Kalmus & Associates, Inc. - Executive Summary |
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Our corporate policy at Kalmus and Associates, Inc., requires establishing programs and utilizing written procedures to cover the actions that management and employees shall take to ensure the following: a) accidental toxic release prevention; b) prompt and sufficient emergency response to fire, chemical spills, or gas release; c) safety at the facility; d) implementation of safe procedures. Our senior management is committed to protecting our employees, the surrounding community, and environment from accidental toxic release and pollution. Kalmus and Associates, Inc., is a manufacturer of printed circuit boards to industrial, including automotive, businesses. Our company is certified to QS 9002, which demonstrates our compliance to world-wide and automotive quality system standards. Our facility in Aurora was constructed and opened in 1996 to service high-volume requirements of our customers in single-sided printed circuit boards. We use several regulated chemicals to process our products which include various polymer and thermal inks, hydrochloric acid, chlorine gas, tin-lead solder, weak acid fluxes, and proprietary sodium persulfate and sodium hydroxide solutions. Regarding chlorine gas, which is the only substance at our facility that is subject to the EPA's Risk Management Program, the worst-case scenario that could occur would be a leak from a chlorine gas tank. This tank has up to one ton of chlorine that is liquified under pressure. In the event the tank is punctured or the valve is broken off the tank, the liquified chlorine would quickly vaporize into the atmosphere within ten minutes. The chlorine gas cloud could cause a toxic effect at a radius of up to 0.9 miles from the facility. The chlorine tank is enclosed in a room inside the building which reduces the release rate to 110 pounds per minute. An alternative scenario could occur if the chlorine gas leaks out of a pipe or fitting leading from the chlorine gas tank to the etcher equipment , which processes the chlorine. This scenario could occur if the pipe or fitting is broken or punctured by severe mechanical shock (e.g. from a tornado) to or a defect in the pipe or fitting material. The pipes and fittings are mitigated by enclosure within the building which slows release to the outside atmosphere. Our facility has an accidental release prevention program which incorporates OSHA's Process Safety Management guidelines. All employees responsible for the etcher process have been thoroughly trained by the supplier of the chlorine gas in proper and safe handling, maintenance, and transfer of the chlorine tanks. The room where the chlorine is stored has a chlorine detector alarm system. If chlorine is detected, red strobe lights are activated right outside of the chlorine room, in the main factory room, and in the etching room where the chlorine is used. Every three months, the entire chlorine system is inspected for damage and wear on the valves, piping, and gas reg ulators. Daily inspection of pressure regulators, pressure gauges, and the chlorine detector is being done. In addition, the overhead hoist which transfers the one-ton tanks to and from the chemical supplier truck is inspected and maintained periodically. Whenever the facility stops operations (during weekends and holidays), the chlorine gas tank valves are shut off. Since operations have begun in this facility in 1996, our company has not had any accidents regarding toxic release of the chlorine gas. In the unlikely event that toxic release of chlorine gas occurs, we have a comprehensive emergency response program which is coordinated with the Aurora Fire Department and the chlroine gas supplier, Alexander Chemical. Several employees have been trained to lead this program, which covers all hours of operation. Our emergency response program includes how to recognize emergency situations, notify the proper local emergency responders, and perform emergency control procedures. All employees have been informed of how to evacuate the building during an emergency. Emergency response drills are performed annually in cooperation with the Aurora Fire Department. In a continuing effort to improve safety and prevention of accidental release, our company plans on further training employees and managers on the maintenance and handling of the chlorine gas system and expanding our prevention program through an annual inspection of the system by our chlorine gas supplier, Alexander Chemcial. We, at Kalmus and Associates, Inc., will continue maintaining and improving our risk management program to the best of our ability to minimize the risk in our community and environment. |