Cabot Performance Materials - Executive Summary |
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Cabot Performance Materials, located in Boyertown, Pennsylvania, is committed to ensuring a safe work environment for the employees and the community. To this end, the management strongly supports the implementation of safe procedures for all aspects of operation, including the processing of the one regulated substance: hydrofluoric acid, greater than 50% by weight (HF). The facility follows the regulation and intent of the Environmental Protection Agency's (EPA) Risk Management Program (RMP). This facility utilizes HF as an integral component of the manufacturing operations of inorganic compounds and refining of nonferrous metals. HF is delivered to the facility in tank trucks. Delivered HF is unloaded into one of three bulk HF storage tanks. During delivery, the HF truck is connected at an unloading connection and an on-the-truck compressor performs the off-loading. At all points during delivery, a qualified facility employee and qualified personnel from the supplier remain w ith the delivery truck. From the bulk HF storage tanks, measured quantities of HF are pumped into process vessels in five buildings. Once the HF is added to a process vessel, the concentration of HF drops below 50% by weight and is no longer regulated by RMP. As part of the RMP requirements, facilities which contain a regulated substance (such as HF) at quantities exceeding 1,000-pounds as HF must consider the impact of a worst-case and an alternate-case release of the substance. To determine the potential impact a release could have, Cabot Performance Materials utilized the Areal Locations of Hazardous Atmospheres (ALOHA) Model developed by the National Oceanic and Atmospheric Administration and the EPA, and the EPA Offsite Consequence Analysis Guidance reference tables and equations. By definition, a worst-case release involves a catastrophic failure under the worst possible atmospheric conditions, and is therefore extremely unlikely. For this facility, the worst-case scenario is the failure of a bulk storage tank, located inside adequate containment, when filled to capacity. HF evaporates from the liquid pool formed in the containment area. The vaporized HF is predicted to reach offsite endpoints and nearby public receptors; no sensitive environmental receptors would be impacted. The bulk HF storage tanks are on a regular maintenance and inspection schedule and are in a protected and isolated location, making a catastrophic failure all the more unlikely. CPM has implemented an HF Mitigation Plan to reduce the potential emissions that would occur under a worst-case scenario of a failure of a bulk HF tank into a containment area. Alternatives were evaluated and passive mitigation methods were selected to reduce emissions from each of the three bulk HF tank containment areas. For two of the areas, a sufficient quantity of floating balls was placed into the dike to reduce the effective surface area for vapor emissions in case there is an HF spill into th e dike. The plastic balls will float on the surface of the liquid in a tightly packed double layer that will reduce the exposed liquid surface area by 91%. The reduced liquid surface area dramatically reduces the liquid loss to the atmosphere through evaporation while the liquid is safely transferred to another storage container as necessary. The third containment dike has been modified to include a vapor suppression grate. The grate will allow liquids to rapidly drain through the grate into the containment area. The grate reduces the exposed liquid surface area by 54%, reducing HF evaporation to the atmosphere from the pooled liquid. The floating ball cover and vapor suppression grate mitigation approach has reduced the off-site consequence analysis distance by 72% and reduced the potentially affected residential community by 100% (zero population). The alternate-case release which was evaluated involves a leak from the weigh tank. This release would also occur within the cont ainment with the floating ball cover. In this situation, evaporating HF would leave the property boundaries and would reach a minimal number of offsite endpoints; again, no sensitive environmental receptorsor population would be impacted. A regular maintenance and inspection schedule reduces the potential for release. As part of this facility's commitment to provide a safe work environment, Cabot Performance Materials continues to implement a number of management programs to enhance safety. Monthly safety meetings are conducted for all plant employees to evaluate plant safety issues. Specific HF-related training is given to all operators of the HF systems. All components of the HF systems are covered under a Mechanical Integrity program to assure that they operate safely and are physically sound. Appropriate standard operating procedures (work instructions) are in place for start-up and shutdown of the processes, in both normal and emergency situations. Information on the chemi cal, process technology, and equipment has been compiled. All changes to the process are reviewed under management of change procedures. Pre-startup safety reviews are conducted prior to the implementation of any process change. Contractors receive extensive safety training prior to beginning work in the facility including the hazards and safe handling of HF. Competence of the contractor employees is assured as part of the contractor selection program. Hot work and other safe work permit programs are in place in the facility. A process hazard analysis was conducted to identify potential hazards and areas for improvement. Cabot Performance Materials demonstrates its commitment to public and worker safety by a continued accident prevention program. Any incidents are investigated to determine the root cause and to identify changes to prevent recurrence. Even minor incidents and near misses are investigated to identify what went wrong and to learn how to prevent future occurrenc es. The Risk Management Program is outlined and discussed in a RMP manual in use at the facility. In the event of an HF release, Cabot Performance Materials has in place an Emergency Response (ER) Plan which is reviewed and updated whenever a significant change to the HF systems occurs. All employees have been trained on the notification and evacuation procedures detailed in the ER Plan. Cabot Performance Materials maintains an onsite Emergency Response Team that responds to all HF incidents. The team is trained to administer first aid treatment following the HF protocol, which uses calcium gluconate. A member of the team would go with injured personnel to the hospital to ensure continued treatment appropriate for HF exposure. The facility's emergency response plan establishes a written procedure to follow in the event of a release. In the event of a major release, the plan calls for a facility evacuation and notification of the Berks County HazMat Team and the local fire depart ment. The emergency response plan also contains procedures to alert facility personnel of the danger potential; a list of emergency contacts; evacuation procedures and primary/secondary gathering locations; and the procedures to be implemented in the event of a fire at the facility. Cabot Performance Materials is committed to continuously improving the overall safety and environmental performance record at the Boyertown facility. Specific policies aimed at improving safety will be continually improved. These policies include continuing development of best management practices; conducting site- and job-specific training; continuing coordination with the fire department, local HazMat team, and Local Emergency Planning Committee; and upholding the facility's goal for a safe workplace. In summary, Cabot Performance Materials is fully committed to the safe storage, use, and operation of the HF systems utilized at the facility. |