Kelly-Moore Paint Company, Inc. - Executive Summary |
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The Kelly-Moore Paint Company, Inc. ("Kelly-Moore") has prepared this Risk Management Plan for the facility it owns and operates in Hurst, Texas ("the facility"). Kelly-Moore is committed to being a responsible member of any community in which it has operations and gives top priority to operating in a safe and environmentally sound manner. This commitment to safe and environmentally sound operations is documented in Kelly-Moore's policies, procedures, and compliance manuals, which are available to all employees. The primary purpose of the facility is to produce water base paints, oil base paints and intermediate products used in manufacturing paints. The latex manufacturing process ("the process") at the facility consists of three 10,000-gallon vinyl acetate/butyl acrylate monomer blend (VA/BA) storage tanks, two 3,000 gallon reactors, a spent fume scrubber, and associated pumps, piping, fittings and controls. Vinyl acetate monomer is a toxic liquid stored at atmospheric temp erature and pressure. Personnel at the facility reviewed all incident investigation reports from January 1994 to present to identify accidental releases of extremely hazardous substances that resulted in deaths, injuries, or significant property damage on site, or known off-site deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage. No accidental releases were identified. The worst-case release scenario associated with the release of toxic substances from the process is the release of the total contents of the three interconnected VA/BA storage tanks (166,036 pounds of vinyl acetate monomer). The alternative-case release scenario is a spill at the fill station caused by failure of a transfer hose resulting in a five second release of 204 pounds of vinyl acetate monomer. The storage tanks have secondary containment systems to mitigate the impact of an accidental release should one occur. Additional safeguards to prevent and mitigate accid ental releases of regulated substances are described in the facility's operations, training, maintenance, and emergency response procedures. The process has control systems designed to maintain operating parameters within allowable limits. The process is also equipped with alarms to alert personnel when the operating parameters exceed the allowable limits. Kelly-Moore developed procedures and trained facility personnel to familiarize them with the consequences of exceeding allowable limits and the hazards of the regulated substance to ensure the correct response to the alarms. Overall safety at the facility is governed not only by the ability to prevent accidental releases of regulated substances, but also by the ability to mitigate any accidental releases. Kelly-Moore therefore developed an emergency response program to minimize the effects of accidental releases of regulated substances on employees, the public, and the environment. The facility has a trained hazardous respo nse and response/containment teams, appropriate equipment and supplies, and a detailed emergency response plan. Kelly-Moore conducted a review to identify the hazards associated with its process and regulated substance, opportunities for equipment malfunction or human error that could cause a release, safeguards that will control the hazards or prevent the malfunction or error, and steps to detect or monitor releases. Recommendations were developed as a result of the review and other equipment inspections, safety meetings, review of industry experience, technology improvements, and employee suggestions. The following change to improve safety is planned: develop and implement a procedure to monitor the temperature in the VA/BA storage tank during power outages by December 31, 1999. |