Archimica (Florida) - Executive Summary |
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ARCHIMICA (FLORIDA) EXECUTIVE SUMMARY Archimica (Florida), Inc. uses five regulated substances in various reactions during the manufacturing of organic chemicals (NAICS Code 32519). The regulated substances are listed below. Acetylene (flammable, CAS # 74-86-2) Anhydrous ammonia (toxic, CAS # 7664-41-7) Oleum (toxic, CAS # 8014-95-7) Trichlorosilane (flammable, CAS # 10025-78-2) Trimethylchlorosilane (toxic, CAS # 75-77-4) A hazard assessment was performed using the United States Environmental Protection Agency (USEPA) RMP*CompTM. Model. The worst-case release scenarios were assumed to be the total release of the largest quantity of each substance from their respective storage vessel for a duration of 10 minutes. The alternative release scenarios we selected were failure scenarios developed during process hazard reviews and analyses. The alternative release scenario for each regulated substance is described below. Acetylene - A regulator fail ure causes the two inch diameter pipe to pressurize to 100 psig. A release occurs at the relief valve at the reactor, causing an explosion. Anhydrous ammonia -The flange on the remote operated valve (ROV) fails, causing a release to occur. Oleum - A failure in the bottom valve in reactor R-5 due to corrosion causes a release to occur. Trichlorosilane - A leak develops in the recirculation line. This scenario is based on a release that occurred at the facility on August 8, 1998. Trimethylchlorosilane - A two inch diameter pipe fails at the pipe rack causing a release to occur. The following accidental release scenarios were selected based on the distance to the endpoints as determined by RMP*Comp. One worst-case release scenario for the toxic substances (anhydrous ammonia). One worst-case release scenario flammable substances (trichlorosilane). Every alternative release scenario for the toxic substances (anhydrous ammonia, oleum, trimethylchlorosilane). O ne alternative release for the flammable substances (trichlorosilane). Potential zones of impact were constructed for the selected release scenarios. These zones were analyzed to provide estimates of the total population and public and environmental receptors that could potentially be exposed should the hypothetical releases occur. Although off-site areas would be impacted by the releases, we believe that safety procedures and mitigation measures will reduce the potential for off-site consequences and subsequent risks to the surrounding community. Our safety devices include detectors, alarms, and automatic system shut-off features. We have had three releases with offsite consequences in the last five years. The substances and dates of the releases are listed below. Trichlorosilane, June 17, 1994 Anhydrous Ammonia, May 8, 1998 Trichlorosilane, August 8, 1998 Information from each release was collected and reviewed to determine the corrective actions to be implemented to p revent a reoccurrence. We considers near-misses as serious as actual releases. Therefore, the same procedures used for major incidences are used for near-misses. In order to fulfill the requirements of the Risk Management Program (RMP), we have developed an accidental release prevention program and emergency action plan for our facility. The accidental release prevention program satisfies the requirements for the USEPA RMP and the Occupational Safety and Health Administration's (OSHA) Process Safety Management (PSM) program. The prevention program ensures that our facility is operated under safe conditions and that any risk of a release is minimized. The program has been written to reduce the potential of a release due to human error or equipment failure at our facility. In order to prevent the release due to human error, our prevention program ensures that operating procedures are current and reviewed annually. Training also plays a vital part in our program. Employees and con tractors working near or on the facility's chemical manufacturing processes are required to be trained in the various processes and the hazards of the chemicals used in those processes. To prevent equipment failure that could result in a release, our program ensures that equipment inspections, tests, and preventive maintenance are in accordance with accepted engineering practices and includes manufacturer's recommendations. Manufacturing equipment is inspected and tested in accordance with the planned maintenance schedule. All existing and proposed future equipment has been designed according to applicable standards and codes. We maintain records and documentation on equipment inspections and tests. Precautions are taken to ensure that new equipment and processes are inspected and tested, that all changes on the processes are authorized, and employees are informed of changes. We performed Process Hazard Analyses (PHA) to address the facility hazards and to evaluate and contro l where the potential for a release exists. Employees were involved in determining hazards of the processes and subsequent consequences. Active employee participation will ensure the success of the RMP at our facility. Employees have been assigned various tasks to ensure that all elements of the RMP are implemented. We have developed specific programs and forms to assist employees in performing, recording, and documenting the various elements of the RMP. In the event of a release, we have implemented an Emergency Response Program in compliance with 29 CFR 1910.38 and 29 CFR 1910.120. Our facility is also included in the community emergency response plan. Employees at our facility are thoroughly trained to respond to accidental releases that occur on-site. The Emergency Response Program consists of initial response procedures, response team procedures, facility emergency numbers, and coordination with the Gainesville Fire Department. The plan also addresses notification pr ocedures to the public and the local emergency response agency. We conducted a neighborhood open house under the Local Emergency Planning Committee's (LEPC) Safety Street program in March 1999. We are also willing to conduct tours of our facility for members of the public. |