Tru Vue Inc. - Executive Summary |
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TRU VUE RMP Plan Executive Summary Introduction The Tru Vue Company is committed to operating in a manner that is safe for the Tru Vue employees, the public and the environment. As part of this commitment, Tru Vue has established a system to help ensure safe operation of the hydrofluoric glass etching process at this facility. One component of this program is called the risk management program (RMP) that helps manage the risks at Tru Vue and that complies with the requirements of the Environmental Protection Agency's (EPA'S) regulation 40 CFR part 68, Accidental Release Prevention Requirements: Risk Management Programs (The RMP Rule). One of the requirements of the RMP rule is to submit a risk management plan (RMPlan) describing the risk management program at Tru Vue. The plan is intended to satisfy the RMPlan requirements of the RMP Rule (68.150 through 68.185) and to provide the public with a description of the risk management program at Tru Vue. Accidental Release Prevention and Emergency Policies Tru Vue is committed to the safety of the Tru Vue workers and the public and to the preservation of the environment, through the prevention of accidental releases of hazardous substances. Tru Vue implements reasonable controls to prevent foreseeable releases of hazardous substances. In the event of an accidental release, Tru Vue controls and contains the release in a manner that will be safe for the workers and will prevent injury to the public or the environment. Tru Vue Facility and Regulated Substances The Tru Vue Company processes glass and uses aqueous hydrofluoric acid in its glass etching process. HF acid at the solution concentration of 50wt% or greater are regulated by the RMP Rule, and although only dilute (about 30%wt%) HF acid solutions are used in the etching tank, HF acid at a solution concentration of 70wt% is stored in one large tank at the Tru Vue facility for use in the process. A maximum of 5,000 gallons of 70% HF acid is stored in one 5,000 gallon tank located at the Tue Vue site. The weight of the HF acid in 5,000 gallons of 70% solution is 51,000 lbs. which exceeds the RMP threshold quantity for HF acid in a process (1,000 lb.). Because the HF acid storage process is not covered by the Occupational Safety and Health Administration, process safety management regulation and because the potential exists for the offsite consequences resulting from accidental release of HF the process falls under the RMP program 2 prevention program. Offsite Consequence Analysis The RMP Rule requires Tru Vue to perform an offsite consequence analysis for one worst-case and one alternative release scenario for the aqueous HF acid, a toxic substance. The worst-case release scenario is a failure of the storage tank releasing 51,000 lbs. of the aqueous HF acid at 70% concentration. A diked area contains the released aqueous HF acid, which evaporates, forming a vapor cloud. The Maximum distance the toxic end point concentration is 0.19 of a mile. No residential housing is located within the evacuation zone. A large industrial facility is located north of the zone with only the employee parking lot being subjected to any hazard. The alternative release scenario for aqueous hydrofluoric acid is a rupture of the 1 1/2 inch process line. The scenario assumes that the solution is released through the hole for 20 minutes before workers detect the release and isolate the line. The released acid forms a pool, with the HF evaporating from the pool and forming a vapor cloud. The maximum distance to the toxic endpoint is 0.19 mile No houses are located within this zone although several industrial complexes' are. Accidental Release Prevention Program and Chemical - Specific Prevention Steps Safety Information Tru Vue maintains a Variety of technical documents that are used to help ensure safe operation of the glass etching process. Material Safety Data Sheets document the physical properties of the hazardous substances h andled at Tru Vue, including HF Acid. The engineering design documents include the operating parameters, the design basis and configuration of the equipment in each of the covered processes, and refers to applicable codes and standards. Hazard Review Tru Vue has just recently performed a hazard review of the etching process. Several changes to ensure the safe operation of the process are being worked on and will be implemented as soon as possible. An update of the Hazard Review will be conducted in July of 2000. Operating Procedures Tru Vue develops and maintains operating procedures to define how tasks related to process operations should be performed. The operating procedures are used to (1) train employees and contractors and (2) serve as a reference guides for the appropriate actions to be take during normal operations and process upsets. Training Tru Vue trains personnel in the operating procedures to help ensure safe and effective performance of their assigned tasks. A trai ning documentation file is maintained to help ensure that refresher training is provided, as necessary. Maintenance Tru Vue properly maintains the process equipment. The Tru Vue maintenance program includes (1) procedures to safely guides workers in their maintenance tasks, (2) worker training in the maintenance procedures, and (3) an inspection and testing program to help identify equipment deterioration and damage before the equipment fails. Compliance Audits Tru Vue performs periodic compliance audits of the covered process to verify that the process is operating in compliance with the requirements of the RMP rule. A compliance audit report is prepared after each audit, and any deficiencies noted by the audit are corrected in a timely manner. Incident Investigations Tru Vue investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public, or the environment. Tru Vue encourages employees to identify and report any incident requiring investigation. An investigation team will be assembled, and the investigation will be initiated within 48 hours of the incident. The results of the investigation will be documented, recommendations will be resolved and appropriate process enhancements will be implemented. HF Acid-Specific Prevention Steps Industry standards are followed at Tru Vue to help ensure safe handling of the aqueous HF Acid. The vendor supplies HF via a Department Of Transportation (DOT) approved tank truck and follows DOT standards when offloading the aqueous HF acid. The storage tank design and construction are consistent with American National Standards Institute standards. Workers who perform operations involving HF acid receive training emphasizing safe handling procedures for HF acid developed by Tru Vue. Five Year Accident History Tru Vue maintains a 5 year accident history that fulfills the requirements of the RMP rule (68.42). No releases of regulated substances have occurred from the Tru Vue facility in the last five years that have resulted in consequences of interest (i.e., deaths, injuries, or significant property damage on site; or known deaths, injuries, evacuations, sheltering in place, property damage or environmental damage off site). Emergency Response Programs Tru Vue has established a written emergency response plan that complies with the RMP rule and with other federal contingency plan regulations. The plan has been communicated to the local emergency response officials. Regular dialogue is maintained between Tru Vue and the local fire chief, and Tru Vue provides appropriate information to the fire chief. Tru Vue has established a policy that will periodically conduct fire and evacuation drills, including annual drills coordinated with the local fire department. Planned Changes To Improve Safety Tru Vue constantly strives to improve the safety of the hydrofluoric etching line through the incident investigation program and a program soliciting safety sug gestions from the workers. The following changes to improve the process are planned or have recently been completed. A off loading containment area will be built for the tank truck offloading on the east side of the building. This safety feature will prevent any (should any occur) spillage of acid from leaving the company property. |