OSRAM SYLVANIA Products Inc. - Warren, PA - Executive Summary |
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OSRAM SYLVANIA Products Inc. (OSPI) makes ever effort to prevent the accidental release of hazardous materials into the environment. The facility makes it a policy to have a complete combined PPC, SPCC, and SPR on-site at all times as well as copies located at the local fire department and emergency management agency office. This document is reviewed annually by the Safety and Environmental representatives or as significant changes need to be made, whichever comes first. The facility also makes a point of actively participating on the Warren County LEPC and in its annual full-scale hazmat exercises. Having no on-site emergency response team, the facility works closely with the LEPC and local responders to assure that the risk to the community and the environment would be minimal should an accidental release occur. To that end, the facility has taken an active role in developing along with the LEPC an accurate and workable off-site response plan which is reviewed and updated annual ly. The Warren, PA facility is composed of several operations. The Wire business consists of drawing and plating of ferrous and non-ferrous wire and rod for the electric, electronic and automotive industries. The Precious Metal Plating operation conducts precious metal plating of non-ferrous wire pins and contacts, wire, and strip materials for the automotive and electronic industries. The Specialty Metals plant manufactures precious metal plating salts and conducts reclamation operations of precious metals from the Precious Metal Plating department in Warren. This portion of the facility also accepts precious metal bearing cyanide waste from OSPI's Towanda, PA facility for gold reclamation (per 25 PA 266.90(b)). Finally, the Connector Products operation consists of plastic molding, metal stamping, and connector assembly operations plus their support groups within the plant. Anhydrous ammonia is the only substance in use at the facility above its RMP threshold quantity. It is stored in a 30,000 gallon registered above ground storage tank on the north side of the Wire drawing operation. The ammonia is fed through a pipeline system to a dissociator building where it is broken down into its basic hydrogen and nitrogen components as DA, dissociated ammonia. This gas is then used to control the atmosphere in the various annealing furnaces located throughout the wire drawing process. Anhydrous ammonia is delivered by truck to the ammonia storage tank. It is a clear, colorless gas with a characteristic, intensely irritating outhouse or urine-like odor. It is very soluble in water. Ammonia spills or leaks in this facility will always generate ammonia gas or vapor. The worst-case and alternative release scenarios were calculated using the EPA's RMP*Comp program. In both cases since the facility currently has no mitigation systems in place, none were considered in the calculation. The plant is located in a residential and industrial area and, consequently, was deemed to be in urban surroundings. It was also specified that the material is liquified under pressure. In the instance of a worst-case disaster it was assumed that the entire contents of our on-site storage tank would release in 10 minutes. As layed out in the regulations for worst-case scenarios, the wind speed was assumed to be 1.5 meters per second, the material had a stability class of F and the air temperature was assumed to be 77 degrees F. This 132,600 lb. release would result in a release rate of 13,300 lbs. per minute. These conditions resulted in an estimated distance to endpoint of 4.4 miles. The area affected (depending on the wind direction) would include the entire city of Warren and portions of the adjacent townships, a number of elementary schools plus the local middle and senior high school, the YMCA, the county jail, the county courthouse, several nursing homes, the local hospital, and at least one other RMP facility. The Allegheny River and Conewango Cr eek are also within the affected area. When the alternative release scenario was considered, it was assumed that a system pipe carrying the anhydrous ammonia was sheared off. The cross-sectional area of the pipe was 1.23 square inches, the initial operational flow rate was 1.09 lbs. per minute, the operational pipe pressure was 75 psi, and the change in pipe elevation was 8 feet. These parameters were set based on the actual facility anhydrous ammonia system. It was also assumed that the release duration would be 45 minutes taking into consideration the amount of time our local response team would take to arrive and stop the release. RMP*Comp set the wind speed at 3 meters per second, the stability class at D, and the air temperature at 77 degrees F. This alternative release scenario resulted in a release rate of 2,550 lbs. per minute and an estimated distance to toxic endpoint of 0.3 miles. Facilities affected within this area include a residential portion of the City of Warren , an elementary school, the local YMCA, and another RMP facility. The Allegheny River and Conewango Creek are also within the affected area. Accidental releases on-site are prevented through diligent efforts to inspect and maintain all chemical storage and transport systems as well as the on-site wastewater treatment plant. Inspections are performed and documented at a minimum of once per week. Deficiencies within these systems discovered during these inspections are given priority by the maintenance department for repair and/or upgrade. Purchased chemicals for production are stored in the Specialty Metals warehouse. The potential for spills is minimal. The warehouse floor has no drains and racks which house liquid chemicals are contained at floor level with either curbing or catch basins. In the production facility, chemicals are stored in areas which are graded to drain to containment or wastewater treatment plant trenches. The aisles are kept clear for safe fork truck handl ing of chemicals to and from storage and production areas. The production areas of the plant where chemical storage and usage occurs have no drains to storm or sanitary sewers. A released solution would be transported to the on-site wastewater treatment plant or cleaned up with in-house absorbents and stored until proper disposal is arranged. Wastes from the plating lines are transported to the on-site wastewater treatment plant via waste-specific segregated piping which is located in a trenching system designed to act as secondary containment. The anhydrous ammonia system has the appropriate piping and safety measures in-place for receiving tank truck shipments to the outside ammonia storage tank. The tank is firebox quality steel and is painted reflective white. It is located on a concrete base and is surrounded by a chain link fence. For consistency sake, this OSPI facility utilizes only one anhydrous ammonia supplier. During loading of the tank, the driver is required to ch ock the truck wheels. He must stay with the truck throughout the unload process and be prepared to stop flow if any leaks should develop. After pumping starts, the driver's instructions indicate he is to check all couplings for leaks and to stop pumping if any leaking is detected. The anhydrous ammonia storage facility is inspected for leaks or conditions that could lead to spills or emergency situations on a daily basis. The storage tank system is equipped with excess flow valves to stop the flow of ammonia in the event of a significant rupture or drop in pressure in the ammonia feed line. The tank is also equipped with pressure and temperature gauges and pressure relief valves. This facility has had no accidents or releases involving anhydrous ammonia during the last five years. OSPI - Warren does not have an on-site emergency response team, consequently, we have worked closely with the Warren County LEPC to develop an off-site response plan which covers our anhydrous ammonia a s well as all other extremely hazardous substances stored on-site above the threshold planning quantity. We maintain copies of our PPC, SPCC, and SPR plan with our local Emergency Management Agency (EMA) as well as the local fire department. We can obtain on-site response to an anhydrous ammonia release from either Weavertown Environmental Group or DGD Environmental Services, Inc. Weavertown Environmental Group is also Warren County's contracted response team and would respond to the facility per the EMA's request should a release go off-site. The facility plans to make some improvements to the system in the August 1999 time-frame to improve the safety of the operation. These changes are to include the installation of a new in-line electric vaporizer, the reflanging and revalving of all appurtenances on the tank including all new safety relief valves and excess flow valves, and the removal of old foundation pieces to minimize tripping hazards in the area. |