Ultra Pure One (UP-1) Plant - Executive Summary |
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KOCH MICROELECTRONIC SERVICE COMPANY, INC. A DIVISION OF SPECIALTY CHEMICALS Ultra-Pure One Plant Bryan, Texas EXECUTIVE SUMMARY FOR THE RISK MANAGEMENT PLAN (RMPlan) Introduction and Policies Under the Koch Environmental Excellence Program (KEEP) at Koch Industries, Inc., we are committed to being associated with unmatched environmental performance as measured by our employees, customers, regulators, and the public. Our KEEP management philosophy goals are achieved by the personal commitments of our employees and contractors, and by open communication with our employees, customers, neighbors, and regulators. The accidental release prevention and emergency response programs we have at our facilities are part of the high standards we strive for through KEEP. Our high standards are achieved by operating in compliance with all required environmental permits and regulations, by operating and maintaining our assets in such a manner that any unpermitted release will be unintentional and acknowledged as unacceptable, by remedying any shortcomings found during regular audits of our facilities, and by reporting promptly to regulators any shortcomings found during the course of our audits as required by law. The Ultra-Pure One (UP-1) Plant is operated by Koch Microelectronic Service Company, Inc. (Koch). At the facility, we receive anhydrous hydrogen fluoride (HF), anhydrous ammonia, hydrochloric acid, and isopropyl alcohol via rail and truck. These raw products are then purified through a number of processes and shipped out to customers via rail cars or trucks. The facility supplies customers with purified hydrofluoric acid (49% to 70% concentration), hydrochloric acid (up to 38% concentration) isopropyl alcohol, and ammonium hydroxide (29% concentration). Ammonia, hydrochloric acid, and HF are the only toxic substances regulated under the Risk Management Program (RMP) present at the UP-1 Plant in amounts greater than threshold quantity. There are no flammable RMP substances present at the facility. The facility is classified as Program Level 3 under the regulation. The purpose of this Risk Management Plan (RMPlan) is to provide information about our operations at the facility, our programs to prevent accidental chemical releases, our emergency response plans in case an accidental release should occur, our 5 year accident history, and our planned changes to improve safety at the facility. Worst Case and Alternative Release Scenarios As specified by the U. S. Environmental Protection Agency (EPA) RMP Regulations, our worst case release scenario for toxic chemicals would be the loss of all of the HF in our largest vessel within 10 minutes. In the case of the UP-1 Plant, this would involve our 12,050 gallon pressurized tank. Such a scenario is highly unlikely, however, using the EPA Offsite Consequence Analysis (OCA) methods, the distance that vapors could travel, in this hypothetical case, would be 25 miles from our facility. Although we have active mitigation measures in place to prevent such releases (high level/pressure alarms, emergency shutdown, interlocks, deluge systems, and others) and to manage their consequences, the only control taken into account when modeling this scenario was that the release would occur inside a building. As required by EPA, an alternative release scenario which is more likely to occur than the worst case scenario must be reported for each toxic chemical. The alternative release scenarios that could involve offsite exposure to a toxic chemical, are calculated to reach 1.0, 0.6, and 0.3 miles from the release point for ammonia, hydrochloric acid, and HF, respectively. These distances are also based on the EPA OCA methods, which are known to overpredict the impact of any potential release from such a scenario. The ammonia alternative release scenario is based on a release of ammonia during truck unloading due to an overfill of the ammonia storage vessel. If such an incident occ urred and our active mitigation failed, two relief valves on top of the storage vessel would be activated during the filling process. These valves ensure that the entire vessel does not rupture and only a minor controllable release results. Excluding any active mitigation measures in the calculations, the 2-inch diameter valves could release the ammonia at a rate of approximately 0.7 tons per minute. We have several mitigation measures in place to greatly reduce the chance that such an event could ever occur: 7 The unloading operation is at a pressure (200 psig) that is lower than the established pressure of the relief valves (250 psig). In other words, the compressor which fills the tank is incapable of delivering a pressure of 250 psig. 7 The level of liquid ammonia is measured during the filling process and the compressor will automatically shut off should the level reach a high level setpoint. 7 The unloading operation is monitored by Koch personnel continuously so that any problems would be detected prior to an overfill of the vessel. 7 Fire monitors are available to knock down any vapor that may be released. 7 If a release of ammonia occurred and the fire water system was implemented, there is secondary containment that would ensure that the resulting wastewater is disposed of properly. The hydrochloric acid alternative release scenario is based on a release of hydrochloric acid through the relief valve on the storage tank due to an overfill of the tank. If such an incident occurred and our active mitigation failed, the relief valve on the tank would be activated during the filling process. This valve ensures that the entire tank does not rupture and only a minor controllable release results. Excluding any active mitigation measures in the calculations, the 2-inch diameter valve could release hydrochloric acid at a rate of approximately 1.5 tons per minute. We have several mitigation measures in place to greatly reduce the chance that such an even t could ever occur: 7 There are high level alarms on the weigh cell to alert personnel that the tank is being overfilled. 7 If the level were to continue increasing, there is an independent high level switch on the tank which is interlocked to an emergency shutdown. 7 There are high and low pressure alarms on the tank to further reduce the possibility of an overfill. 7 If a release of hydrochloric acid occurred, a manually activated deluge system would ensure vaporization of the product would be kept to a minimum or avoided completely. The HF alternative release scenario is based on a 0.5 square inch hole in piping inside the HF Barn. If such an incident occurred, HF could be released from the building at a rate of 12.5 pounds per minute. In calculating this distance, we took credit for the release occurring inside a building, however, we took no credit for any of our other mitigation measures. We have several active mitigation measures in place to greatly reduce the chance th at such an event could ever occur: 7 The HF Barn vents to a scrubber system (2 scrubbers in series) which removes vapors at a 99.9% efficiency rate. 7 The HF Barn is equipped with a vapor detection system. If vapor is detected, a high concentration alarm is activated. 7 If a higher concentration is detected by the vapor detection system, an emergency shutdown occurs and a deluge system is activated to absorb vapors in the building. The presence of these active mitigation measures serves to both prevent these scenarios from occurring and minimize their impact if they do occur. We have discussed these potential ammonia, hydrochloric acid, and HF releases with our employees and with local emergency response officials in the City of Bryan and Brazos County, and prepared response plans to further reduce the possibility of any impact on the public. Prevention Program The UP-1 Plant operates under the strict guidelines of the Occupational Safety and Health Administration (OSHA ) Process Safety Management (PSM) Program. At the facility, we emphasize continual analysis of the potential hazards of our process, training of our employees, and on-going safety awareness. Part of the PSM program also involves identifying and taking steps to avoid potential accidental chemical releases. A few examples of the additional prevention features implemented at this facility include: 7 All processes have a combination of interlocks and emergency shutdowns to ensure cessation of product movement within the plant if a problem were to arise. 7 All process areas have deluge systems which are automatically activated by chemical detection or, conversely, can be manually activated if necessary. 7 HF is unloaded inside a building which vents to a scrubber and has a deluge system with secondary containment. 7 The HF acid and ammonia unloading and/or loading operations are covered by a canopy and are equipped with a deluge system and secondary containment. 7 Fire water monitors c over 100% of the process area to ensure that fires are extinguished or vapor clouds can be knocked down. 7 Scrubber systems have been installed in the HF, ammonia and hydrochloric acid processes to ensure at least 99% removal of any emissions. These safeguards as well as the vigilance of our trained employees have helped us operate safely at this facility since its inception. Five Year Accident History No incident resulting in onsite or offsite impacts from the release of an RMP substance has occurred at the UP-1 Plant within the last five years. The plant construction was initiated in 1998 and operations began in 1999. Although we take pride in our record so far, we also place daily emphasis on our prevention and safety programs to ensure this record continues. Emergency Response Program We will continue to conduct emergency response preparedness activities and coordinate any emergency response actions necessary for the UP-1 Plant with the City of Bryan Fire Depar tment, the College Station Fire Department, the Bryan Police Department, and the Brazos County Sheriff. Also involved in emergency response for the facility would be the Texas Highway Patrol and St. Joseph Regional Health Center, if necessary. The UP-1 Plant Manager is responsible for coordinating all emergency actions. A specific Emergency Response Plan for the facility is in place, and that plan has been coordinated with local officials, along with evacuation procedures, regular drilling, and training. Our Emergency Response Program provides the essential planning and training for effectively protecting workers, the public, and the environment during emergency situations. Planned Changes to Improve Safety Diligent compliance with our RMP Prevention Program forms the framework on which we will continue to improve the level of safety at the UP-1 Plant. Some of the key components of the safety improvements we expect to achieve are as follows: 7 The Management of Change p rovisions ensure that we consider the potential safety and health impacts of any change we make to process chemicals, technology, equipment or procedures. 7 The Process Hazard Analysis (PHA) provisions serve as a tool to ensure continual evaluation of potential hazards, thereby leading to continual improvements in our safety standards. 7 The Mechanical Integrity provisions ensure that process equipment and instrumentation are designed, constructed, installed and maintained to minimize the risk of hazardous releases, thereby serving as an integral part of our safety program. 7 Internal and third party compliance audits will ensure we maintain and increase our level of safety protection. 7 An ongoing dialogue with the City of Bryan and Brazos County Emergency Management Directors will ensure a constant state of readiness to respond to any potential emergencies, as well as a means to implement improvements as the need develops. In this way, we shall bolster our strong commitment to the s afety of our workers and the community. We encourage all interested citizens or community organizations to contact the City of Bryan and Brazos County Emergency Management Director for the latest information on emergency response for the county. We plan to diligently integrate our response capabilities and personnel with those of the county on an ongoing basis. |