Heraeus Amersil Inc. - Buford Plant - Executive Summary

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Background Data 
In accordance with Title 40 of the Code of Federal Regulations, Chapter 68 (40 CFR 68)  
promulgated by the Environmental Protection Agency (EPA), Heraeus Amersil, Inc. submits this  
Risk Management Plan (RMP) for operations at their Buford, Georgia facility.  Heraeus Amersil has  
been in operation at this facility for 13 years, providing quality products to customers and over 200  
jobs to the local community. 
Accidental Release Prevention and Emergency Response Policy 
Heraeus Amersil is committed to protecting the health of its employees, the surrounding  
community, and the environment.  It is Heraeus Amersil's policy to maintain a safe and healthy  
workplace, protect the environment, and comply with all applicable regulations, including 40 CFR  
68 and, as applicable, Occupational Safety and Health Organization (OSHA) Process Safety  
Management (PSM) regulations promulgated as Title 29 of the Code of Federal and 
Response regulations (29 CFR 1910.120). 
Stationary Sources and Regulated Substances 
In order to produce the glass cylinders in a useable form for their customers, Heraeus Amersil is  
required to acid etch the cylinders at the facility. Heraeus Amersil purchases, stores, and uses  
Hydrofluoric Acid at greater than 50 % concentration (the 112(r) regulated substance) in the acid  
etching operation. The Heraeus Amersil facility stores more than the 1000 pound 112(r) regulatory  
threshold for 50 % concentration or higher Hydrofluoric Acid and is thus subject to this regulation.  
The Hydrofluoric Acid is used at lower concentration levels to acid etch the glass cylinders  
produced by the facility. Heraeus Amersil's acid etching system consists of piping, valves, pumps,  
and tanks, the largest of which is 6500 gallons capacity.  
Worst Case Release Scenario 
As required by 40 CFR 68, Heraeus Amersil has evaluated a worst-case release scenario for  
Hydrofluoric Acid using the par 
ameters specified by the EPA.  The worst-case release scenario is  
defined as the release of the entire contents of the largest single vessel over a 10-minute period.   
Based on Heraeus Amersil's acid etch system, Heraeus Amersil's worst case release scenario is the  
rupture of the largest single vessel (a storage tank) containing 6,500 gallons of Hydrofluoric Acid  
when filled to 100 % capacity, the maximum physical capacity of the tank.  Using the EPA's  
RMP*Comp program, the maximum distance to the specified "endpoint" (a conservative distance  
established by EPA at which it is expected that a person could be exposed to the chemical for an  
hour without suffering irreversible health effects) is 0.2 miles. 
The worst-case release scenario was developed following EPA regulations and is not considered by  
Heraeus Amersil to be a likely release scenario for the facility.  
Alternative Release Scenario 
A more realistic, though still unlikely, release scenario (alternative release) was d 
eveloped by  
Heraeus Amersil. The scenario considered the operation's 13 year history of experience and the  
hazards identified in the process hazard analyses (PHAs) conducted to ensure that Heraeus Amersil  
hazards are identified and minimized. The release scenario identified by Heraeus Amersil would be a  
release caused by overfilling of the storage tank. In developing the release parameters of this  
alternative scenario, Heraeus Amersil considered the high level alarm designed to alert operators to  
a tank overfill condition, the maximum response time of the facility's operators, and the release  
mitigation provided by the building structure.  Using EPA's RMP*Comp program, the maximum  
distance to the endpoint is 0.1 miles. 
Accidental Release Prevention Program 
To prevent and mitigate accidental releases of Hydrofluoric Acid, Heraeus Amersil has implemented  
several precautionary measures that include process/equipment controls, procedures, preventive- 
maintenance programs, employ 
ee training, and audit programs.  
Heraeus Amersil has also developed and implemented a PSM program pursuant to OSHA  
regulations and as such, has evaluated the system for the potential of Hydrofluoric Acid releases.  
Heraeus Amersil has developed standard operating procedures for all employees and contractors  
that have contact with the Hydrofluoric Acid system that incorporates safety measures into the  
procedures. Pursuant to written management of change procedures established by Heraeus Amersil,  
any changes to the operating procedures are to be communicated to affected employees. 
To ensure that Heraeus Amersil's control measures are effective in maintaining the safe operation of  
the Hydrofluoric Acid system, Heraeus Amersil conducts detailed PSM compliance audits every  
three years. In accordance with the PSM program, each audit incorporates review of process safety  
information, process hazard analysis, operating procedures, training programs, system mechanical  
integrity, man 
agement of change, pre-startup review procedures, compliance audit procedures,  
incident investigation procedures, employee participation programs, hot work permit procedures,  
and contractor safety procedures. 
Five-Year Accident History 
Over the last five years, Heraeus Amersil has not experienced an accidental off-site release of  
Hydrofluoric Acid. 
Emergency Response Program 
Heraeus Amersil has devised a comprehensive emergency response program, designed to protect  
both employees and the community in the event of a release.  This program is fully described in a  
order to facilitate response efforts in the event of a Hydrofluoric Acid release. 
Heraeus Amersil has trained on-site personnel to respond to accidental Hydrofluoric Acid releases.   
These personnel receive initial training and update training thereafter. Appropriate mechanisms are in place to notify the Gwinnett County Fire Department and other 
off-site emergency responders when there is a need for a response.  
Continuing Efforts to Improve Safety 
Heraeus Amersil periodically reviews and modifies its safety systems and procedures in an effort to  
continuously improve safety and prevent Hydrofluoric Acid releases.
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