Scott Semiconductor Gases - Executive Summary |
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(a) The accidental release prevention and emergency response policies at the facility Scott Semiconductor Gases (Scott) recognizes the responsibility to make our environment, community, and our employee safety a primary part of our daily concerns. Scott is committed to being a responsible member of the community in which it has operations, by giving top priority to operating in a safe and environmentally sound manner. Safety is our number one priority with an in-house emergency response team, a detailed preventive maintenance program, written standard operating procedures, and over five years without an accidental release. From the owner of the company, down through the newest employee, Scott Semiconductor Gases is committed to safety as a neighbor and concerned member of the community. (b) The stationary source and regulated substances handled: Scott Semiconductor Gases is a division of Scott Specialty Gases, Inc. We supply high-purity gases and equipment for semiconductor ma nufacturing and other electronic applications. One of our services is the transfer of hydrogen chloride gas (the only federally regulated substance at the facility) into a variety of cylinder sizes to meet customer needs. (c) The worst-case release scenario and the alternative release scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario: The worst-case release scenario is complete evacuation of a 60-pound cylinder of hydrogen chloride into the atmosphere over a period of 10 minutes. Hydrogen chloride is transfilled from 60-pound containers into smaller 20, 5, and 3-pound containers. The release is assumed to occur while the 60-pound cylinder is on the loading dock. The impact was calculated using the EPA RMPComp modeling program and resulted in an endpoint of 0.5 miles from the facility. The release rate to the atmosphere is the quantity contained in the cylinder divided by the duration of the release. The alter native release scenario is a failure of a valve on or a connection to a cylinder containing the greatest quantity of the compressed hydrogen chloride gas. The release is assumed to occur while the cylinder is inside the storage and processing building, where the doors would be closed in the event of a leak. It is estimated that the release could be stopped within 15 minutes of occurrence; however, it is likely that the entire quantity of compressed gas in the cylinder would be released before the release could be stopped. Therefore, the release rate to the atmosphere is the quantity contained in the cylinder divided by the duration of the release; adjusted to account for the mitigation provided by the enclosed building. The resulting endpoint using RMPComp was less than 0.1 mile. (d) The general accidental release prevention program and chemical-specific prevention steps: Rules and regulations with which Scott complies are the following: ? CGA Guidelines; ? Uniform Fire Code, 199 4 edition; ? American National Standards Institute (ANSI)/American Society of Mechanical Engineers (ASME) B31.3 "Code for Chemical Plant and Petroleum Refining Piping"; ? National Fire Protection Association (NFPA) 30 "Code for Flammable and Combustible Liquids"; ? NFPA 70 "National Electric Code"; ? NFPA 77 "Recommended Practice on Static Electricity"; ? Occupational Safety and Health Administration (OSHA) 29 CFR 1910.101 "Compressed Gases (General Requirements)"; ? CFR-29 Code of Federal Regulations, Department of Labor; and ? CFR-40 Code of Federal Regulations, Protection of the Environment. The hydrogen chloride process is subject to the federal Process Safety Management (PSM) standard, making the process also subject to Program 3 prevention program requirements. Scott has complied with each of the Program 3 requirements, providing the facility with a comprehensive and ongoing prevention program. Hydrogen chloride cylinders are fitted with relief devices that are designed and mai ntained according to CGA Guidelines. The facility is monitored in several key locations with toxic gas monitors. Laboratory personnel maintain the gas monitors and preventive maintenance of the gas monitors is conducted according to the manufacturer's recommendations. Included in the standard operating procedures is information on safe upper and lower limits for major process parameters, consequences of deviation from established safe limits, and safety systems. (e) The five-year accident history: Scott completed a 5-year accident history review that indicates there have been no accidental releases within the last 5 years that meet the RMP reporting requirements. (f) The emergency response program: The Scott Fremont facility has an Emergency Planning and Response Program (EPRP) that addresses emergencies involving hydrogen chloride. The EPRP will be activated if a release of hydrogen chloride triggers the sensors and alarms or if a release of hydrogen chloride has the potenti al to harm human health or the environment. The EPRP includes specific actions to be taken in response to an accidental release, procedures for informing the pubic and local agencies responding to an accidental release, and information on emergency health care. (g) Planned changes to improve safety: Scott is committed to providing a safe place of business for the employees and the surrounding community. The programs and procedures in place at Scott are designed to minimize the probability and/or consequences of accidental releases of highly hazardous chemicals from the facility and include such measures as a system hazard review, operating and maintenance procedures, training, compliance auditing, management system, and updates. To improve facility safety Scott has plans to install separation walls to better separate the compatible and incompatible gases. Also, a joint HAZMAT training exercise with the Fremont Fire department is scheduled at the facility. In addition, Scott ha s future plans to upgrade the process systems, upgrade their Emergency Planning and Response Program, install duct-working for ventilation, and install more monitors for HCl and mineral acids. |