SEH America, Inc. - Executive Summary |
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Per the requirements of Section 112(r) of the Clean Air Act Amendments of 1990 as codified in Title 40 of the Code of Federal Regulations (CFR) Part 68, this Risk Management Plan (RMP) is submitted to the United States Environmental Protection Agency (U.S. EPA) in a timely manner for the SEH America Vancouver, Washington facility, which handles one or more regulated substances listed in Appendix A of Part 68. 1.1 STATIONARY SOURCE & REGULATED SUBSTANCES HANDLED SEH America owns and operates a silicon wafer manufacturing facility located in Vancouver, Washington. The regulated substances handled by this facility are Hydrogen Chloride and Hydrogen, which are considered hazardous by the United States Environmental Protection Agency (U.S. EPA). SEH America manufactures high quality silicon wafers used in the manufacture of integrated circuits. This facility manufactures a number of different types and sizes of wafers. Hydrogen Chloride is used in the manufacturing of epitaxial wafer s. The epitaxial process produces a thin layer of silicon on top of already polished wafers. Hydrogen chloride is a gas that is used in the deposition of this silicon layer. The maximum quantity of Hydrogen Chloride that can be stored or handled at this facility is 46,120 pounds. (2 tube trailers of 21,560 pounds each plus 5 smaller cylinders of 600 pounds each) Hydrogen is used in several processes in the facility. It is frequently used as a carrier gas for other chemicals. Hydrogen is stored as a liquefied gas at cryogenic temperature (-423o F). The maximum quantity of Hydrogen that can presently be stored or handled at this facility is 11,812 pounds. 1.2 ACCIDENTAL RELEASE PREVENTION & EMERGENCY RESPONSE POLICIES SEH America has a proactive approach to prevent accidental releases and uses OSHA's Process Safety Management rule as a guideline. SEH America greatly values all of our employees and we are honored to be members of our community. We engineer the highest standards of safety and environmental management into our systems. SEH America will respond with its Emergency Response Team to all emergency situations including leaks or suspected leaks. To be prepared for the unlikely event that a release does occur, SEH maintains a highly trained and always ready Emergency Response Team that works closely with the Vancouver Fire Department. 1.3 WORST-CASE & ALTERNATIVE RELEASE SCENARIOS SEH America has developed worst-case and alternative release scenarios for each regulated chemical. Hydrogen Chloride - Worst Case Scenario The worst case scenario for hydrogen chloride involves the release of the contents of one pressurized storage cylinder with a capacity of 3080 pounds. The contents of the cylinder leak out into the storage building over a ten minute period. Although scrubbers and other active mitigation systems are installed in the gas storage area, they are not allowed to be considered in the worst-case analysis. Since the release takes place i nside of an enclosed building, passive mitigation is allowed. Hydrogen - Worst Case Scenario The worst case scenario for hydrogen involves the release of the entire contents of the liquid hydrogen storage tank, which has a capacity of 11,812 pounds. The hydrogen is dispersed and ignited, resulting in a vapor cloud explosion. Hydrogen Chloride - Alternative Release Scenario The alternative release scenario for hydrogen chloride involves a vehicle striking process piping outside of the storage building and breaking the pipes. The flow is assumed to be just less than the maximum allowed by the excess flow valve installed to prevent large releases. This release involves 37 pounds of hydrogen chloride over 3.1 minutes. Hydrogen - Alternative Release Scenario The alternative release scenario for hydrogen involves the failure of a pipe in the vicinity of the storage tank, presumably by vehicle or object impact. Hydrogen gas is then vented from the pipe and is ignited by some ignitio n source, resulting in a jet fire. 1.4 GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM & CHEMICAL-SPECIFIC PREVENTION STEPS SEH America complies with EPA's Accidental Release Prevention Rule and applicable state codes and regulations. The facility follows guidelines and recommended practices of the Compressed Gas Association for the safe handling and use of compressed gases such as hydrogen and hydrogen chloride. . Numerous safety systems are used to prevent, detect, and mitigate releases of hazardous materials. These include regular piping inspections, process area chemical detectors, process alarms and shutdowns, mitigation systems such as scrubbers and water sprays, and systems that fail in the "safe" position. 1.5 FIVE YEAR ACCIDENT HISTORY SEH America has never had a release of a regulated substance that has resulted in any deaths, injuries, off-site impacts or significant property damage on-site. 1.6 EMERGENCY RESPONSE PROGRAM SEH America has developed an emergency response program to prevent and respond to accidental chemical releases of hazardous materials. The facility coordinates its response plan with members of the local Fire Department and the Local Emergency Planning Committee (LEPC) of which SEH America is an active member. SEH has developed and trained an emergency response team that is highly qualified to respond to releases of hazardous materials, and is available on-site 24 hours a day. The team regularly trains with outside responders and performs regular drills with the local Fire Department. 1.7 PLANNED CHANGES TO IMPROVE SAFETY The following safety improvements have been planned for 1999: * Process Hazard Analysis for covered systems will be updated as required by OSHA PSM. * A comprehensive OSHA PSM audit will be conducted by an outside agency in June of 1999. * A review and appropriation of advanced HAZMAT response equipment is being performed. * Plant familiarization tours for Vancouver Fire Department personnel are being conduct ed to update them on recent additions. * A response drill on RMP scenarios is being coordinated with the Vancouver Fire Department. SEH America is committed to placing safety and the environment first. Our Safety & Environmental Policy stresses continuous improvement. |