Etch Logic, LLC - Executive Summary

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Etch Logic, LLC, operates a chemical milling manufacturing process that produces shaped metal pieces through a photochemical etching process.  Typical products are lead frames, metal baseplates used for the mounting of semiconductor devices, custom accelerometers, and custom tactile/pressure sensing frames.  The operations occur on a reel to real operation where a base metal of either copper or steel alloy is processed through several stages that include; pre-lamination clean, lamination of photochemical materials, alignment and exposure, development of photochemical materials, etching, rinse, and other physical cutting or forming operations.  In the etching operations, a solution of cupric chloride and ferric chloride-hydrochloric acid is employed to etch away base material through etching tanks.  As the operation proceeds and material has been etched from the base, the effectiveness of the etching bath decreases.  In order to maintain the etching chemical, chlorine gas is injected in 
to to the etchant which directly reoxidizes the inactive element.  The chlorine gas triggers the requirements of 40 CFR Part 68 - Chemical Accident Prevention Provisions because Etch Logic system has greater than 2,500 pounds of chlorine within the system.  The Etch Logic facility has the ability to store chlorine in four (4) one ton (2,000 lbs) cylinders, which equates to 8,000 lbs (approximately) maximum inventory of chlorine. 
The goal of part 68, the risk management program, is to prevent accidental releases of substances that can cause serious harm to the public and the environment from short-term exposures and to mitigate the severity of releases that do occur. The 1990 Amendments to the Clean Air Act (CAA) require EPA to issue a rule specifying the type of actions to be taken by facilities (referred to in the statute as stationary sources) to prevent accidental releases of such hazardous chemicals into the atmosphere and reduce their potential impact on the public and the enviro 
nment.  Part 68 is that rule.  40 CFR 68 requires the development of a risk management program for the use and storage of chlorine gas, and any process and employees associated with or potentially affected by the use of chlorine.  This submission is the risk management plan (RMP) which provides a summary of the risk management program. 
The rule defines three Program levels based on processes' relative potential for public impacts and the level of effort needed to prevent accidents.  The Etch Logic facility falls under the Program 3 requirements.  Program 3 facilities have processes not eligible for Program 1 and either subject to OSHA's PSM standard under federal or state OSHA programs or classified in one of nine specified Standard Industrial Classification (SIC) codes are placed in Program 3, which imposes OSHA's PSM standard as the prevention program as well as additional hazard assessment, management, and emergency response requirements.  The OSHA Process Safety Management standar 
d (codified at 29 CFR 1910.119) is a set of procedures in thirteen management areas designed to protect worker health and safety in case of accidental releases.  Similar to EPA's rule, OSHA PSM applies to a range of facilities that have more than a threshold quantity of a listed substance in a process. 
Regardless of the program levels of a facility, all facilities subject to 40 CFR 68 must complete a five-year accident history for each process and submit a RMP that covers all processes.  All Program 3 processes must conduct and document at least one worst-case release analysis and one alternative release scenario to cover chlorine.  A Program 3 facility must coordinate emergency response activities with local responders and, if the facility uses it's own employees to respond to releases (Etch Logic does not), the facility must develop and implement an emergency response program.  For each Program 3 process, the facility must implement all of the elements of the Program 3 prevention pr 
ogram: process safety information, process hazard analysis, standard operating procedures, training, mechanical integrity, compliance audits, incident investigations, management of change, pre-startup reviews, contractors, employee participation, and hot work permits. 
Etch Logic has developed a thorough risk management program that as involved auditing the existing PSM program, developing and implementing detailed corrective action plans (when needed), developing RMP-specific information (i.e. off-site consequence analysis), and interacting with employees and local emergency personnel (LEPC, fire, police) to ensure proper planning and coordination in case of an accident.  The risk management program has incorporated all of the required elements (i.e. accident history, prevention program, off-site consequence analysis, and emergency response) and provides Etch Logic and the surrounding community with a comprehensive and workable accident prevention program.
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