Photocircuits Corporation - Executive Summary |
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RMP EXECUTIVE SUMMARY 810 Building Chlorine System a. Photocircuits Corporation ("PC") strives to meet or exceed federal, state and local environmental, health and safety requirements at its facilities. The Photocircuits accidental release prevention policy for chlorine involves a systematic approach that integrates design engineering, standardized procedures, process hazard analysis, and management oversight. Photocircuits complies with all applicable procedures of the U.S. Environmental Protection Agency ("EPA") and the Occupational Safety and Health Administration ("OSHA"). System design and operational procedures are consistent with those published and approved by the Chlorine Institute. b. The Photocircuits emergency response plan coordinates the efforts and resources of specially trained in-plant responders, neighboring industrial facilities, and the Fayette County Hazardous Materials ("HazMat") Response Team. Members of the Peachtree City Fire Department ("PCFD") and t he Fayette County HazMat Team 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 necessary equipment required to safely equip emergency responders, contain a release, and monitor possible exposures is maintained at Photocircuits. c. Photocircuits uses chlorine in the manufacture of printed circuit boards that are used in automobiles, computers, and a variety of electronic products. The chlorine supply system at 810 Dividend Drive includes 20 one ton supply cylinders, control valves, vaporizers, regulators, alarms, and additional safety equipment. Trained maintenance employees follow standardized procedures to exchange cylinders and inspect the facility on a daily basis. Specially trained employees, members of the Photocircuits Emergency Response Team ("ERT"), are av ailable onsite to address any trouble alarms that may occur. d. The EPA requires facilities with chlorine inventories exceeding 10,000 pounds, 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 "worst case release" and the "alternative scenario". The worst case release requires the owner or operator to assume that the "maximum quantity in 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 release scenario as the failure of a one ton cylinder. The offsite consequence analysis for this scenario followed the conditions and charts pre-defined by the EPA and found in EPA's RMPComp software. The pre-defined conditions included the release of a full one ton cylinder in 10 minutes, urban terrain and stable weather c onditions. Photocircuits elected not to use the relief granted by EPA for passive mitigation of an enclosure, assuming the worst case scenario to be the failure of a cylinder stored outside of the enclosure. Photocircuits believes that the EPA's defined worst case release is unrealistic for the following reasons: (1) As discussed in paragraph C of this document, the chlorine system is designed with several layers of protection including chlorine emergency scrubbers and integrated alarm systems to mitigate the release of chlorine. In the development of the worst case scenario the EPA does not permit owner/operators to include to include these mitigating measures in the scenario. (2) Even in the unlikely event that a one ton cylinder fails, the full contents of chlorine would not be released in a time span of ten minutes. (3) The Photocircuits Emergency Response Team (ERT) is well trained and would respond promptly, arriving on the scene within minutes to stop the leak well be fore the full contents of a cylinder would be released. (4) Only the population within an elliptical plume extending east-northeast (prevailing wind direction) downwind of the release point is potentially affected. The elliptical plume area is less than 10% of area of the full circle corresponding to the toxic endpoint distance. f. The alternative scenario is defined as conditions more likely to occur than the worst case scenario and permits the application 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 alternative scenario is 100 pounds in 10 minutes. That equates to 10 pounds of chlorine per minute. In such an event, the chlorine alarms would immediately detect the leak, notify emergency personnel, and an emergency chlorine scrubber would activate. Su bsequently, 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 of 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. Automatic shutoff valves will be installed and operational by July 12, 1999, adding an additional mitigation measure. Though the aforementioned equipment will provide an excellent degree of operational assuredness, Photocircuits believes the alternative scenario is accurate based on the facility's historical safety performance. g. The gen eral Photocircuits accidental release prevention program is based on full compliance of the OSHA Process Safety Management Standard and on the following key elements: 7 High level of operator training 7 An effective maintenance program coupled with manufacturer's repair of components 7 Use of state-of-the-art process and safety equipment 7 Use of accurate and effective operating procedures written with the participation of engineers, maintenance employees, contracted chlorine experts, and operators. 7 Implementation of an auditing and inspection program The chemical-specific prevention steps include: 7 Use of protective clothing and self contained breathing apparatus (SCBA) worn by the operators during connection/disconnection of chlorine supply 7 Training for all affected employees of the hazards of chlorine 7 An integrated chlorine detection system 7 Availability of two Chlorine Emergency "B" Kits which are designed by the Chlorine Institute to stop leaks 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 provisions of the EPA Risk Management Program. i. The 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 ERT members. Each shift has an assigned commander and all actions are conducted through an incident command system. The team participates in chemical response, incipient fire, CPR, and first aid training on an annual basis. Additional emergency coordination is conducted through the Fayette County Local Emergency Planning Commission and the Fayette County Resource Council. The last risk assessment was conducted over a period of several days in June 1999. Ten improved safety recommendations were identi fied. We have currently upgraded the cylinder control valve system with the addition of automatic closing safety valves that are controlled by a continuous chlorine detection system. All actions recommended during the June 1999 assessment will be implemented by September 30, 1999. June 21, 1999 |