Heraeus Amersil Inc. - Buford Plant - Executive Summary |
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EXECUTIVE SUMMARY HERAEUS AMERSIL INC. BUFORD, GEORGIA Background Data In accordance with Title 40 of the Code of Federal Regulations, Chapter 68 (40 CFR 68) promulgated by the Environmental Protection Agency (EPA), Heraeus Amersil, Inc. submits this Risk Management Plan (RMP) for operations at their Buford, Georgia facility. Heraeus Amersil has been in operation at this facility for 13 years, providing quality products to customers and over 200 jobs to the local community. Accidental Release Prevention and Emergency Response Policy Heraeus Amersil is committed to protecting the health of its employees, the surrounding community, and the environment. It is Heraeus Amersil's policy to maintain a safe and healthy workplace, protect the environment, and comply with all applicable regulations, including 40 CFR 68 and, as applicable, Occupational Safety and Health Organization (OSHA) Process Safety Management (PSM) regulations promulgated as Title 29 of the Code of Federal and Emergency Response regulations (29 CFR 1910.120). Stationary Sources and Regulated Substances In order to produce the glass cylinders in a useable form for their customers, Heraeus Amersil is required to acid etch the cylinders at the facility. Heraeus Amersil purchases, stores, and uses Hydrofluoric Acid at greater than 50 % concentration (the 112(r) regulated substance) in the acid etching operation. The Heraeus Amersil facility stores more than the 1000 pound 112(r) regulatory threshold for 50 % concentration or higher Hydrofluoric Acid and is thus subject to this regulation. The Hydrofluoric Acid is used at lower concentration levels to acid etch the glass cylinders produced by the facility. Heraeus Amersil's acid etching system consists of piping, valves, pumps, and tanks, the largest of which is 6500 gallons capacity. Worst Case Release Scenario As required by 40 CFR 68, Heraeus Amersil has evaluated a worst-case release scenario for Hydrofluoric Acid using the par ameters specified by the EPA. The worst-case release scenario is defined as the release of the entire contents of the largest single vessel over a 10-minute period. Based on Heraeus Amersil's acid etch system, Heraeus Amersil's worst case release scenario is the rupture of the largest single vessel (a storage tank) containing 6,500 gallons of Hydrofluoric Acid when filled to 100 % capacity, the maximum physical capacity of the tank. Using the EPA's RMP*Comp program, the maximum distance to the specified "endpoint" (a conservative distance established by EPA at which it is expected that a person could be exposed to the chemical for an hour without suffering irreversible health effects) is 0.2 miles. The worst-case release scenario was developed following EPA regulations and is not considered by Heraeus Amersil to be a likely release scenario for the facility. Alternative Release Scenario A more realistic, though still unlikely, release scenario (alternative release) was d eveloped by Heraeus Amersil. The scenario considered the operation's 13 year history of experience and the hazards identified in the process hazard analyses (PHAs) conducted to ensure that Heraeus Amersil hazards are identified and minimized. The release scenario identified by Heraeus Amersil would be a release caused by overfilling of the storage tank. In developing the release parameters of this alternative scenario, Heraeus Amersil considered the high level alarm designed to alert operators to a tank overfill condition, the maximum response time of the facility's operators, and the release mitigation provided by the building structure. Using EPA's RMP*Comp program, the maximum distance to the endpoint is 0.1 miles. Accidental Release Prevention Program To prevent and mitigate accidental releases of Hydrofluoric Acid, Heraeus Amersil has implemented several precautionary measures that include process/equipment controls, procedures, preventive- maintenance programs, employ ee training, and audit programs. Heraeus Amersil has also developed and implemented a PSM program pursuant to OSHA regulations and as such, has evaluated the system for the potential of Hydrofluoric Acid releases. Heraeus Amersil has developed standard operating procedures for all employees and contractors that have contact with the Hydrofluoric Acid system that incorporates safety measures into the procedures. Pursuant to written management of change procedures established by Heraeus Amersil, any changes to the operating procedures are to be communicated to affected employees. To ensure that Heraeus Amersil's control measures are effective in maintaining the safe operation of the Hydrofluoric Acid system, Heraeus Amersil conducts detailed PSM compliance audits every three years. In accordance with the PSM program, each audit incorporates review of process safety information, process hazard analysis, operating procedures, training programs, system mechanical integrity, man agement of change, pre-startup review procedures, compliance audit procedures, incident investigation procedures, employee participation programs, hot work permit procedures, and contractor safety procedures. Five-Year Accident History Over the last five years, Heraeus Amersil has not experienced an accidental off-site release of Hydrofluoric Acid. Emergency Response Program Heraeus Amersil has devised a comprehensive emergency response program, designed to protect both employees and the community in the event of a release. This program is fully described in a document entitled CONTINGENCY PLAN STANDARD OPERATING PROCEDURES (SOP) in order to facilitate response efforts in the event of a Hydrofluoric Acid release. Heraeus Amersil has trained on-site personnel to respond to accidental Hydrofluoric Acid releases. These personnel are trained in accordance with 29 CFR 1910.120, OSHA's Hazardous Operations and Emergency Response regulations according to their duties and functi on. These personnel receive initial training and update training thereafter. Appropriate mechanisms are in place to notify the Gwinnett County Fire Department and other off- site emergency responders when there is a need for a response. The Buford plant is included in the community emergency response plan developed by the Georgia DNR-EPD, the LEPC for Gwinnett County. Continuing Efforts to Improve Safety Heraeus Amersil periodically reviews and modifies its safety systems and procedures in an effort to continuously improve safety and prevent Hydrofluoric Acid releases. |