocircuits Emergency Response Plan coordinates the efforts and resources of specially trained in- plant responders and the Glen Cove Fire Department. Members of the GCFD have toured the facility and are orientated to the plant layout and operations. In the event of a release of chlorine, all agencies coordinate their efforts to protect the health and safety of Photocircuits employees, members of the community, and the environment. The nec essary equipment required to safety equip emergency responders, contain a release, and monitor possible exposures is maintained in duplicate location at the facility. c. Photocircuits uses chlorine in the manufacture of printed circuit boards. Printed circuit boards are used in an array of items such as; automobiles, computers, telephones, radios, and in a variety of other electroninc products. There is one chlorine supply within the facility that supplies chlorine to the production areas from one ton cylinders. The chlorine supply building is autonomous and includes 12 supply cylinders, control valves, regulators, vaporizers, alarms, and additional safety equipment. Trained employees follow standardized procedures to exchange cylinders and inspect the facility on a daily basis. Specially trained employees, members of the Ph otocircuits Emergency Response Team, (ERT), are available onsite to address any trouble alarms that may occur. d. The EPA requires nearly every chlorine facility, including public water authorities, to follow specific guidelines to determine the offsite consequences of a release. The offsite consequence analysis includes the consideration of two release scenarios, identified by the EPA as the "worse case release" and the "alternative release scenario". The worst case, which is most likely impropable, requires the owner or operator to assume that the "maximim quantity of the largest vessel is released as a gas over 10 minutes", due to an unspecified failure. e. The EPA requires Photocircuits to define its worst case scenario as the failure of a ton cylinder. The The offsite consequence analysis for this scenario followed the conditions and charts pre-defined by the EPA. The predefined conditions EPA included; the release of a ton cylinder in 10 minutes, urban terrain, s table weather conditions. Photocircuits believes the EPA's defined "worse case release scenario", is unfair and unrealistic for the following reasons: 1- As discussed in paragraph C, of this document, Photocircuits utilizes effective measures such as automatic shut off valves, chlorine emergency scrubbers, and integrated alarm systme to mitigate the release of chlorine. In the development of the worse case scenariio the EPA does not permit owner/operator the apply of these mitigating measures into the scenario. 2- Even in the unlikely event that a ton cylinder fails, the full contents of chlorine would not be released in a time span of ten minutes 3-The Photocircuits Emergency Response Personnel would arrive on the scene within minutes to stop the leak well before the full contents of a cylinder would be released. f. The alternative scenario is defined as conditions more likely to occur than the worse case scenario and permits the a pplication of active mitigation measures when calculating offsite consequences. The alternative scenario involves the failure of a section of flexible piping or a release from a pressure relief valve. The amount of chlorine potentially released to the containment building under this scenario is 100 lbs in 10 minutes. That equates to 10lbs of chlorine per minute If such an event would occur, the chlorine alarms would immediately detect the leak, automatic shut off valves would close, and the emergency chlorine scrubber would activate. Subsequently, the leak would be controlled and most of the released chlorine would be contained within the building and converted to a much less harmful solution of bleach, sodium hydroxide, and salt water. The emergency scrubber is capable of controlling a leak up to 2000 pounds at greater than 99% efficiency. Since the containment buildings are not entirely air tight, an additional 10% efficiency loss should be assumed as some chlorine would leak out of the building before it is captured by the scrubber. The amount of chlorine released to the environment under this alternative scenario would be 11% of 100 pounds which equates to 11 pounds. With the date of this submission, the above referenced automatic shutoff valves have not been installed in the Building 7 chlorine handling facility. The auto valves are scheduled to be installed by July 12, 1999. Though the aforementioned equipment will provide an added degree of operational assuredness, we (PC) believe the alternative scenario is accurate based on the level of protection provided by the facility's emergency chlorine scrubber, as well as the facility's historical safety performance record. Building 2 chlorine handling facility is presently being taken out of service and will be permanently decommissioned as of July 10, 1999. Based upon the facility's historical data, the short-term operation of this minor facility does not affect the alternative scenario. g. The gene ral Photocircuits accidental release prevention program is based on full compliance with OSHA Process Safety Management Standard and on the following key elements: >High level of operator training >An effective maintenance program coupled with manufacture repair of components >Use of accurate and effective operating procedures written with the participation of engineers, maintenance employees, process operators, and contracted chlorine experts >Auditing and inspection program > Use state of the art process and safety equipment The chemical specific prevention steps include: > Use of specific personal protective clothing/equipment and self contained breathing apparatus (SCBA), worn by the operators during connection/disconnection of chlorine supply > Chlorine Safety Training for affected employees >An integrated chlorine detection system >Availability of two Chlorine Emergency "B" Kits which are designed by the Chlorine Institute to stop a leak in the cylinder sidewalls, valves and fusible plugs. h. During the previous five years, Photocircuits has not experienced an accidental release that meets the criteria for reporting under the provisionsof the EPA Risk Management Program. Although, on 2/25/99 approximately two pounds of chlorine was released. No one off-site was injured and did not require evacuation of local residents. i. Photocircuits Glen Cove facility has an emergency response program that is centered on the specially trained members of the Emergency Response Team (ERT). The Facility Industrial Hygienist coordinates the overall emergency response program and provides training to Emergency Response Team members. Each shift has an assigned "Shift Commander" and all actions are conducted through an incident command system. The team par ticipates in chemical response, incipient fire, CPR, and first aid training on an annualy basis. Additional emergency coordination is conducted through the Glen Cove Fire Department, and Glen Cove Police Department. j. The last risk assessment was performed in June 1999. Sixteen recommendations were identified and are being investigated. Tentatively, the completion of the recommendations will be completed by 9/1/99. We have currently upgraded the cylinder control valve system with the addition of automatic closing safety valves which are controlled by a continuous chlorine detection system |