OSRAM SYLVANIA Products, Inc. - Executive Summary |
|
1. Plant Policy Concerning Chemical Safety It is the policy of OSRAM SYLVANIA Inc., St. Marys Plant to conduct its operations and to design and manufacture quality lamps in a manner which is protective of the environment and the health and safety of our employees, our customers, and the public. In furtherance of this policy, the Plant is committed to: * Being good, responsible corporate citizens in our community. * Meeting or striving to exceed all applicable environmental laws, regulations and requirements of federal, state and local governments, all all other OSRAM SYLVANIA INC. requirements. * Identifying the actual and potential environmental impacts of the plant's facilities, activities, products and services, and minimizing and eliminating them whenever reasonably possible. * Contributing to pollution prevention and to the efficient use of resources. * Continually improving its environmental management system and performance by periodically establishing, reviewing, a nd updating meaningful objectives and targets relating to prevention of pollution and the Plant's identified significant environmental impacts and applicable requirements. * Providing appropriate employee and management training and implementing programs designed to achieve the Plant's established environmental objectives and targets. * Periodically monitoring, auditing, and evaluating the Plant's environmental performance as it relates to applicable environmental requirements and established objectives and targets. 2. Facility Description The OSRAM SYLVANIA Products, Inc. St. Marys, PA facility manufactures incandescent lamps (SIC code 3641). Sulfur dioxide is used in the glass forming process. Six (6) full 2,000-pound cylinders and two (2) partial cylinders are used to store the sulfur dioxide. The two partial cylinders are stored in the SO2 room: one in use and the second on standby. The second tank is connected to the system when the first tank is empty. Only one cyli nder is in use at any one time. The remaining six (6) cylinders remain outside until they are needed. The St. Marys facility has been in continuous operation since 1955 without any incidents involving the sulfur dioxide system. 3. Worst-Case Scenario The worst-case scenario, as required by EPA guidance, assumes that the entire contents of one (1) 2,000-pound cylinder will be released during a 10-minute event. The consequences of such an event were modeled using the EPA/NOAA Areal Locations of Hazardous Atmospheres (ALOHA) model. Assuming that the release occurred during the worst-case meteorological conditions, such an event could cause the EPA's toxic endpoint (0.0078 mg/l) to be exceeded beyond the plant boundaries. 4. Alternative Release Scenario Several alternative scenarios have been evaluated for this RMP. The scenarios all involved damage to a single cylinder caused by human error or equipment failure, circumstances that are believed to be the most likely causes of an accident. The ALOHA model was used to estimate the distance from the facility that the toxic endpoint (0.0078 mg/l) could reach. Scenarios included broken valves above and below the liquid level of the tank and tank punctures of various sizes above and below the liquid level. The maximum distance to the toxic endpoint was caused by dropping the tank onto a sharp object that would cause a small puncture (one-inch diameter) in the bottom of the tank. As for the worst-case scenario, such an event would cause the toxic endpoint to be exceeded beyond the plant boundaries. 5. OSRAM SYLVANIA Prevention Program The sulfur doxide tanks and assoicated piping are subject to the OSHA Process Safety Management (PSM) program. OSRAM SYLVANIA complies with the requirements of PSM and has reviewed its program during preparation of this plan. 6. Five-Year Accident History OSRAM SYLVANIA has had no accidents involving the sulfur dioxide system during the period June 21, 1994 through June 21, 1999. 7. Emergency Response Plan OSRAM SYLVANIA employees are not trained to be first responders for emergency situations involving the sulfur dioxide system. In the event of an emergency, OSRAM SYLVANIA's emergency coordinators would notify proper authorities including the Crystal Fire Department, the Elk County Hazmat Team, and the St. Marys Police Department. 8. Planned Changes No changes in the process are planned at this time. |