Guardian Industries Corporation-Carleton Facility - Executive Summary

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Executive Summary 
Guardian Industries - Carleton Michigan 
June 1999 
This Risk Management Plan is written in accordance with all governmental guidelines and mandates.  It is completed in an effort to develop a plan for responding to sulfur dioxide exposure.  Currently we use this chemical in three areas of the plant for the same purpose.  That is to encourage gripping of glass as it passes through an annealing oven. 
I. Plant Location 
The Carleton plant located within Ash Township at 14600 Romine Road, Carleton, Michigan, at which a total of 400 production employees and 125 administrative personnel are employed.  The facility size is 880, 000 square feet and comprised of two glass melting furnaces, one electric tempering furnace and one glass coater.  Although production is a twenty-four hour operation, regular business hours are from 8:00am to 4:30pm, Monday through Friday.  Facility 24 hour phone number:  (313) 654-6264. 
II. Parent Corporation 
Guardian Industries World Headquar 
ters location is 2300 Harmon Road, Auburn Hills, Michigan   48326.  Facility twenty-four hour phone number: (810) 340-6264. 
III. Historical Background 
Guardian Industries was incorporated in 1968 as successor to the Guardian Glass Company, a privately owned company engaged in the manufacturing of automobile glass since 1932.  In 1970, the company began the manufacture of flat glass by the float process in this, the Carleton Plant.  The immediate success of this type of glass manufacturing and excellent final product warranted the installation of a second float glass line in 1973. 
Guardian Carleton also installed an electric powered Vertical Furnace in 1971 to temper specialized pieces of glass.  For improved production, this was dismantled and replaced in 1973 with a gas fired Air Hearth, which was eventually replaced in 1978 with the electric Roller Hearth currently in use. 
In 1991 a coating operation was added to this plant.  Originally installed across the street, it was reloc 
ated and to the south end of this plant and has over time been updated to accommodate the variety of surface coatings add to the glass. 
IV.Current Status 
Currently Guardian Industries is a worldwide manufacturer of flat glass, fabricated glass products used in the architectural and automotive industries.  Guardian's fabricated glass products include heat-treated and tempered safety glass, insulating and reflective glass for the residential and commercial construction industry, and laminated windshields and tempered side and rear windows for the automotive industry.   
V. Production Process 
Identified under SIC Code 3211, the following operations are housed within the 17.2 acre manufacturing facility: 
Administration and Personnel 
Engineering and Maintenance 
Production Control and Sales 
Inventory Control 
Float Glass  
Warehouse Storage 
Guardian's Carleton Facility manufactures glass by the "float" method.  In this process, silica sand, limestone, dolomite, 
soda ash, salt cake and recycled glass are melted at approximately 2700: F in a gas-fired furnace.  The molten glass then leaves the furnace and "floats" on a pool of molten tin, where it is formed and drawn out as a continuous ribbon.  After leaving the tin bath, it is drawn through an annealing oven where its temperature is gradually reduced.  It is here in this oven, called a lehr, that sulfur dioxide is used to coat the rollers as an aid in moving glass through the system.  Glass passes through the lehr and into the packing section of the plant.  Once inspected it is cut to size and packed for shipment. 
The electrically powered Roller Hearth is used to temper specially sized glass for automotive and architectural use.  Glass is physically seamed, or sanded to remove burrs on its edge, and then it is placed on a conveyor line leading to a washing system for removal of large dirt particles.  The conveyor system delivers the glass into the electric furnace where it is heated to appr 
oximately 13000 and quickly cooled to complete the tempering process. 
The coating line utilizes the principles of sputtering.  The glass is cleaned in a five station washing area, then moved through a series of increasing vacuum chambers for eventual exposure to a metal covered target where sputtering onto the glass, takes place.  Glass then passes through decreasing vacuum chambers to the ambient air to eventually be inspected and packed for shipment. 
VI. Emergency Coordination 
Guardian Industries has developed and abides by safe work practices when interacting with hazardous materials.  Management is committed to creating a safe work environment and employees are encouraged to report unsafe work practices or tools as one means to preventing accidents.  Joint cooperation between employees and management in the observance of safety and health policies is considered to be of first importance and mutual cooperation and dedication are necessary in making all safety policies successfu 
In accordance with government regulations, Guardian Industries has appointed the plant Engineering Manager as emergency coordinator who shall be responsible for coordinating and implementing emergency contingency plans. 
The Emergency Coordinator must be on the premises or if off-site, on call and located such a distance that he can reach the facility within a short period of time.  He must be thoroughly familiar with all aspects of this plan, all operations and activities at this site, the location and characteristics of waste handled, the location of all records within the facility and the facility layout.  In addition the emergency coordinator must have the authority to commit the resources (personnel and monetary) to carry out these emergency plans. 
VII. Preventive Measures 
During an emergency the emergency coordinator must take all reasonable measures necessary to ensure that fires, explosions and releases do not occur, recur or spread to other hazardous materials on-site.  
These measures may include stopping processes and operations, removing or isolating containers, monitoring for leaks, pressure buildup, gas generation, ruptures in valves or other equipment. 
VIII. Facility Personnel 
The Emergency Coordinator will direct actions of all facility personnel in     accordance with this plan, to: 
1.) Identify hazards and assess extent of potential harm to human health or the environment. 
2.) Notify, as necessary, the appropriate Emergency Response contacts. 
3.) Respond in cooperation with outside agencies to minimize hazards. 
4.) Follow up response actions with required reports (verbal and written). 
IX. Plan Revision 
These procedures shall be reviewed and immediately amended, if necessary whenever: 
7 The plan fails in an emergency. 
7 The facility changes - in its design, construction, operation, maintenance, or other circumstances, in a way that materially increases the potential for spills or releases other or changes the response necessary in an emerge 
7 The list of personnel conducting the emergency coordination responsibilities. 
7 The list of monitoring or emergency equipment changes. 
7 Applicable regulations are revised. 
X. Coordination Agreements 
Coordination arrangements have been established and agreed to by local police departments, fire departments, hospitals, contractors, state and local emergency response teams to coordinate emergency services. 
XI. Five Year Accident History 
Within the last five years there has been one sulfur dioxide exposure which took place November 1995, when a temporary worker was asked to assist an engineer on the production line.  Investigation found a leaking hose which was fixed immediately.  The employee was taken to the hospital for observation since he also suffered from asthma. He was released a few hours later.   
XII. Worst-Case Release and Alternate Scenario's 
Anhydrous sulfur dioxide is stored on-site in one ton containers.  Our worst scenario would entail the unexpected release 
of this substance if a tank should be punctured or otherwise damaged.  Approximately 2000 pounds of this chemical would be released having the potential to reach an endpoint of 2.10 miles within a 10 minute period according to EPA Guidelines.  Within this radius a Guardian owned recreational facility, residences, farmland, schools, a park and other businesses are located.  Tanks are currently stored in a horizontal position at the south end of the plant on an outdoor pad.  They are stored in a low traffic area and are unlikely to be damaged.  Tanks used within the plant rest on specially designed racks raised above the ground.  Personnel required to change out the tanks are properly trained in the procedure and personnal protective equipment needed to perform the task safely. 
In an alternate scenario there is the possibilty that a pipe or hose may leak.  Immediately an alarm will sound indicating which tank is at fault.  This alarm is located in the tin bath control room which is man 
ned 24 hours a day.  If such a release were to happen within seconds the tin bath operator would realize the sudden drop in pressure and would summons maintenance assistance. 
However, if such an event happened, release time would be less than one minute.  With a wind speed of 3.0 miles/second the distance to end point would be 1.00 miles.  Within this area, Guardian Industries Recreational Facility, a park, school and several residences and businesses are located. 
XIII. Chemical Release Prevention and Planned Safety Improvement. 
Guardian continues to review procedures and update equipment to ensure the absence of sulfur dioxide exposure.  The massive revamping of the alarm systems this past year enables us to be aware of leaks seconds after the leaks begin.  Accordingly Guardian reviews and updates the PHA for sulfur dioxide to ensure all safety measures and precautions are taken.
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