Compeq International - Executive Summary |
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The Executive Summary for the Risk Management Plan is required under Section 112(r) of the Clean Air Act and 40 CFR 68.155. 1. The accidental release prevention and emergency response policies at the plant. Compeq International has an Environmental Policy Statement, as shown here: Environmental Policy Statement Compeq International Corporation 620 North John Glenn Road Salt Lake City, Utah 84116 As leaders in the printed circuit board industry, Compeq International Corporation recognizes and believes that all operations and activities of the company should be conducted responsibly and in a manner designed to protect the health and safety of its employees, customers, the public, and the environment. Compeq International Corporation?s goal is not only to comply with existing environmental, safety, and health laws and regulations, but also to support additional activities that contribute to environmental protection, responsible resource management, and the safety and health of emplo yees, customers, and members of the community. Specifically, Compeq International will: 1. Ensure that all activities fully comply with all federal, state, and local environmental, health, and safety regulations. 2. Include environmental, safety, and health considerations in its business practices. 3. Provide a safe and healthy work environment for all employees. 4. Build and operate our facility in ways that protect human health and the environment. 5. Mitigate and, if necessary, remediate any accidental impact Compeq International?s operations may have on the environment. Ted Witte is the Administration Manager and has jurisdiction over all environmental and safety issues. COMPEQ International has a full-time environmental engineer and a full-time safety supervisor and a full-time wastewater treatment supervisor on staff. Their names are: Donald E. Robinson, P.E. Environmental Engineer Jayson Evans Safety Supervisor Chris Allred Wastewater Treatment Supervisor All can be reached at 801-990-2000. COMPEQ International does not have a formal system to track existing and new regulations, which may apply to the company. However, the state regulatory agencies are all in Salt Lake City and can be reached very quickly. COMPEQ International receives several publications on environmental and safety regulations. The plant has a complete set of 40 CFR on site. The Environmental Engineer prepares a Comprehensive Site Compliance Evaluation on an annual basis in December of each year. This is required by the storm water permit, which was issued by the Utah Division of Water Quality. It addresses the compliance status of the plant and discusses any releases, which occurred to air, water, or land. It also addresses the general condition of the plant. In addition, the Environmental Engineer prepares an air emissions inventory on April 15 of each year and a toxic release inventory on July 1 of each year. The following safety procedures for the HCl storage tank are implemented at Compeq International: Secondary containment around the tank; surface area is 324 square feet Containment wall is high enough to hold entire contents of tank (8000 gallons) Tank is new and will be installed in July 2000 Overfill alarm system Tank within a tank; outer tank is fiberglass; inner tank is HDPE 2. Your facility and the regulated substances handled. COMPEQ International manufactures printed circuit boards. The actual manufacturing process includes many steps, including the ones listed below: Material Control & Purchasing Cut to Size Design Process In Process Quality Control (IPQC) Function - All Areas Inner Layer Dry Film Dry Process Drill Outer Layer Dry Film Wet Process Plating, PTH, Pattern Etch & Strip Inner Layer & Outer Layer Quality Inspection Solder Mask Final (Electrical) Inspection Shipping Waste Water Treatment Surface Finish Immersion Gold Plating Goldfinger Hot Air Level [HAL] ENTEK Quality Assurance Customer Service & Sales The only RMP regulated substance currently in use at Compeq International is hydrochloric acid, 37% concentration, CAS #7647-01-0. The Threshold quantity is 15,000 lb (only the HCl counts). There is one storage tank with a volume of 8000 gallons. This is more than 29,129 LB of HCl. 3. The worst-case release scenarios. Compeq International used RMP Comp Version 1.06 to determine the toxic endpoint for the storage tank. The worst case release scenario for HCl shows off-site impact. The distance to the toxic end point is 0.50 miles. Public receptors are impacted. The following parameters were put into the model, and the model yielded the following results: Chemical: hydrochloric acid 37%. CAS 7647-01-0 Category: Toxic liquid Scenario: Worst case Quantity released: 29,129 LB Liquid temperature: 77 F Mitigation measures: Diked area: 324 SF Dike height: 3 feet Release rate to outside air: 3.86 LB/minute Topography: Rural surroundings (terrain generally flat and unobstructed) Toxic endpoint: 0.030 mg/liter; basis ERPG-2 Estimated distance to toxic endpoint: 0.5 miles Assumptions about this scenario: Wind speed: 1.5 meters/second Stability class: F Air temperature: 77 F 4. The general accidental release prevention program and chemical-specific prevention steps. Compeq International complies with the following environmental rules: A. Process Safety Management (PSM) Rules; 29 CFR 1910.119 Compeq International is subject to PSM. The PSM binder includes the following information: 1. Emergency Preparedness Contingency Plan (EPCP). This plan has been developed to assist the Emergency Coordinator (EC) in determining appropriate response procedures. It is dated March 1997. It is currently being updated by the EC. The plan addresses response procedures for fire, explosion, and accidental releases to air and ground. It also includes a list of equipment stored in the HAZMAT room, and a list of chemicals used at Compeq International. 2. Process Flow Charts 3 . Escape routes from the building 4. Fire extinguisher locations 5. Confined Space Pre-entry Hazard Analysis 6. Hazardous Materials Management Plan. This document describes the management of hazardous materials at Compeq International. It is submitted to the Salt Lake City Fire Department. It addresses the following: Combustible Dust Explosion Vents Hazardous Materials Inventory Statement General Site Plan Building Floor Plan Hazardous Materials Handling Chemical Compatibility and Separation Monitoring Program Security Pr3ecautins Hazard Labeling & Warning Signs Inspections & Record Keeping Employee Training Emergency Equipment Appendix I, General Site Plan Appendix II, Building Floor Plan Appendix III, Exempt Amounts of Hazardous Materials Appendix IV, Retention Calculations 7. Standard for Lead. This document defines the procedures that are required when working in areas that have a lead hazard. This policy covers employees that are or have the potential to be exposed to le ad by working in or traveling through these designated areas. See 29 CFR 1910.1025 and 1910.134. B. Clean Air Act of 1990 Compeq International is subject to this act indirectly. Air quality issues at Compeq International are handled under the Utah Air Conservation Act and the air permit. C. Utah Air Conservation Act Compeq INTERNATIONAL has an air permit issued by the Utah Division of Air Quality. It is dated May 5j, 1999 and addresses criterial pollutants as well as hazardous air pollutants as defined by the Clean Air Act. The permit requires Compeq International to properly maintain all equipment and to maintain records of maintenance. The permit lists all the pollution control equipment at the plant as well as all process equipment. The HCl storage tank is not specifically listed in the permit, but proper maintenance of it is required under the permit. D. RCRA Rules Compeq International complies with all applicable RCRA rules regarding 90-day storage of hazardous waste a nd satellite accumulation of hazardous waste. Compeq International is a large quantity generator of hazardous waste. E. Clean Water Act Compeq INTERNATIONAL has a storm water permit, which was issued by the Utah Division of Water Quality. Under this permit, Compeq INTERNATIONAL must minimize contamination to storm water and perform sampling every quarter. 5. The five-year accident history. Compeq International has no accidental releases of air pollutants in the last vi e years. 6. The emergency response program. Describe elements of the program such as coordination with local emergency responders, training received by personnel, drills conducted, public alert systems, etc. A. Coordination with local emergency responders Compeq International has coordinated with specific agencies for emergency response. In the event of an imminent or actual incident that could threaten the environment or human health, the following agencies will (by prior arrangement) respond to emergency ca lls or investigation of incidents at Compeq International: Police Salt Lake City Police Department 315 East 200 South Salt Lake City, UT 84111 801-799-3000 or 911 in emergencies Fire Salt Lake City Fire Department Station 11 581 North 2360 West Salt Lake City, UT 84122 801-596-5251 Or 911 in emergencies Chemical Spill Hazardous Materials Coordinator Salt Lake City Fire Department 315 East 200 South, 7th Floor Salt Lake City, UT 84111 801-799-4153 Or 911 in emergencies Hospital Pioneer Valley Hospital 3460 South Pioneer Parkway West Valley City, UT 84120 801-964-3100 Or 911 in emergencies OSHA Utah OSHA 160 East 300 South, 3rd Floor PO Box 146650 Salt Lake City, UT 84114 801-530-6901 State Emergency Response SERC, Emergency Response Section Utah DEQ 168 North 1950 West Salt Lake City, UT 84116 801-536-4123 Medical Transport Gold Cross 1717 South Redwood Road Salt Lake City, UT 84119 801-972-1211 Or 911 in emergencies Hazardous Material Information Chemtrec 800-424- 9300 National Response National Response Center 800-424-8802 B. Training received by personnel Compeq INTERNATIONAL (as of June 5, 2000) has given the following training: Training No. of Employees Maintenance technician 18 Wastewater treatment foreman 2 Environmental technician 12 Lab technician 12 24 Hour Hazmat 24 40 Hour Hazwoper 7 SCBA 7 Safety 16 C. Drills conducted Compeq International has scheduled the following drills for its employees who will respond to emergencies: 1) Emergency evacuation drills are held twice a year. The last one was held on 5-15-00. 2) Emergency response drills are conducted to train employees to handle spills of hazardous materials or hazardous waste. Drills will consist of training and scenarios that could occur at Compeq International. These drills are held on the first Friday of every quarter. The next one will be held on October 6, 2000. The following groups will participate in the drills (about 40 people total): Environmental Engineer S afety Supervisor Security guards Wastewater Treatment Supervisor Wastewater Treatment staff Maintenance Supervisor Maintenance staff D. Public alert systems Compeq INTERNATIONAL has the following alarm systems in place: 1) Evacuation alarms for plant-wide emergencies. It includes 44 manual pull stations, 60 smoke detectors, 11 hatch switches. All are monitored by the Alarm Control panel. 2) Pit alarms. These alarms activate in case of chemical overflow in the pits below the machinery. There are three of them, one in A10 pit, B10 pit, and the basement. They are monitored by the security person on duty. 3) Door alarms. All exit doors are alarmed. They are monitored by the security person on duty. 4) Overhead paging system. It can be accessed form any phone in the plant. 7. Planned changes to improve safety. A. Planned Future Safety Training Compeq International intends to have all WWT employees, supervisors, and security employees trained in safety procedures. This is a n ongoing process due to employee turnover and internal transfers. B. Planned Future Environmental Training Compeq International intends to keep the environmental staff up to date on environmental regulations through attendance at seminars and purchase of appropriate handbooks and new editions of regulations. |