Photofabrication Engineering Inc. - Executive Summary
PHOTOFABRICATION ENGINEERING INC. |
500 FORTUNE BOULEVARD
EXECUTIVE SUMMARY FOR RMP*SUBMIT
A. Who is Photofabrication Engineering Inc.?
Photofabrication Engineering Inc. (PEI) was founded in 1967 to provide the electronics and related industries with high precision chemically machined parts. Shortly after the company's establishment, we began branching into the decorative markets. Our products can be found in the electronics, medical, appliance, automotive, and aerospace industries. Our decorative products offer exquisite and intricate design and fabrication in the area of jewelry findings, holiday ornaments, commemoratives, museum pieces, and architectural model components.
We have been located at 500 Fortune Boulevard, Milford, MA since 1984. We employ 60 people from Milford and the surrounding communities. Since we commenced operations in Milford, we have been very active in supporting community activities such as the Salvation Army
, Make One Wish charity, Milford Legion Baseball, and the United Way.
B. What is the Risk Management Program?
In 1996, the US Environmental Protection Agency (EPA) promulgated regulations for the response, prevention, and detection of accidental releases of 77 toxic substances and 63 flammable substances. The regulation, called "Chemical Accident Prevention Provisions," is found at 40 CFR 68 and meets the requirements of the Clean Air Act Amendments of 1990's Section 112r. The purpose of these Risk Management Programs is to prevent accidental releases where possible, minimize the impacts of accidental releases on the general population and the environment, and to educate the public on the potential impacts of an accidental release.
A facility is subject to these regulations if it handles, stores, uses, or manufactures more than a threshold quantity of a regulated substance in a "process." An applicable facility must prepare a Risk Management Plan that includes a hazard asses
sment, accident prevention program, and emergency response program, and is required to submit the Risk Management Plan to EPA by June 21, 1999.
C. How is PEI Subject to RMP?
Chlorine gas is used in one of our processes. Chlorine is a toxic gas that is liquefied under pressure. Chlorine is included on EPA's list of chemicals subject to RMP and has a threshold of 2,500 pounds. We store a maximum of four (4) one-ton steel cylinders of chlorine gas inside our building, under lock and key. The total amount of chlorine stored for this process exceeds the RMP threshold. No other chemical at PEI exceeds the RMP thresholds of applicability. Following EPA's guidance, we determined that we are subject to Program 3 of the RMP regulations.
Ours metal etching process uses an etchant that can be regenerated and reused over and over, 50 or more times. One of the benefits of regenerating the etchant is that the amount of waste generated from the process is significantly reduced. It is th
is regeneration process that utilizes chlorine gas.
II. PEI'S RISK MANAGEMENT PLAN
PEI's Risk Management Plan, of which this Executive Summary is a part, complies with the specific requirements in EPA's RMP regulations (40 CFR 68) for Program 3 processes.
A. RMP*Submit Data Elements
The files submitted to EPA for the June 21, 1999 deadline include the data elements completed using EPA's RMP*Submit program and two graphics files (*.jpeg) portraying the radii of the zones of impact for the worst case release and the alternative release scenarios. Please refer to the RMP*Submit files for the complete submittal made to EPA.
B. Understanding PEI's Approach to Chemical Safety
We understand that our use of chlorine requires proper storage and handling precautions to prevent exposures of our co-workers, neighbors, and the environment in the day-to-day use of chlorine and in event of an accidental release. Furthermore, it is our goal to meet or exceed, where possible, all state
and Federal requirements regarding protection of the environment. As such, the management at PEI has implemented numerous measures to prevent, mitigate, and respond to accidental releases of chlorine at the facility.
Managing the risks and hazards associated with chorine begins with the employees. It is our policy that only trained and experienced chlorine handlers operate the chlorine cylinders and the associated equipment. All employees are encouraged to make recommendations to further ensure safe handling of chlorine.
The regeneration process, process equipment, and materials of construction comply with the guidelines in The Chlorine Institute's "Chlorine Manual," including:
7 heavy-walled steel cylinders
7 a fire suppression system in the event of a fire
7 an emergency repair kit (Emergency Kit "B")
7 seven safety relief valves
7 triple valving to allow isolation of leaks
7 regular inspections and maintenance of process equipment.
Another key aspect of our prevention p
rogram is compliance with the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) Program. PSM includes a Hazard Analysis that identifies problems that may lead to a release and/or exposure to chlorine and rectifies the problem. PSM also evaluates training, maintenance, management of change, and inspection activities related to proper use, storage, and handling of chlorine. The PSM program is updated regularly.
Our chlorine handling policies also include that the chlorine is turned off at the cylinder when not in use and only two one-ton cylinders are connected to the process at any time. The cylinders that are not connected to the process (i.e., in storage) are very unlikely to be involved in an accidental release when considering the strong steel structure of the cylinders and the preventative measures put in place.
As further evidence of our rigorous chlorine management programs, we have not experienced an accidental release of chlorine to da
te. Nevertheless, we will continue to improve our chlorine, use, storage, and handling efforts in the future.
C. Emergency Response Program - Just in Case
In spite of the fact that we have never had a chlorine release, PEI has prepared a "Hazardous Materials and Hazardous Waste Contingency Plan" to ensure rapid response in the event of an accidental release. The Contingency Plan has been submitted to local response teams who will be able to act swiftly to provide emergency services if called upon to do so. The Contingency Plan has been distributed to the Milford Fire Department, Milford Police Department, Milford Board of Health, Milford/Whitinsville Hospital, and Clean Harbors. In the event of an emergency that may potentially impact the community, the Milford Police Department will notify residents and businesses.
III. HAZARD ASSESSMENT
The hazard assessment includes configuring the appropriate release scenario and predicting the maximum distance to the edge of the impact a
rea (called the "zone of impact"). We used guidance from EPA to define the release scenarios for the alternative release and the worst-case release. We used a computer-based atmospheric dispersion model for denser-than-air releases called "SLAB" to predict the zone of impact for the two scenarios.
The concentration of chlorine that defines the zone of impact is based on the American Industrial Hygiene Association's (AIHA) Emergency Response Planning Guidelines. The endpoint represents a safe level of exposure "below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects." The endpoint for chlorine is 3 parts per million in ambient air.
A. Alternative Release Scenario
The alternative release scenario is the more "probable" release for the facility. For the alternative release scenario, U.S. EPA allows the facility to define the conditions of the release using reasonabl
e judgement, process knowledge, and practical assumptions. As opposed to the worst-case release scenario, the alternative release scenario becomes the more "realistic" accident scenario. PEI used the following parameters to determine the zone of impact for the alternative release scenario:
7 The scenario is that a 3/8 inch (outside diameter) copper pipe between the cylinder regulator and the manifold is fractured
7 The release rate is 5.4 pounds of chlorine per minute for 60 minutes
7 The meteorological conditions are representative of average atmospheric stability ("D" Stability) and 3.0 meters per second wind speed
7 The release takes place inside the building (qualifies for 45% reduction in release rate) with a partial open floor to a confined basement below
7 Active mitigation measures (fire suppression system, structure of the heavy-walled steel cylinder, triple valving, etc.) prohibit certain other release scenarios from occurring.
The results of the alternative release scena
rio for PEI was a distance of 0.18 miles. Using EPA-approved methodologies, we determined that there are no schools, hospitals, correction facilities, recreation areas, residences, or sensitive environmental receptors within the zone of impact. However, there are commercial and industrial areas within the zone of impact for PEI's alternative release scenario. Although we estimated that the population within the zone of impact to be 104 using EPA-approved methodologies, there are no residences in the area and we assume that the population is closer to zero.
Please refer to the attached graphic file called "peialter.jpeg" for an illustration of the zone of impact superimposed onto a street map of the region.
B. Worst-case Release Scenario
The worst-case release scenario is prescribed by the U.S. EPA. Every facility subject to RMP must evaluate the worst-case release using the same parameters. For toxic gases, the release must incorporate the following parameters:
7 The releas
e of the largest quantity of a regulated substance from a vessel or process line failure over 10 minutes
7 Meteorological conditions are representative of worst-case atmospheric stability ("F" stability) and 1.5 meter/second wind speed
7 Release at the ground level, regardless of the actual location of the vessel or process
7 Only "passive" mitigating measures (such as building enclosures) may be incorporated to the modeling (qualifies for 45% reduction in release rate)
Though its name suggests that the impact would be the highest from a given facility, the worst-case release scenario is essentially a highly improbable and unrealistic release scenario.
The results of the worst-case release scenario for PEI was a distance of 0.73 miles. Using EPA-approved methodologies, we determined that there are no schools, hospitals, correction facilities, or sensitive environmental receptors within the zone of impact. However, there are commercial and industrial areas, recreation areas, resid
ences, and one daycare facility within the zone of impact for PEI's "worst-case release scenario." We also estimated that the population within the zone of impact is 1,836.
Please refer to the attached graphic file called "peiworst.jpeg" for an illustration of the zone of impact superimposed onto a street map of the region.
At PEI, we understand that our use of chlorine requires proper storage and handling precautions to prevent exposures of our co-workers, neighbors, and the environment in the day-to-day use of chlorine and in event of an accidental release. It is also our goal to meet or exceed, where possible, all state and Federal requirements regarding protection of the environment.
Following EPA guidance, our worst-case impact extends to 0.73 miles from the facility. Please note that EPA's prescribed worst-case release scenario is generally considered to be an extremely unlikely release scenario for most facilities. Our more realistic alternative rel
ease scenario extends to a distance of 0.18 miles. We believe that there are no residences within this zone of impact and, therefore, should have a minimal impact.
In the event of an accidental release, we have provided sufficient documentation to the local emergency response teams to act swiftly and accurately. Though we have never had a single chlorine release, we will continue to find ways to further reduce the threat of release to the environment.