Sony Technology Center-Pittsburgh - Executive Summary

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A) Facility Description 
    The Sony Technology Center - Pittsburgh (STC-P) is located at 1001 Technology Drive in East Huntingdon Township, Westmoreland County, Pennsylvania.  The facility is located in close proximity to State Route 119, Pennsylvania Turnpike (Interstate 76), and Interstate 70.  Sony Electronics Inc. consists of three operations: Cathode Ray Tube (CRT) and component manufacturing, Color Television (CTV) assembly, and support functions which include Wastewater Treatment Plant and Central Utilities Plant. 
B) Aperture Grille (AG) Manufacturing Division        
    AG department produces aperture grilles or masks- a CRT component- that are a thin sheet of cold rolled steel located inside a cathode ray tube (CRT) between the electron gun and panel glass.  The RMP is being submitted for Chlorine used in the production of AGs.  
    B1) Aperture Grille Process 
         The aperture grille or mask serves as a screen to block stray el 
ectrons from hitting the wrong color   
    phosphor on the panel glass.  Each grille contains several hundred apertures or slits.  The  
    manufacturing process begins with a rolled steel coil.  The coil is unwound and transferred through a  
    series of chemical process tanks and chambers.  Transfer of the material, or web, is accomplished via  
    a series of nip rollers, steering, and drive mechanisms.  The coil remains continuous until the final  
    shearing is performed.  Primary web processing steps are as followings: 
    1. Clean and degrease with an alkaline solution. 
    2. Coat with a photo-sensitive material followed by drying.   
    3. Print the desired aperture pattern on the web using high intensity UV light exposure.   
    4. Develop the aperture pattern. 
    5. Etch the aperture grille pattern on the web using ferric chloride solution. 
    6. Strip coatings with sodium hydroxide solution and rinse. 
    7. Shear the aperture grille to proper size. 
Inspect and pack. 
    All wet processes are exhausted to four fume scrubbers equipped with mist eliminators. 
C) Chlorine System & Its Safeguards  
    In accordance with OSHA requirements of the process safety management (PSM) regulation, 29 CFR 1910.119, the chlorine supply system was validated in 1993 for process hazard analysis (PHA ).  In addition, to comply with PSM regulation for updating PHA every five years, the chlorine system underwent the revalidation of PHA in July 1998.  A number of preventive engineering design features and procedural steps have been established in order to reduce the risk of occurrence of an incident and/or its severity.  The safeguards have been categorized into stationary source siting, equipment, and documentation. 
    C1) Stationary Source Siting   
         Chlorine is received (as liquid) via rail service in 55-ton tank car in a protected area away from any  
    on-site traffic and other process equipment.  Liquid chlorine is then conver 
ted to vapor form which is   
    the physical phase required for converting FeCl2 to FeCl3 (regeneration of FeCl3).  The chlorine tank  
    car as well as the facility are being monitored on a 24-hour basis by security surveillance cameras and  
    security guards.  The chlorinators and vaporizers are situated in a room which is isolated from the  
    supply system. All administration & engineering offices as well as auxillary services such as machine  
    shops and labs are located outside the supply system.  Due to increase in production and in order to  
    reduce the frequency of connection and/or disconnection of the chlorine vessel, the facility has  
    changed from 17-ton tanker truck to rail car. 
    C2) Equipment Safeguards 
        The facility has a Total Preventive Maintenance (TPM) program on equipment according to the  
    recommended schedule by the manufacturer.  The PM program requires for periodic inspections of  
    tanks, piping, and other equipment to e 
nsure their proper working conditions.   Included in the  
    inspections that are routinely conducted by the chlorine personnel are the following: 
    - Reviewing the operation status reports prepared by the previous shift. 
    - Several daily walkthroughs of the system for possible leaks or other abnormalities using portable  
      analytical equipment. 
    - Testing and inspecting of alarms, detectors, piping, and instrumentation in accordance with Total  
      Preventive Maintenance (TPM) program.   
    - Annual inspection of relief valves and rupture disks which includes removal, inspection, testing, and  
      replacement if necessary.      
         A number of audible alarms are in place throughout the facility.  The Chlorine alarms are linked to the  
    security office via a Builiding Automated System (BAS).  In addition, several sensors that are capable  
    of detecting chlorine are installed around the supply system, fume scrubber stacks, etching process,  
and the aperture grille building.  Additional equipment and related safeguards are:     
    - The chlorine system is operated via a panel that is equipped with emergency power. 
    - An excess flow valve as well as thermal expansion relief provided on the supply system with  
      pressure indication on the expansion chambers.           
    - To limit the amount of chlorine that could potentially be released due to ruptures, the supply line is   
      divided into several sections with isolation valves which will be shut off automatically.   
    - High pressure alarms are installed to notify the operators should a rupture disk open. 
    - Fail/safe settings for critical valves should loss of utilities occurs.  
    - The emergency stop buttons are present in accessible locations.  The operators can manually use the  
      E-stops should other engineering control devices fail. 
    - The sodium hydroxide purge scrubber will evacuate chlorine from the pressure side piping and  
    neutralize it.   
    - Safety equipment such as self contained breathing apparatus units, shower/eyewash stations, and  
      respirators are strategically located throughout the process.   
    - Several windsocks are in place throughout the facility to assist personnel in identifying the safest  
      routes for evacuation.                      
    C3) Documentation   
         The facility is certified for both ISO 9002 and ISO 14001 systems and has established a broad range  
    of written policies and procedures for the chlorine system.  The documentation covers areas such as  
    operating standards, preventive maintenance, confined space entry, hot work, lockout/tagout, and  
    possible line breaking.  Also in compliance with OSHA process safety management regulations, the  
    documentation system provides written procedures for management of change, dealing with incident  
    investigations and corrective actions resulting from the incident. 
operators of the chlorine system undergo an extensive training program prior to being validated   
    to operate the system.  The training includes full understanding of the procedures that relate to  
    startup/shutdown, normal operation, and emergency situations.  In addition, a designated group of  
    individuals including all operators of the chlorine system receive a 40-hour "Hazardous Materials  
    Technician" training course along with quarterly refresher courses which provide them with detailed  
    instructions of how to respond to emergency situations.  This training also provides the facility  
    with an on-site presence of qualified Haz-Mat Response personnel at all times to reduce the  
    response time to an emergency situation.  
D) Emergency Response Plans 
    The facility has established a Preparedness, Prevention, & Contingency (PPC) plan that consists of a Hazardous Materials Emergency Response and an Emergency Action Plan.  In addition, Sony has coope 
rated with the Local Emergency Planning Committee for the Emergency Planning District of Westmoreland County to develop an Off-site Response Plan in accordance with the provisions of the Superfund Amendments and Reauthorization Act of 1986 (SARA Title III), and PA Act 165 of 1990.     
    The Hazardous Materials Emergency Response and Emergency Action Plans set forth facility's procedures for responding to emergency situations.  These procedures include: 
1. Procedure to follow upon discovering a fire or chemical release 
2. Management line of authority 
3. Response ground rules 
4. Support personnel 
5. Evacuation. 
    Management line of authority at the scene of an emergency, support personnel, and evacuation procedures are part of the PPC plan.  Management at the scene of an emergency and higher authority policies set forth the responsibilities and chain of command of management in the event of an emergency incident.  The support personnel section sets forth duties and responsibiliti 
es for members of the HazMat Team responding to an emergency situation.  The evacuation section (Emergency Action Plan) sets forth notification signals and recommended emergency escape routes for each department in the event an evacuation would become necessary.  These elements of the emergency response plan have been incorporated into the PPC plan. 
    D1) Implementation of Preparedness, Prevention, & Contingency (PPC) Plan  
         In case of a chemical release or fire the Incident Commander/Emergency Coordinator (IC/EC) takes  
    full responsibility for the situation and will contact the proper channels of authorities at both the  
    management level of facility and the outside agencies.  The IC/EC is familiar with all elements of the  
    contingency plan, facility operations & locations, and characteristics of hazardous materials.  This  
    individual remains in control of all activities and personnel (such as response supervisors and Haz-Mat  
    team) unless an outsi 
de response team is requested to arrive for the purpose of controlling the release  
    or fire.  The PPC plan contains an updated list of Incident Commanders whom at least one is required to  
    be on-site or on call at all times.     
         The facility provides a 24-hr medical coverage consisting of full time registered nurses and  
    Emergency Medical Technicians.  In the event of a situation with potential to cause injury, the PPC plan  
    contains a list of local and regional hospitals that are familiar with the facility.   
    D2) Employee Training Program 
         During initial site orientation, all new employees are given an awareness training on the chlorine  
    system, means of reporting emergency situations to site officials, the evacuation routes for fire and  
    chlorine release, and specific departmental gathering points & procedures.  In addition to an overall site  
    awareness,  employees also receive a Hazard Communication training in accordance  
with OSHA  
    requirements 29 CFR 1910.1200 regulation.  The HazCom training is specific to each work area and  
    provides the individuals with information about potential hazards of handling chemicals and identifies  
    safe work practices.  
    D3) Emergency Equipment 
         The facility maintains a large inventory of equipment and materials for response in case of  
    emergency.  Some of the items include self contained breathing apparatus units; full face respirators  
    with various cartridges; level-A encapsulating and level-B suits; portable gas detectors being capable  
    of detecting % LEL, % oxygen, and ppm level of chlorine; Drager pumps with various colorimetric tubes;  
    chlorine Institute emergency "C" kit; neutralizing supplies and decontamination tools; and first aid  
         All emergency equipment is required to be inspected periodically with proper maintenance and  
    cleaning after every response operation.   
An annual inventory of all equipment throughout the site is  
    also conducted.   
    D4) Westmoreland County Off-Site Emergency Response Plan 
         The Off-site Response Plan was developed with the Local Emergency Planning Committee for the   
    Emergency Planning District of Westmoreland County to develop an off-site emergency response plan.   
    The plan details emergency release notifications, off-site evacuation areas and routes, traffic control  
    points and staging areas, local emergency response units, list of hazardous substances, hazard  
    analysis, chemical transportation routes, emergency equipment list, and potential cleanup contractors. 
         The emergency release notification requirements, list of hazardous substances, local emergency  
    response units, hazard analysis, emergency equipment list, and potential cleanup contractors sections  
    are directly applicable the PPC plan.  These elements of the off-site response plan are incorporated in 
    the PPC plan. 
E) Accident History 
    In the past five years, as a result of various safety features and comprehensive employee training, the facility has had no reportable incident.  One minor incident occurred on July 27, 1995 in which one pound of chlorine was released.  Following the incident, corrective actions were immediately issued and all the actions were completed by August 10, 1995 (in two weeks).  In addition, through the management of change procedure, other safety design features have been added to improve the chlorine system since the incident. 
F) Release Scenarios 
    The facility has registered the chlorine system as a program 3 process.  Under the RMP, two separate release situations for the chlroine system were analyzed.  Although the facility is located in an area of rolling terrain, it is considered as "urban" for the release determination purposes.  This is due to presence of several obstacles such as terrain, hills, trees, glass manufacturing plant 
, warehouse building, and an industrial park which are in close proximity to the facility.  The Wastewater Treatment Plant (WWTP)  Guidance was used to determine the end points for both worst case and alternative releases.  The endpoint for chlorine is assumed to be 3 ppm (8.7 mg/m3).  The atmospheric conditions, according to the guidance, are an ambient temperature of 77F and humidity of 50 percent.  In order to determine whether any public and/or environmental receptors are located within the hazard area, software (LandView III) and USGS maps were utilized.   
    F1) Worst Case Scenario 
         The analysis is based on release of the full content of a 55-ton rail car which is presently being  
    used.  In order to determine the offsite consequences of a worst-case release and based on the EPA   
    Wastewater Treatment Plant (WWTP) Guidance, the following assumptions were made: wind speed of  
    1.5 m/sec under very stable atmospheric conditions (class F) which allow for low 
er plume dispersion  
    and higher concentration; the duration time in which the release occurred is 10 minutes at ground level.   
    According to the results, the release rate is 5.5 ton/min with an end point of 10.4 miles.  Within this  
    endpoint, there are several public receptors, however no environmental receptors can be identified.     
    F2) Alternative Release Scenario 
         The modeling is based on release of 64 lbs of liquid chlorine in one minute due to a failure of supply  
    line under a wind speed condition of 3 m/sec.  The selection of wind speed is based on the EPA's  
    Offsite Consequence Analysis (OCA) Guidance which allows use of neutral atmospheric stability  
    (class D) resulting in greater plume dispersion and lower concentrations.  This will result in an end  
    point of 0.15 mile within which no public receptors are located nor are there any environmental  
    receptors.  Equipment safeguards (such as those identified in section C2) and 
    employee training programs are in place in order to prevent an incident or to minimize a release.
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