Osram Sylvania Products Inc., Wellsboro Glass - Executive Summary
RMP Executive Summary |
Osram Sylvania Products Incorporated
INTRODUCTION: Osram Sylvania Products Incorporated (Osram) is committed to operating in a manner that is safe for Osram workers, the public and the environment. As part of this commitment, Osram has established systems to help ensure safe operation of the processes at this facility. Toward that end, Osram operates within a Quality Management System, certified under ISO 9002, and an Environmental Management System, certified under ISO 14001. A non-Osram, independent party audits both systems two times per year. Another system is a risk management program (RMP) that helps manage the risks at Osram and that complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR part 68, "Accidental Release Prevention Requirements: Risk Management Programs" (the RMP rule). One of the requirements of the RMP rule is to submit a risk management plan (RMPlan) describing the risk management program at
Osram. This plan is intended to satisfy the RMPlan requirement of the RMP rule ('68.150 through '68.185) and to provide the public with a description of the risk management program at Osram.
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES: Osram is committed to the safety of Osram workers and the public, and to the preservation of the environment, through the prevention of accidental releases of hazardous substances. Osram implements reasonable controls to prevent foreseeable releases of hazardous substances. In the event of an accidental release, Osram controls and contains the release in a manner that will be safe for workers and will help prevent injury to the public or the environment.
OSRAM, WELLSBORO FACILITY and REGULATED SUBSTANCES: The Osram, Wellsboro plant processes raw materials by melting them to form glass envelopes for the lighting industry. The energy required to turn the raw materials into molten glass is provided by natural gas, with propane as a b
ack-up energy source. The Osram Company also processes glass envelopes and uses hydrofluoric acid and aqueous ammonia in its glass etching process. The etching process produces frosted lighting envelopes.
Hydrofluoric Acid: HF acid at solution concentrations of 50 wt% or greater are regulated by the RMP rule. Although only dilute (about 28 wt%) HF solutions are used in the etching process, HF acid at a solution concentration of 70 wt% is stored in a large tank at the Osram facility for use in the process.
A maximum of 5,330 gallons of 70 wt% HF acid is stored in one 5,922 gallon tank located at the Osram site. The weight of HF acid in 5,330 gallons of 70 wt% solution is just under 38,000 lb., which exceeds the RMP rule threshold quantity for HF acid in a process (1,000 lb.) Because the HF acid storage process is not covered by requirements of the Occupational Safety and Health Administration's process safety management regulation and because the potential exists for offsite con
sequences resulting from an accidental release of HF acid, the process falls under the RMP Program 2 prevention program.
Aqua Ammonia: Aqueous Ammonia at solution concentrations of 20 wt% or greater are regulated by the RMP rule. Although only dilute (about 12 wt%) Ammonia solutions are used in the etching process, Ammonia at a solution concentration of 30 wt% is stored in a large tank at the Osram facility for use in the process.
A maximum of 12,000 gallons of 30 wt% Ammonia is stored in one 12,000 gallon tank located at the Osram site. The weight of Ammonia in 12,000 gallons of 30 wt% solution is just under 27,000 lb., which exceeds the RMP rule threshold quantity for Ammonia in a process (20,000 lb.) Because the Ammonia storage process is not covered by requirements of the Occupational Safety and Health Administration's process safety management regulation and because the potential exists for offsite consequences resulting from an accidental release of Ammonia, the process falls
under the RMP Program 2 prevention program.
OFFSITE CONSEQUENCE ANALYSIS: The RMP Rule requires Osram to perform and offsite consequence analysis for one worst-case and one alternative release scenario for toxics and flammables. Aqueous HF acid and aqueous Ammonia are toxic substances.
HF Acid: The worst-case release scenario is failure of the 5,922-gallon storage tank, releasing 54,200 lb. of aqueous HF acid (70 %wt). A diked area and containment building confine the released aqueous HF acid, which evaporates, forming a vapor cloud. The maximum distance to the toxic endpoint concentration is 0.2 mile. Several houses are located within this distance from the storage tank, with a total population of about 130 people; no environmental receptors are within this distance.
The alternate release scenario for aqueous hydrofluoric acid is pipe leak in the schedule 160 liquid line connecting the aqueous HF acid (70 wt%) storage tank to the process catch basin. This scenario assumes tha
t the solution is released for 10 minutes before workers detect the release and isolate the line. The released acid forms a pool, with HF evaporating in the pool and forming a vapor cloud. The maximum distance to toxic endpoint is 0.2 mile. Several houses are located within this distance from the storage tank, with a total population of about 130 people; no environmental receptors are within this distance.
Aqua Ammonia: The worst-case release scenario is failure of the 12,000-gallon storage tank, releasing 89,700 lb. of aqueous ammonia (30 %wt). A diked area contains the released aqueous ammonia, which evaporates, forming a vapor cloud. The maximum distance to the toxic endpoint concentration is 0.2 mile. Several houses are located within this distance from the storage tank, with a total population of about 130 people; no environmental receptors are within this distance.
The alternate release scenario for aqueous ammonia (30 wt%) is a transfer hose failure during the unloading o
f a bulk delivery truck into the 12,000-gallon storage tank. This scenario assumes that the solution is released for 10 minutes before workers detect the release and stop the unloading. The released aqueous ammonia forms a pool, with ammonia evaporating in the pool and forming a vapor cloud. The maximum distance to toxic endpoint is 0.1 mile. Several houses are located within this distance from the storage tank, with a total population of about 50 people; no environmental receptors are within this distance.
ACCIDENTAL RELEASE PREVENTION PROGRAM and CHEMICAL-SPECIFIC PREVENTION STEPS: The RMP rule requires a Program 2 prevention program for aqueous HF, aqueous ammonia processes. The following paragraphs describe the prevention program elements at Osram that apply to these units.
Safety information: Osram maintains a variety of technical documents that are used to help ensure safe operation of the Osram processes. Material safety data sheets document the physical properties of h
azardous substances handled at Osram, including HF acid, and Aqua Ammonia. The engineering design documents include the operating parameters, the design basis and configuration of the equipment in each covered process, and references to applicable codes and standards.
Hazard review: Osram performs and periodically updates hazard review of the covered processes to help identify and control process hazards. Checklists are used to guide the hazard review. These checklists include items to help ensure that Osram operates and maintains the equipment in a manner consistent with the applicable design specifications, codes, standards and regulations.
Operating procedures: Osram develops and maintains operating procedures to define how tasks related to process operations should be performed. The operating procedures are used to (1) train employees and contractors and (2) serve as reference guides for appropriate actions to take during both normal operations and process upsets. All operat
ing procedures, instructions and records fall within the Quality Management System, certified under ISO 9002, or the Environmental Management System, certified under ISO 14001.
Training: Osram trains personnel in the operating procedures to help ensure safe and effective performance of their assigned tasks. A training documentation file is maintained to help ensure that refresher training is provided as necessary. All training procedures, instructions and record keeping fall within the ISO 9002 or ISO 14001 systems.
Maintenance: Osram properly maintains the process equipment. The Osram maintenance program includes ISO 9002 or 14001 procedures to (1) safely guide workers in their maintenance tasks, (2) train workers in the maintenance procedures, and (3) inspect and test equipment and processes to identify deterioration and damage before the equipment fails.
Compliance audits: Osram performs periodic compliance audits, of covered processes to verify that the processes are operat
ing in compliance with the requirements of the RMP rule. A compliance audit checklist is completed during each audit, and any deficiencies noted by the audit are corrected in a timely manner.
Incident investigations: Osram investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public, or the environment. Osram trains employees to identify and report any incident requiring investigation. An investigation team is assembled, and the investigation is initiated within 48 hours of the incident. The results of the investigation are documented, recommendations are resolved, and appropriate process enhancements are implemented.
Process-specific prevention steps: Industry standards are followed at Osram to help ensure safe handling of aqueous HF and aqueous Ammonia. The vendors for these materials supply them via Department of Transportation (DOT) approved tank trucks, and follow DOT standards when loading the respective Osram storage tanks.
The covered processes storage tank design and construction are consistent with American National Standards Institute standards. All employees receive documented annual training in Right-to-Know and Emergency Response Procedures at the Awareness Level. Workers who perform operations involving the covered processes receive training emphasizing safe handling procedures developed by Osram. An Osram HAZMAT Team of certified technicians is available for material releases.
Five-year Accident History: Osram maintains a 5-year accident history that fulfills the requirements of the RMP rule ('68.42). No releases of regulated substances have occurred from Osram in the last 5 years that have resulted in consequences of interest, or that had the potential to result in consequences of interest.
Emergency Response Programs: Osram has established written response plans that comply with the RMP rule and with other federal contingency plan regulations. This plan has been communicated to local em
ergency response officials through the Tioga County Emergency Management Agency, and the Wellsboro Fire Department. Regular dialogue is maintained between Osram and the Tioga County Local Emergency Planning Committee through the Osram Environmental Engineer, who is a member of the LEPC. Osram provides appropriate information to the Wellsboro fire chief, and a lock-box with the Facility Off-Site Response Plan is kept at the plant entrance, for the fire chief. Osram periodically conducts emergency response drills, including drills coordinated with the fire department and the LEPC.
Planned Changes to Improve Safety: Osram constantly strives to improve the safety of the processes through both the incident investigation program and a program soliciting safety suggestions from the workers. The following changes to improve process safety are planned or have been recently completed:
7 Osram is re-routing the 2,400V main power feed lines away from the propane storage tanks. The re-routin
g will help ensure that any catastrophic break in these high voltage power lines will not result in contact with the 30,000 gallon propane storage vessels.
7 Osram intends to install a second fire suppression monitor nozzle at the West Side of the propane storage tank area. This suggestion was made by the local fire department.