Capital Resin Corporation - Executive Summary |
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Capital Resin Corporation (CRC) believes in a proactive, integrated approach to Accidental Release Prevention. Our program integrates ongoing upgrades in periodic maintenance scheduling, ISO documentation, and Process Safety Management. CRC personnel receive initial training in emergency response plans and policy during new employee orientation, and hands on training annually. Contracts are in place with local response companies to insure immediate service should contingencies occur that exceed the capacities of CRC equipment or personnel. CRC processes covered by the Risk Management program include our formaldehyde manufacturing plant and its associated storage tanks and load rack. The regulated substance (per 68.130) is formaldehyde solution (50-00-0). As the attached Risk Management Plan details, our worst case scenario involves the complete failure of one or more of the storage tanks. While the chances of this occurring are extremely unlikely, analysis of this scenario was r equired under the RMP rule. Any leak or failure in the formaldehyde storage system would be contained by the dike system around the tanks. Accidental Release Prevention is integrated with all aspects of CRC operations. Process Safety information is contained in each Formaldehyde Operator's Manual and MSDS data. Formaldehyde Training, conducted approximately every 18 months, provides intensive, documented explanation of each of the required areas. Written operating procedures are documented and controlled through CRC's ISO 9000 program. Operating Procedures are reviewed and a written test is administered in the formal training sessions. Each employee involved in operating the Formaldehyde Plant, Tanks, or Load Rack is trained in an overview of the process and familiarization with the operating procedures described previously. The training emphasizes safe operation of the plant and associated systems. Several weeks of on job training emphasize job tasks, safety and health hazard s, normal and emergency operations, and safe work practices. CRC's utilizes a software based system to control and track periodic maintenance requirements and insure mechanical integrity of its processes. Under this program, representative sampling and inspection of formaldehyde tank structure for corrosion and integrity is accomplished. CRC has mature Management of Change and Pre Start-up Review programs implemented under PSM and administered for this and other processes. |