Hitachi Electronic Devices (USA), Inc. - Executive Summary |
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Hitachi Electronic Devices (USA), Inc. (HED(US)) operates a color television picture tube manufacturing facility in Greenville, South Carolina, near the intersection of Interstate 85 and Mauldin Road. HED(US) has a strong corporate commitment to employee and public safety as well as environmental protection. HED(US) has been active in coordinating emergency planning and preparedness with HED(US) is in compliance with the following safety and environmental regulations and provisions: 7 Occupational Safety and Health Administration's (OSHA's) 1983 Toxic and Hazardous Substances Hazard Communication Standard (HCS). This regulation covers the training of employees, chemical labeling, maintaining current Material Safety Data Sheets (MSDSs) and communicating the hazard information to employees. 7 OSHA's HAZWOPER regulation. This regulation covers the requirements of training personnel who will be "First Responders" for emergency situations, including chemical accidents and releases. 7 OSHA's Process Safety Management (PSM) regulation. This regulation requires extensive design and operations reviews for processes involving chemicals that OSHA has classified as "Highly hazardous". HED(US)'s regulatory and safety compliance program includes routine evaluations of the hazards, personnel training and operating procedures associated with handling these chemicals. In compliance with PSM, HED(US) maintains an Emergency Planning and Response Plan for it's entire facility. Emergency Coordinators have been selected and trained. These personnel are on call at all times. HED(US) has coordinated this emergency planning with local organizations and agencies including police, fire, hospitals, rescue squads, ambulance services and state and county emergency response teams. HED(US) has developed an Emergency Planning and Response Plan in accordance with Best Management Practices (BMP) and OHSA PSM. This plan is reviewed and upd ated annually in accordance with BMP requirements. In addition, HED(US) is preparing for certification under International Standards Organization (ISO) 14000 later this year and has performed drills and audits to demonstrate the effectiveness of the emergency response procedures. This plan includes notification of local authorities and the public in the event of the release of hazardous substances. HED(US) is primarily a manufacture of color picture tubes for the electronics industry. The North American Industry Classification System code for the overall facility is 334411: Electron Tube Manufacturing. HED(US) does not produce any hazardous substances, but uses small quantities of several regulated substances in plant processes. The EPA Risk Management Program (RMP) provides Threshold Quantities (TQs) which are the minimum quantity of each regulated chemical stored on site that will require preparation of a Risk Management Plan (RMPlan). In December of 1998, HED(US) compiled a list of all regulated chemicals used at the facilities and determined the maximum quantity of each chemical that would be stored at the facility at any given time. HED(US) identified 6 regulated substances that were used at the facility that are not stored in quantities or concentrations above the TQs. In accordance with the EPA RMP regulation, these substances are not included in this RMP. These substances are included in HED(US)'s Emergency Planning and Response Plan and HED(US) has evaluated the impact of releases of these substances. In addition, HED(US) identified 1 substance, an acid, that is stored in excess of the EPA RMP TQs. This RMP is submitted for this acid. The acid is purchased in two container types: 55-gallon drums contained in overpack drums and 5-gallon plastic containers. There is only one location where the total quantity of this acid exceeds the EPA's TQ. The drums are stored until use in the Hazardous Material s Storage Building. There is a potential to have as much as 6,000 pounds of the acid in 55-gallon drums and 5,000 pounds of the acid in 5-gallon containers in this storage building. The EPA guidance for RMP states that the worst case release scenario for a substance should be based on an instantaneous release of the entire contents of the largest container. In our case, that is the release of the contents of a 55-gallon drum. The worst case release scenario could occur either inside or outside of the Hazardous Materials Storage Building. HED(US) modeled a release both inside and outside the Hazardous Materials Storage Building. The greatest distance calculated to an endpoint was for the release outside of the building, calculated at 0.31 miles. This is included in Section 2. Toxics: Worst Case. The release of the entire contents of the drum of acid inside the building was calculated to reach 0.19 miles to the endpoint and is included in Section 3. Toxics: Alternative Release. Both of these scenarios could have off-site impacts. Neither scenario is considered likely to occur. The drums are contained in overpack drums designed to contain any of the acid that may spill from the inside drum. In reviewing past releases to create the 5-year accident history (Section 6), the largest release in the past 5 years was the content of a 5-gallon container. Modeling results indicate that a release of this size would not have off-site impacts. This release was caused by using a forklift inside the Hazardous Materials Storage Building. As a result of this release, forklifts are no longer allowed inside the building for drum loading or unloading. Drums are moved with drum trucks rather than forklifts, so the likelihood of rupture during transportation is reduced. HED(US) routinely reviews and audits safety procedures, training and practices. Our philosophy is to avoid accidents and releases through adherence to sound operating procedures. Recognizing the potential for human error, equipment failure and unforeseen circumstances, HED(US) has emergency procedures in place and has coordinated with local organizations and agencies including police, fire, hospitals, rescue squads, ambulance services and state and county emergency response teams. In the event of a release from the facility, HED(US) is prepared to act quickly and decisively to notify emergency response personnel and the public while at the same time taking any possible actions to mitigate the potential for on-site and off-site damage. |