IBM East Fishkil Facilityl - Executive Summary |
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Executive Summary In order to comply with the Risk Management Program regulations, 40 CFR part 68, mandated under the accidental release provisions of the Clean Air Act Amendments of 1990, the International Business Machines, (IBM) Corporation is submitting this Risk Management Plan for the East Fishkill Facility. Hydrogen is currently the only substance which is stored in a quantity greater than the reporting threshold and required to be included in this submission. Hydrogen is currently stored in two separate locations within the facility. A process Hazard Analysis is conducted on a five year schedule by the process hazard analysis team. The team is composed of a Team leader (also Gas Engineer) , Safety Representative for gases, Gas Technicians, Manufacturing Representative, Emergency Control Representative, and an Engineer from Air Products (vendor). The results are recorded and maintained on file. Operating procedures were written by the Gas Engineer using technical proce ss description, process safety information, and in cooperation with the affected employees. Operating procedures are currently available where specified in Process Safety Management, (PSM) Documentation or in Central Utilities System 1 department, (D/20G), "Bulk Gas Procedures & Desk References located in B/316". Training is formulated and tracked by the Gas Engineer and training records are maintained by the D/20 G Manager. The Mechanical Integrity is shared between the gas supplier and IBM. The program consists of equipment lists and specifications, equipment history, preventative maintenance procedures. The Vendor is audited by IBM every three years as required by PSM to assure compliance to all requirements. Hot work permits for hydrogen are issued by D/20G "High Purity Gases Piping Permit". This permit includes inspecting the area for safety. In addition to the Hot Work Permit most jobs may also require an open flame permit to be issued by Emergency Control. Manageme nt of Change, (MOC ) program is quality assured by the Process Safety Management Owner. The MOC is composed of written program with elements delegated to appropriate members of the PSM team. A copy of the documentation is maintained for the life the process. There is a written pre-startup review program quality assured by the Process Safety Management Owner. Progress is documented and maintained as part of MOC program. Incident investigation program follows The IBM Incident Report Procedure in the Safety & Health Manual, Index 4-03-14A for fact determination, root cause analysis and recommendation implementation. Employee participation is incorporated in each element program description. A maximum of 43,000 pounds of hydrogen are inventoried to produce semiconductor and related products. The Worse Case Flammable release of hydrogen is calculated at 0.3 miles by RMP*Comp. The Alternate Case Flammable release of hydrogen is calculated at 0.2 miles by RMP*Comp. Release prev ention of hydrogen uses Mass flow monitoring, automatic shutoff valves and/or interlocks, automatic alarms and procedures. Operator refresher training and system update training are conducted on the prescribed basis of the operator training program. The maintenance program inspections and tests to assure operation of the prevention devices. Management of change is monitored by the Process Safety Management Coordinator to assure the program is updated, and implemented according the corporate standards for design and operation. All incidents are investigated to determine root cause and system deficiency correction. The company has not experienced any accidents/incidents involving hydrogen in the past 5 years. The IBMEF emergency response program was designed and updated to the EPA Integrated Contingency Plan Guidance. The plan defines response organization, coordination with local emergency respones committee, equipment, response procedures, training, notification procedures and d rills. The plan is updated according to the recommendations resulting from system deficiencies uncovered by periodic drills. IBMEF plans no safety improvements at this time because the hydrogen storage facility is currently maintained and operated at the state of the art level. |