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. 8. 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 90-ton rail 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. All 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 supplies. 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 to 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 90-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 9 ton/min with an end point of 13.4 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 e xtensive employee training programs are in place in order to prevent an incident or to minimize a release. |