Heraeus Amersil Inc. - Buford Plant - Executive Summary
EXECUTIVE SUMMARY |
HERAEUS AMERSIL INC.
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
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
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
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
document entitled CONTINGENCY PLAN STANDARD OPERATING PROCEDURES (SOP) in
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.