Kelly-Moore Paint Company - 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 San Carlos, California ("the facility"). Kelly-Moore is committed to being a responsible member of any community in which it operates 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 and intermediate products used in manufacturing paints. The latex manufacturing process ("the process") at the facility consists of two 30,000-gallon vinyl acetate/butyl acrylate monomer blend (VA/BA) storage tanks, three latex reactors, a spent fume scrubber, and associated pumps, piping, fittings and controls. Vinyl acetate monomer is a toxic liquid stored at atmospheric temperature 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 process is regulated under the California Accidental Release Prevention (CalARP) regulations and the EPA Risk Management Program regulations because the maximum quantity of vinyl acetate monomer stored in the process is more than the threshold quantity listed in the regulations. The process does not meet the eligibility requirements for program 1 because there are public receptors within the worst-case vulnerability zone. The process does not meet the eligibility requirements for program 3 because it is not subject to the OSHA Process Safety Management standard; it is not in Standard In dustrial Classification (SIC) code 2611, 2812, 2819, 2821, 2865, 2869, 2873, 2879, or 2911; nor has it had an accidental release of a regulated substance in the last five years. Therefore, the process is eligible for program 2 requirements. The worst-case release scenario associated with the release of toxic substances from the process is the release of the total contents of two interconnected VA/BA storage tanks (350,520 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 5 second release of 204 pounds of vinyl acetate monomer. The storage tanks and the fill station have secondary containment systems to mitigate the impact of an accidental release should one occur. Additional safeguards to prevent and mitigate accidental releases of regulated substances are described in the facility's operations, training, maintenance, and emergency response procedures. The process has con trol 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. Kelly-Moore has trained hazardous response and response/containment teams, appropriate equipment and supplies, and a detailed emergency response plan. Emergency response procedures have been coordinated betw een Kelly-Moore and local emergency response organizations. 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. Kelly-Moore considered natural- and human-caused internal and external events in the hazard review. The potential hazards associated with these external events include a spill of vinyl acetate monomer from a tank, tank truck, or transfer line; a fire; an explosion; or a runaway reaction in the VA/BA storage tanks. The process has secondary containment systems, alarms, fire detection and suppression systems, and neutralization systems in place to monitor, detect, control and mitigate each of these potential hazards. Recommendations were developed as a result of the hazard review, equipment inspections, safety meet ings, review of industry experience, technology improvements, and employee suggestions. The following changes to improve safety are planned: install an audible high-temperature alarm on the VA/BA storage tank thermometer; incorporate high-temperature alarm response instructions into operating, training and maintenance procedures; and update the mechanical integrity records for the VA/BA storage tanks. These changes are expected to be complete by January 31, 2000 |