Rust-Oleum Corporation - Executive Summary |
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A Risk Management Program (RMP) has been implemented at Rust-Oleum's Pleasant Prairie facility for the reduction of accidental releases of hazardous materials. The RMP summarizes the management, administrative, procedural, and technological controls that work together to minimize the risk to the community of hazardous chemical releases. The Risk Management Plan is organized to correspond with specific U.S. Environmental Protection Agency (EPA) RMP definitions and requirements, including: 7 Pleasant Prairie's policies to protect health, environment, and safety; 7 Facility identification and regulated substances covered processes; 7 Hazard Assessment; 7 Prevention Program; 7 Five-Year Accident History; 7 Emergency Response Plan; and 7 Planned changes to improve safety. PLEASANT PRAIRIE POLICIES TO PROTECT HEALTH, ENVIRONMENT, AND SAFETY Risk management and safety are important concerns at Pleasant Prairie; this RMP formalizes and documents these activities. Pleasant Prairie is committed to conducting its operations in a safe and responsible manner and to reducing risks to human health and to the environment. FACILITY IDENTIFICATION The Rust-Oleum Corporation owns and operates a paint manufacturing plant in Pleasant Prairie, Wisconsin. LP gas (propane/butane mixture) is used at the facility as a propellant for aerosol paints. LP gas is a regulated flammable RMP substance with a threshold quantity for accidental release prevention of 10,000 pounds. The amount of LP gas present in the system is approximately 93,000 pounds. HAZARD ASSESSMENT - WORST CASE SCENARIOS (WCS) The worst-case toxic accidental release scenario assumes the entire contents of a single 12,000-gallon storage tank of LP gas are instantaneously involved in a vapor cloud explosion. According to equation C-1 of EPA's OCA Guidance document the distance to the endpoint of an overpressure of 1 psi is estimated to fall 0.29 miles from the storage tank. HAZARD ASSESSMENT - ALTERNATIVE RELEASE SCENARI OS (ARS) The ARS for the LP gas assumes a feed line is severed and a flow of up to 100 gpm is released for 5 minutes. The release results in a vapor cloud explosion. According to equation C-1 of EPA's OCA Guidance document the distance to the endpoint of an overpressure of 1 psi is estimated to fall 0.06 miles from the storage tank. GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM A prevention program is in place to minimize the risk of hazardous chemical releases in accordance with the OSHA Process Safety Management (PSM) standard (29 CFR 1910.119) and the EPA Risk Management Program. This prevention program covers the entire paint process, in which LP gas is present above the threshold quantity for both PSM and RMP rules. The prevention program provides a structured approach to preventing accidents. Some of the specific activities in the prevention program include: 7 Process safety information is provided to all employees upon hire and is accessible at all times. 7 In-depth pro cess hazard analyses are completed every five years by qualified personnel using techniques approved under the PSM standard. 7 Written operating procedures (kept up-to-date) are used for training and guiding the work of operators. 7 Training is provided to all employees upon hire, and refresher training is given annually or upon request. 7 Operators, mechanics, and contractor personnel are qualified, trained in the general hazards in the facility, and informed of any temporary situations affecting safety. 7 Pre-startup safety reviews are conducted to insure that conditions for safe operation have been satisfied prior to starting new or modified equipment. 7 A program is in place to maintain the mechanical integrity of the process, which includes written procedures, training requirements, work orders, scheduled maintenance, and computerized documentation. 7 A hot work permit system assures that work is done safely and properly. 7 A management of change system is in place to en sure that changes are managed safely. 7 Incidents are investigated and actions are taken as part of a continuous improvement effort. 7 Routine audits are conducted to assure that safe practices are being followed. 7 Employee participation is ensured through an active "Facility Safety Committee". This systematic approach to process safety at Pleasant Prairie involves employees and strives for continuing improvements in overall safety. The training, qualifications, and safety awareness of our operations, maintenance, and management personnel are a key element in reducing and mitigating accidents. FIVE-YEAR ACCIDENT HISTORY There have been no accidents/release of LP gas from the covered process at Pleasant Prairie which led to on-site deaths, injuries or significant damage in the past five years. There are also no reported incidents of off-site consequences from an accidental release of LP gas. EMERGENCY RESPONSE PLAN Pleasant Prairie has an emergency response plan to ensure that in the event of an emergency the personnel are aware of the appropriate actions to take and authorities to contact in order to mitigate the effects of a release. Response activities are coordinated with the Pleasant Prairie Fire Department. PLANNED CHANGES TO IMPROVE SAFETY Chemical safety is an important part of the Pleasant Prairie operations. Continuous improvement in safety is an important goal. The Pleasant Prairie facility has begun the initial stages of acquiring an explosion suppression system for one of two gas houses of the aerosol propellant filling operation. The other gas house already has such a system. |