Columbus, OH Plant - Executive Summary

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1.  EXECUTIVE SUMMARY 
 
Georgia-Pacific Resins, Inc. (GPRI), a wholly owned subsidiary of Georgia-Pacific Corporation, owns and operates a synthetic resin manufacturing facility in Columbus, OH.  The facility is located on Watkins Road. The resin facility consists of a plant that was originally constructed in 1970.  Overall, the facility employs 42 full-time employees. 
 
GPRI is committed to operating the Columbus Plant in a manner that is safe for its workers, the public, and the environment.  As part of this commitment, GPRI  has established a system to help ensure safe operation of the processes at this facility.  One component of this system is a Risk Management Program (RMP) that helps manage the risks at the Columbus Plant and that complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR part 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule).  One of the requirements of the RMP rule is to submit a Risk M 
anagement Plan (RMP Plan) describing the Risk Management Program at the Columbus Plant. This document is intended to satisfy the RMP Plan requirement of the RMP rule and to provide the public with a description of the Risk Management Program at the Columbus Plant. 
 
The risk management program at the Columbus Plant consists of the following four elements: 
 
? a hazard assessment to help understand (a) the potential offsite consequences of hypothetical accidental releases and (b) accidents that have occurred during the last five years associated with the use of substances regulated by the RMP rule (regulated substances). 
 
? a prevention program to help maintain and safely operate the processes containing more than a threshold quantity of a regulated substance (covered processes). 
 
? an emergency response program to help respond to accidental releases of regulated substances from covered processes 
 
? a risk management system that assigns responsibility for specific elements of the RMP pr 
ogram. 
 
Information further describing these elements is provided in this RMP Plan. 
 
Although the risk management program at the Columbus Plant helps provide assurance that the facility is maintained and operated in a safe manner, it is only one component of the safety program.  In fact, the Columbus Plant has a comprehensive safety program in place with many levels of safeguards against release of a hazardous substance, and injuries and damage from a release of a hazardous substance. 
 
GPRI prevents releases of the hazardous substances used at the facility.  When a hazardous substance is used at the Columbus Plant, the equipment is carefully designed, built and operated to reduce the likelihood of an accidental release. Industry and government standards are closely adhered to in the design, construction, and operation of the equipment.  
 
GPRI limits damage from a release, if such a release occurs.  GPRI trains its workers to respond to an accidental release, reducing the consequences o 
f a release if it occurs.  In addition, GPRI works with the local fire department and with the Local Emergency Planning Committee (LEPC) to help prevent injuries and/or environmental damage if a release does occur. 
 
The safety program at the Columbus Plant consists of a number of elements, only some of which are required by the RMP rule. This RMP Plan is primarily intended to describe those parts of the safety program at Columbus Plant that are required by the RMP rule. 
1.1 Accidental Release Prevention and Emergency Response Policies 
 
GPRI is committed to the safety of workers and the public, and the preservation of the environment, through the prevention of accidental releases of hazardous substances.  GPRI implements reasonable controls to prevent foreseeable releases of hazardous substances.  These controls include training programs for personnel, programs to help ensure safety in the design, installation, operation, and maintenance of processes at the Columbus Plant; and programs  
to evaluate the hazards at the plant. 
 
In the event of an accidental release, the Columbus Plant controls and contains the release in a manner that will be safe for workers and will prevent injury to the public and the environment.  GPRI provides response training to its personnel, designates an emergency response coordinator to oversee response activities, and coordinates response efforts with the local fire department.  Response activities are coordinated with the LEPC.   
 
In order to effectively implement these policies, GPRI established a management system, headed by the Plant manager to oversee safety-related activities. 
 
1.2 Regulated Substances 
 
The Columbus Plant handles only formaldehyde water solution in sufficient quantity to be covered by the RMP rule, as shown in the following list of RMP-covered Program Level 3 processes at the plant. 
 
Regulated Substance    Process    Process Quantity*, lbs    RMP Threshold, lbs* 
Formaldehyde Solution (50% water)    Storage in Unpressurized Tanks    1 
21,824    15,000 
            
Formaldehyde Solution (50% water)    Resin Manufacturing    55,836    15,000 
 
* Process and threshold quantity is the quantity of "pure" chemical, not of the water solution 
1.3 Offsite Consequence Analysis 
The RMP rule includes specific requirements for the "worst-case" and "alternative release" scenarios that must be reported by GPRI.  These requirements are: 
 
? one "worst-case release scenario" for the class of toxic substances in Program 3 processes 
 
? one "alternative release scenario" for each of the toxic substances in a Program 3 process 
 
The Columbus Plant performed an offsite consequence analysis to estimate the potential for an accidental release of a regulated substance to affect the public or the environment.  The offsite consequence analysis evaluates a "worst-case release scenario" and an "alternative release scenario."  The "worst-case scenario," as described above, has never occurred, and GPRI does not expect a "worst case release" scenario described in the of 
fsite consequence analysis to ever occur.  The "alternative release scenario" was selected to help the LEPC improve the community emergency response plan.  An "alternative release scenario" represents a release that (1) might occur at a facility like the Columbus Plant and (2) would result in the relative greatest potential offsite consequences if the release occurred. 
 
 
The following information summarizes the offsite consequence analysis performed by the Columbus Plant: 
 
1.3.1 Program 3 Processes-Toxic Substances - Formaldehyde/Water Solutions 
 
The "worst-case release scenario" for a 50% water solution of formaldehyde is the release of the entire contents of 25,380 gallons formaldehyde/water solution (or 121,824  lbs of pure formaldehyde) from a formaldehyde material storage tank.  A concrete diked area contains the released formaldehyde solution which evaporates and forms a vapor cloud.  The maximum distance to the "toxic endpoint concentration" based on modeling is 0.44 mile.  The 
residential population potentially affected within this distance from the plant is approximately 78 people.  The public receptors located within this distance include nearby residences and industries.  No environmental receptors are located within this distance. 
 
The "alternative case release scenario" for a 50% water solution of formaldehyde is the overfilling of a formaldehyde material storage tank and the release of 100 gallons formaldehyde/water solution (or 480 lbs of pure formaldehyde) into the concrete diked area.  Modeling this scenario indicates a "toxic endpoint" distance of 0.1 mile. The residential population potentially affected within this distance from the plant is 0 people.  The public receptors located within this distance include nearby industries. No environmental receptors are located within this distance.     
1.4 Accidental Release Prevention Program and Chemical-Specific Prevention Steps 
 
Since 1992, the Columbus Plant has used a prevention program to help preven 
t accidental releases of hazardous substances.  Beginning in 1992, the plant formalized this prevention program for the formaldehyde storage process to comply with the 14 elements of the OSHA process safety management (PSM) prevention program. In 1996, the EPA RMP rule established levels of prevention requirements.  The Columbus Plant is subject to Program 3 which is essentially the same as OSHA PSM, except that the program also focuses on protecting the public and the environment. 
 
The following sections briefly describe the elements of the Columbus Plant's Program 3 prevention program that address EPA's RMP rule prevention program requirements. 
 
1.4.1 Program 3 Prevention Program 
 
The Columbus Plant's Program 3 prevention program consists of the following 12 elements: 
 
1.4.1.1 Process Safety Information- the Columbus Plant maintains a variety of technical documents that are used to help ensure safe operation of the plant processes.  These documents address (1) physical properties of  
hazardous substances handled at the plant, (2) operating parameters of the equipment used at the plant, and (3) design basis and configuration of the equipment at the plant.  GPRI ensures that this process safety information is available to all employees, the LEPC, and the Columbus Fire Department. 
 
Material safety data sheets (MSDSs) document the physical properties of the hazardous materials handled at the plant, including regulated substances in covered processes.  The information available for each hazardous substance typically includes: 
 
? toxicity information and permissible exposure limits 
? physical data (e.g., boiling point, melting point, flash point) 
? reactivity and corrosively data 
? thermal and chemical stability data  
? hazards of mixing substances in the process  
 
MSDSs for hazardous substances handled in each process are available in the quality control lab (raw material MSDS's) and in the main office (product MSDS's) so that the operators have ready reference to this 
information.  In addition, a list of MSDSs is provided to the LEPC and the fire department for use in helping formulate emergency response plans. 
 
The equipment used in each covered process is designed, maintained, inspected, tested and operated in a safe manner.  The engineering design documents include the operating parameters and the design basis and configuration of the equipment in each covered process.  The available information includes: 
 
? operating parameters (PMI) 
? block flow or simplified process flow diagrams  (SOP) 
? process chemistry (SOP) 
? maximum intended inventories (SOP) 
? safe upper and lower limits for parameters such as temperature, pressure, or flow (Engineering Dept) 
? consequences of deviations from established operating limits (SOP) 
? piping and instrumentation diagrams, including materials of construction (Engineering Dept.) 
? electrical classification (Engineering Dept.) 
? safety  and relief systems  (i.e. interlocks, KEEC, PQ) 
? ventilation system design 
 
? material and energy balances for processes built after June 21, 1999 
? design codes and standards employed 
 
Some key information was developed through special projects or, in the case of operating parameters, during process hazard analyses of the process. Many of the operating parameters are included in the operating procedures to help with the safe operation of the process. These documents are used to (l) train employees, (2) perform process hazards analyses, and (3) help maintain the equipment.  The equipment complies with recognized and generally accepted good engineering practices. 
 
1.4.1.2 Process Hazard Analysis 
 
The Columbus Plant performs an initial process hazard analysis (PHA) on each covered process, and updates each PHA at least every five years unless there is significant changes in the process safety information of the covered processes.  The PHA's comply with 29 CFR 1910.11(e) and were completed by June 21, 1999.  These PHAs help to identify process hazards and generat 
e recommendations to improve the safe operation of the process.  A team composed of personnel with engineering and process operating experience and a leader with process hazard analysis experience, is assembled to analyze the hazards of the process.  The plant primarily uses the "what-if checklist" technique to perform this analysis.  The PHA team prepares a written report describing the results of the analysis, including a list of recommendations.  Responsibility to resolve the recommendations is assigned to unit personnel and, when appropriate, changes to enhance the safety of the process are implemented. Reports are issued periodically to track progress of PHA findings/recommendations.  The PHA's are maintained at the Columbus Plant for the life of the process.  
 
1.4.1.3 Operating Procedures 
 
Columbus Plant operators and supervisors work together to develop and maintain operating procedures to define how tasks related to process operations should be safely performed. The operating  
procedures (1) are used to train employees and (2) serve as reference guides for appropriate actions to take during both normal operations and process upsets.  Operating procedures include: 
 
? steps for safely conducting activities 
? applicable process safety information, such as safe operating limits and consequences of process deviations and steps required to correct or avoid deviations 
? safety and health considerations, such as chemical hazards, personal protective equipment     requirements, and actions to take if exposure to a hazardous substance occurs 
? quality control for raw materials and control of hazardous chemical inventory levels 
? safety systems and their functions 
 
Plant personnel develop and maintain operating procedures that cover all phases of operations, including initial startup, normal operations, normal shutdown, emergency shutdown, startup following a turnaround or emergency shutdown, and temporary operations. The operating procedures are readily accessible to emp 
loyees and are used both to help in operating the plant's processes and as a training guide. 
 
1.4.1.4 Training 
 
The Columbus Plant trains its workers to safely and effectively perform their assigned tasks.  The training program includes both initial and refresher training that covers (1) a general overview of the process, (2) the properties and safety and health hazards of the substances in the process, and (3) a detailed review of the process operating procedures and safe work practices.  Oral reviews and written tests are used to verify that an employee understands the training material. Recommendations from the operators are reviewed, and changes to the training program are implemented as appropriate. The Columbus Plant maintains records which document the date the employee received training and verification that the employee understood the training received. 
1.4.1.5  Mechanical Integrity 
 
The Columbus Plant maintains a written mechanical integrity program to maintain the on-going i 
ntegrity of process equipment to help prevent equipment failures that could endanger workers, the public, or the environment.  The mechanical integrity program includes (1) an inspection and testing program to help identify equipment deterioration, and damage before the equipment fails and (2) a quality assurance program to help ensure that new and replacement equipment meets the design standards required for service in the plant's processes.  The mechanical integrity program includes: 
 
? specifications for inspection and testing of process equipment 
? specifications for replacement parts and equipment 
? procedures for inspecting, testing, and maintaining process equipment 
? procedures for safe work practices such as lockout/tagout, hot work, confined space entry, and line or equipment opening 
? training of maintenance personnel 
? documentation of maintenance activities 
 
1.4.1.6 Management of Change 
 
The Columbus Plant management of change program evaluates and approves all proposed ch 
anges to chemicals, equipment, and procedures for a covered process, to help ensure that the change does not negatively affect safe operations.  Process changes that are determined to be a replacement in kind (e.g., replacing a valve with an identical valve) are allowed without completing a full management of change program. All other changes must be confirmed through the full management of change program to help ensure that inadvertent consequences of process changes are prevented, safety consequences of changes are addressed, affected process safety information and procedures are updated, and affected employees are notified of the changes. 
 
1.4.1.7 Pre-startup Review 
 
The Columbus Plant performs a safety review of a new or modified process before the process is placed into service, to help ensure that the process has been prepared to operate safely. This review confirms that: 
 
? construction and equipment are in accordance with design specifications 
? adequate safety, operating, main 
tenance, and emergency procedures are in place 
? employee training has been completed 
? for a covered process, a PHA has been performed if the process is new, or management of change     requirements have been completed if an existing process has been modified 
 
A pre-startup review checklist is completed to document the review and to ensure that appropriate issues have been addressed. 
 
1.4.1.8 Compliance Audit 
 
At least every three years, the Columbus Plant audits covered processes to be certain that the prevention program is effectively addressing the safety issues of operations at the plant.  The plant assembles an audit team that includes personnel knowledgeable in the RMP and PSM rules and in the process. This team evaluates whether the prevention program satisfies the requirements of the RMP and PSM rules and whether the prevention program is sufficient to help ensure safe operation of the process. The results of the audit are documented, recommendations are resolved, and appropr 
iate enhancements to the prevention program are implemented. 
 
1.4.1.9 Incident Investigation 
 
The Columbus Plant investigates all incidents that could reasonably have resulted in a catastrophic release of a regulated substance and serious injury to personnel, the public, or the environment so that similar accidents can be prevented in the future.  The plant trains employees to identify and report any incident requiring investigation.  An investigation team, with appropriate knowledge and experience, is assembled, and the investigation is initiated within 48 hours of the incident.  The results of the investigation are documented, recommendations are resolved, and appropriate process enhancements are implemented.  The results are also reviewed with all affected employees and are maintained for at least five years. 
 
1.4.1.10 Employee Participation 
 
The Columbus Plant has a written employee participation program for all covered processes to help ensure that the safety concerns of the plant 
's workers are addressed.  The plant encourages active participation of personnel in the prevention program activities of all processes at the plant. Employees are consulted on, and informed about, all aspects of the RMP rule prevention program, including PHAs and operating procedures. 
 
1.4.1.11 Hot Work Permits 
 
The Columbus Plant manages the  hot work permit program to control spark- or flame-producing activities that could result in fires or explosions in covered processes at the plant.  The  Division Safety Department reviewed OSHA's fire prevention and protection requirements in 29 CFR 1910.252(a) and created a Hot Work Permit Form to comply with these requirements. The Lead Operator Technician (LOT) initiates, completes and approves the form before work can begin.  Training in the use of the Hot Work Permit Form is included in the plant's safe work practices orientation. 
 
1.4.1.12 Contractors 
 
The Columbus Plant manages a program to help ensure that contractor activities at the p 
lant are performed in a safe manner.  The program reviews the safety record of all contractors to help ensure that the plant only hires contractors who can safely perform the desired job tasks.  The plant explains to the contract supervisors the hazards of the process on which they and their employees will work, the plant's safe work practices, and the plant's emergency response procedures.  The plant requires that the contractor supervisors train each of their employees who will work at the plant before that worker begins work at the plant site.  The plant periodically reviews contractors' training documents and work performance to help ensure that safe practices are followed. 
 
1.4.2 Chemical-specific Prevention Steps 
 
In addition to the required prevention program elements, the Columbus Plant has implemented safety features specific to the hazardous substances used at the plant.  The following paragraphs describe some of these features. 
 
Formaldehyde solution-Industry standards are f 
ollowed at the plant to help ensure safe handling of formaldehyde.  The formaldehyde stored in the plant's storage vessels is delivered to the plant by offsite vendors or manufactured on-site. The formaldehyde vendor supplies formaldehyde solution via a DOT--approved tank truck, and follows DOT standards when loading the formaldehyde storage tank(s).  The storage tank(s) design and construction are consistent with ANSI standards.  Workers who perform operations involving formaldehyde receive training emphasizing safe handling procedures for formaldehyde developed by the plant. The storage tank(s) is surrounded by a concrete dike which is large enough to contain 100% of the volume of the one of the single largest tanks should its entire contents be released. 
 
1.5  Five-Year Accident History 
 
As defined by the RMP regulations, the Columbus Plant has documented a "five year accident history" that indicates one off-site release incident of toxic compounds in the last five years. 
 
Table 3-  
Five Year Accident History  
 
Year    Number of Reported Accidents    Substance Released    Consequences 
 
1994    0    None    No Offsite Impacts 
1995    0    None    No Offsite Impacts 
1996    0    None    No Offsite Impacts 
1997    1    See Table 4 and Section 4    See Table 4 and Section 4 
1998    0    None    No Offsite Impacts 
1999 to date    0    None    No Offsite Impacts 
 
There was one accidental release from a covered process at the Columbus Plant in September 1997.  There were no accidental releases from the plant in the other four years being reported in this RMP that resulted in deaths, injuries, or significant property damage onsite, or offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. 
 
As required by 40 CFR ?68.42, information about the September 10, 1997 accident is listed in Table 4 attached to this RMP.  The information contained in Table 4 is limited by the format requirements of the EPA's electronic submission which only allows for the input of numeric data and does not permit t 
he Columbus Plant to explain or clarify the data reported.  The following summary provides necessary clarification and explanation for certain data in Table 4 which cannot be adequately reported by a single numeric entry. 
 
Release Time and Chemicals Released:  The release occurred on September 10, 1997, beginning at approximately 10:40 a.m. and lasting approximately 23 seconds (in Table 4, the Release Duration is entered as 1 minute because that is the smallest increment of time that can be entered).  The release was verbally reported to the Ohio EPA Division of Emergency and Remedial Response (DEER) on September 10, 1997.  On September 11, 1997, the release was again verbally reported to OEPA, the LEPC, and the National Response Center with the initial estimate that 57,190 pounds of phenol were released. By letter dated September 16, 1997, the Columbus Plant notified the OEPA and the Franklin County LEPC that, upon further investigation, the actual amounts released were not more than  
34,000 pounds of phenol and 30 pounds of sulfuric acid. By letters dated April 6, 1998, the Columbus Plant modified its earlier notice to the OEPA and Columbus LEPC and stated that "[i]t has been estimated that only 233 pounds of partially polymerized material was not contained on-site.  The 233 pounds of material was comprised of approximately 153 pounds of phenol and 79 pounds of formaldehyde."  The April 6, 1998 revision was made based on physical observations and OEPA observations and notes.  The Columbus Plant is reviewing these prior notices to verify the information and, determine if any additional revisions should be made. 
 
On February 15, 2000, the Columbus Plant notified the Ohio Environmental Protection Agency, National Response Center and the Franklin County LEPC that, after further review and study, the best estimate of the amount of phenol released to the atmosphere was less than 1,100 pounds (gas), that the amount of formaldehyde released to the atmosphere was less than  
250 pounds (gas), and that the amount of sulfuric acid that was released to the atmosphere was less than 70 pounds (gas). 
                                                                                                                                                                                                                                                                                                                                     Onsite Impacts:  
 
Number of Injuries:  The number of onsite injuries, as defined by 40 CFR ?68.3, is reported as 8.  This number includes 4 emergency responders identified in the Critical Incident Report issued by the City of Columbus on November 11, 1997 ("CIR") as individuals who reportedly received medical treatment due to chemical exposure, however, the Columbus Plant has not verified that these emergency responders, in fact, had such exposure or received such medical treatment. 
 
Offsite Impacts: 
 
Number of injuries; Number of Individuals Hos 
pitalized; and Number of Individuals receiving other treatment.  As explained in this paragraph, based upon information received to date, it is unknown, how many, if any, individuals were injured, hospitalized, or received other treatment, and therefore, the Columbus Plant has reported zero for each of these items.  The CIR states that there were no known reports of injured residents or residents taken to area hospitals.  The Columbus Plant has received claims for bodily injury which have not been adjusted either because the claimants are not represented by counsel and the Columbus Plant is therefore unable to adjust those claims because of the pending litigation or because the Columbus Plant has not received documentary support sufficient to verify the claimed injuries of the community members who are represented by counsel.  The Columbus Plant paid medical expenses for two individuals' minor medical treatment, but the Columbus Plant has not verified that the injuries were related to  
the accident.  Although the CIR lists eight residents who complained of symptoms at the time of the accident, the Columbus Plant has been unable to either verify the complaints or document that the identified residents required medical treatment.  
 
Number of individuals evacuated: The total number of individuals evacuated is unknown and, therefore, the Columbus Plant reported zero for this item.  The CIR does not state the total number of individuals evacuated but reports that the Columbus Police Department evacuated three businesses, one school and approximately 12-15 homes along Watkins Road from New World to Alum Creek.  The evacuated businesses, school, and homes were all east of the Columbus Plant. 
 
Property Damage:  Table 4 lists the amount of offsite property damage as  $87,016.10.  This amount represents the amount of offsite property damage claims that have been adjusted and paid by the Columbus Plant as of June 21, 1999. The Columbus Plant has received additional claims for p 
roperty damage which have not been adjusted either because the claimants are not represented by counsel and the Columbus Plant is therefore unable to adjust those claims because of the pending litigation or because the Columbus Plant has not received documentary support sufficient to verify the claimed damages of the community members who are represented by counsel.   
 
Environmental Damage:  Table 4 reports $750.00 for environmental damages which is the amount that was paid to one community member for damage to mulberry bushes and items in a vegetable garden.  The Columbus Plant has received claims from four other community members who allege defoliation damage but the Columbus Plant has been unable to either verify these claims or document that there was, in fact, defoliation damage. 
In addition to the foregoing, on May 6, 1998, a lawsuit was filed suit in state court in Columbus, Ohio by eight plaintiffs who seek to represent a class of individuals who, among other things, lived, wor 
ked, resided, owned, frequented, or otherwise allegedly occupied property located within a three mile radius of the Columbus Plant and allegedly suffered bodily injuries, property damage, and/or environmental damage as a result of the release on September 10, 1997.  The Columbus Plant has denied the material allegations of this lawsuit and the litigation is proceeding. 
1.6 Emergency Response Programs 
 
The Columbus Plant has established a written emergency response program to help safely respond to accidental releases of hazardous substances and to protect public health and the environment. The emergency response plan includes procedures for the following: 
 
? informing the local emergency agencies, including the fire department, about accidental releases that could reasonably result in offsite consequences 
 
? providing proper first aid and emergency medical treatment to treat accidental human exposure to hazardous substances at the plant 
 
? controlling and containing accidental release 
s of hazardous substances, including the use of emergency response equipment 
 
? inspecting and maintaining emergency response equipment 
 
? reviewing and updating the emergency response plan 
 
The Columbus Plant maintains an emergency response team trained in these emergency response procedures.  All plant personnel are trained in evacuation procedures.  The plant periodically conducts emergency response drills. The written emergency response plan complies with other federal contingency plan regulations (e.g., the OSHA regulations 29 CFR 1910.38(a), 29 CFR 1910.120(a), is reviewed and updated as appropriate and has been communicated to local emergency response officials through the local fire department. 
 
A copy of the plant's Emergency Response Plan is attached to the RMP Plan maintained at the plant. 
 
1.7 Risk Management System 
 
The Columbus Plant has established and maintains a risk management system that assigns responsibility for specific elements of the RMP program.  These elemen 
ts include preparation and maintenance of the hazards assessment, accident prevention program (including OSHA PSM), and emergency response plan; RMP Plan preparation and submittal; and communication.  This system ensures that Columbus Plant employees work as a responsible and accountable team, ensuring that the plant operates in a safe and reliable manner, protecting workers, the community, and the environment.  The risk management system document is maintained at the plant and is part of this RMP. 
 
1.8 Planned Changes to Improve Safety  
 
The Columbus Plant constantly strives to improve the safety of the processes at the facility through both the incident investigation program and a program soliciting safety suggestions from the workers.  The list of safety items listed below will be installed and operational at the plant before the end of 1999. 
 
Improved Tank level indicators 
New High/low level alarms 
New Automatic temperature controls 
New Automated resin process controls 
Redesign rel 
ief valves and piping for the KEEC Tanks 
Revised operator training programs 
Larger relief containment tank 
New Base quenching system for resin manufacturing
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