Kensington Plant - Executive Summary

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Executive Summary 
Reichhold, Inc. is committed to operating facilities in a manner that is safe for our employees, the community and the environment.  As part of this commitment, Reichhold has established a Risk Management Program that helps the company to identify and communicate risks associated with our operations.   This program complies with the Environmental Protection Agency'' (EPA) regulation 40 CFR part 68,  Accidental Release Prevention Requirements: Risk Management Programs (the RMP Rule).   This document is intended to satisfy the RMP Plan requirements, and to provide the public with an overview of the risk management program in place here at Reichhold. 
Accidental Release Prevention and Emergency Response Policies 
Reichhold, Inc.  is committed to the safety and protection of its employees, neighboring communities and environment through the prevention of the accidental release of hazardous materials.  As part of this commitment, we have established reasonable controls to 
prevent accidental releases from occurring.   Despite these measures, should an accidental release of hazardous material occur, we have also developed specific plans for each facility to reduce the effect of release upon our employees and the general public.  We have also developed site -specific plans for emergency response that involve both our employees and local emergency service providers. 
Description of Source and Regulated Substances 
Reichhold, Inc  operates a facility located in Chickamauga, GA, which  produces various latex polymers used in the manufacture of carpets and hand gloves.     We use several chemicals to manufacture these polymers.   Two of these chemicals, acrylonitrile and 1,3-butadiene, are regulated by the RMP rule. 
General Accidental Release  / Chemical-Specific  Prevention Program 
As a participating member of the Chemical Manufacturers Association (CMA), Reichhold , Inc. is dedicated to continuous improvement to the inherent safety of its chemical proces 
ses and environmental, health, and safety programs.  To help achieve these goals, this site has a comprehensive environmental, health, and safety program, which includes compliance with the Occupational Safety and Health Administration's (OSHA) Process Safety Management regulation (29 CFR 1910.119). 
Employee Participation, Operating Procedures, and Training 
This facility maintains a highly trained, skilled, and knowledgeable workforce.   Numerous resources and opportunities exist for the benefit of our employees (operations, maintenance, and others) and to provide for the safe work practices exist for the operation and maintenance of our facility.   Written operating procedures and safe working practices exist for the operation and maintenance of our facility.   Our employees receive regular training with respect to these procedures and their application.   In addition, our employees take an active role in the environment, health, and safety operations of the facility, including such 
programs as Process Hazard Analysis, Incident Investigation, and Emergency Planning and Response. 
Process Safety Information, Trade Secrets, and Process Hazard Analysis 
This facility maintains Material Safety Data Sheets (MSDS) for all chemicals handled on site.   The site also maintains technological information such as process chemistry, maximum intended inventories, safe upper and lower operational limits, and an evaluation of the consequences of deviation from those limits. 
Information is also maintained on the processing equipment used within the facility.  This includes relief system design, electrical classifications, design codes and standards. 
All of this information is available to our employees for their use, regardless of the trade secret/patent implications.   This information is used to conduct process hazard analyses in which potential hazard scenarios are identified and analyzed for their potential to occur and/or have a harmful effect on the employees, community,  
or environment.   The data from these studies is then used to propose additional safety systems, procedures, and/or training in an effort to prevent the hazard scenario from occurring. 
Management of Change and Pre-Startup Safety Review 
Changes to chemical processing, equipment, procedures, or other systems that affect the operation of the facility all require proper review and approval prior to implementation.    Therefore, a change cannot occur within a hazardous process without proper consideration being given to the potential hazards that the change could introduce into the manufacturing process.   Additionally, any physical changes that occur require a pre-startup safety review to ensure that, prior to chemical introduction, equipment installation is correct, operating procedures have been updated, and affected employees have been trained in the details of the change. 
Mechanical Integrity, Contractors, and Hot Work 
This facility maintains a maintenance testing and inspection pr 
ogram for equipment used within its hazardous processes.   This program includes the regular testing and inspection of equipment to ensure that the equipment is still suitable for the application in which it is being used.   There are also rigorous programs in place within the facility to keep maintenance and contractor personnel trained on the hazards of the process and in the safe work programs such as Hot Work, Confined Space, Lock Out / Tag Out, and Equipment Preparation.    Under the Hot Work program, all work generating sparks, open flames, or other sources of thermal energy such as welding or cutting requires the issuance of a permit to perform such work. 
Incident Investigation, Emergency Planning and Response 
This facility recognizes that while every effort is made to keep chemicals within the process, no system is 100% safe and that accidents can and do occur.   Therefore, any and all incidents that resulted in, or could have resulted in, a major release of chemical or an in 
jury are investigated to determine the root cause and allow for appropriate prevention programs, systems, or training to be implemented to prevent re-occurrence.  In addition, the facility maintains a comprehensive Emergency Response Plan designed to mitigate and correct any emergency condition that may occur.   Regular training and drills are part of this program. 
Compliance Auditing 
In an effort to continuously improve upon these programs, regular audits are done to determine the facility's implementation and operation under these programs.   These audits are then used to determine where additional efforts, program changes, or training needs to be implemented to ensure that we are meeting the intent and requirements of our environmental, health, and safety programs. 
Five Year Accident History 
There have been five reportable releases involving 1,3-butadiene and/or acrylonitrile during the past five years.   Four of these releases were very small and resulted in no injuries or off- 
site impacts.  Approximately 300 people were evacuated for pre-cautionary reasons as the result of a 1,3-butadiene accident that occurred in February of 1995; however, no one was injured and there were no off-site impacts. 
Emergency Response Plan 
The site has a comprehensive emergency response plan.   There is always an emergency brigade on each work shift available to respond to an emergency situation.  Every member of the emergency brigade receives quarterly training. 
An emergency drill is held annually and involves local emergency responders. 
The emergency notification system utilizes 911 to notify residences near the plant of an emergency situation.  There is also a community siren that can be activated by the 911 service. 
Release Scenarios 
Worst-case scenario (flammable) 
For this scenario, approximately 500,000 pounds of 1,3-butadiene is assumed to escape suddenly  from a catastrophic failure of the storage tank and is immediately ignited.  No active or passive mitigation i 
s assumed.  The one psi overpressure radius is 0.63 miles. 
Worst-case scenario  (toxic) 
For this scenario, approximately 266,000 pounds of acrylonitrile is assumed to escape suddenly from a catastrophic failure that empties both storage tanks.  Only the passive mitigation of a surrounding collection dike is assumed.  The toxic endpoint has a radius of 2.5 miles.   
Alternative-case scenario (flammable) 
For this scenario, approximately 63,000 pounds of 1,3-butadiene is assumed to escape suddenly and is immediately ignited.  No active or passive mitigation is assumed.  The one psi overpressure radius is 0.21 miles. 
Alternative-case scenario  (toxic) 
For this scenario, approximately 375 pounds of acrylonitrile is assumed to escape suddenly from a reactor pressure relief valve.  Operators are immediately alerted to the overpressurization by the process control system and the emergency shutdown system is activated, stopping the release within one minute.  The toxic endpoint has a radiu 
s of 0.3 miles.    
Planned Changes To Improve Safety 
The site is currently conducting up-front engineering of an ambient air monitoring system to detect releases of acrylonitrile and 1,3-butadiene.
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