Benjamin Moore & Company, Newark, NJ Plant - Executive Summary |
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Executive Summary Benjamin Moore & Co. Newark, NJ Plant ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Benjamin Moore & Co. Environmental Policy Benjamin Moore & Co. is committed to sound environmental management. It is the intent of Benjamin Moore & Co. to conduct itself in partnership with the environment and community at large as a responsible and caring global corporate citizen. Benjamin Moore & Co. is committed to producing high-quality products and managing all phases of its business in a manner which minimizes any adverse effects of its products and operations on the environment. Long before the EPA was formed, Benjamin Moore & Co. made a commitment to reduce or eliminate any harmful impact on the environment from our operations and products. In 1968, Benjamin Moore & Co. removed lead as an ingredient in its paint formulations; a decade before legislation was passed banning lead in paint. In 1970 Benjamin Moore & Co. eliminated mercury from its product s, two decades before the EPA banned the use of mercury in interior paints. Of equal importance to our company was the establishment of an environmental impact program at each of our U.S. manufacturing plants. The stringent standards and guidelines we developed to protect the environment cover all aspects of the paint manufacturing process. Along with these standards and guidelines, the processes addressed by this risk management plan have been subject to OSHA's process safety management requirements since 1996. Additionally, Benjamin Moore & Co. is a participant in the National Paint and Coatings Association Coatings Care program (similar to the Chemical Manufacturers Association Responsible Care program and ISO 14000). This is an industry stewardship plan that outlines sound management practices relating to environmental, health, and safety issues. Looking to the future, Benjamin Moore & Co.'s Environmental team, led by the Director of Environmental Affairs, continues to explo re ways of manufacturing quality products in an environmentally sensitive manner. The above policies and ideals reflect our policies and commitment to accidental release prevention and emergency response at this facility. For more specific information on our accidental release prevention plan and emergency response policies, please see the labeled sections of this summary. For more information about Benjamin Moore & Co. in general, please visit our web site at www.benjaminmoore.com. FACILITY DESCRIPTION AND REGULATED SUBSTANCE HANDLED This Benjamin Moore & Co. facility located in Newark, NJ manufactures coatings such as interior and exterior paints, including latex resin, a component of latex (or water-based) paint. Almost all the products that Benjamin Moore produces at this site have no accidental release impact on the surrounding community. Of all the chemicals on site, only one used to produce latex resin, vinyl acetate, is stored in a quantity above the EPA-determined thre shold. Only enough vinyl acetate to produce a batch of latex resin is pumped from a diked storage area to a continually monitored and enclosed kettle. Highly trained and experienced operators, safety alarms and procedures, as well as other safety controls outlined in our risk management plan, ensure careful handling of the vinyl acetate throughout the process. During the manufacturing process, the vinyl acetate is reacted to form a non-hazardous polymer component of latex resin, which is then used to manufacture latex paint for your homes and businesses. THE WORST CASE AND ALTERNATIVE CASE RELEASE SCENARIOS Several different spill scenarios were modeled in order to determine a worst case scenario and an alternative case scenario. The worst case scenario was determined to be the failure of a single 20,000-gallon storage tank into a diked area. The diked area around the storage tank limits the exposed surface area of the spill and thus reduces the release rate and potential for offsite consequences. The size and duration of this scenario are very unlikely due to safety systems and response activities that would be employed. Based on conservative assumptions, the Degadis dense gas dispersion model results gave an offsite consequence circle with a radius of 0.11 miles. An alternative scenario that was chosen for inclusion in the RMP report involved a transfer hose failure resulting in a spill into the containment pad of the truck loading area. Safe unloading procedures (turning off of pumps and valves) and appropriate response were taken into consideration for this scenario. RMP Comp modeling results gave an offsite consequence circle with a radius of less than 0.1 miles. An inspection of the site revealed no residences within either circle. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS This facility complies with EPA's most stringent accidental release prevention program (level 3), as well as OSHA's process safety managemen t program, to ensure safe handling and processing. A team of engineers, plant personnel, and regulatory affairs specialists from Benjamin Moore and expert consultants in the field of process hazard analysis examined the process of making latex resin, as well as associated processes of storage, unloading, and product weighing for potential hazards. The team then developed a plan to implement solutions that would eliminate or minimize risks. Multiple safety systems, procedures, monitoring / detection devices, and mitigation comprise a safety management system that ensures safe handling of all chemicals used at this site. FIVE-YEAR ACCIDENT HISTORY We are pleased to inform the public that we have not had an accidental release of vinyl acetate in the past five years. EMERGENCY RESPONSE PROGRAM In the event of an emergency involving vinyl acetate, it is our policy to notify the Newark Office of Emergency Management, fire department, applicable environmental agencies, and police, and request that they respond to the emergency. We will also notify and employ the services of a professional hazardous materials response and clean up team, which is under contract to respond to emergencies at our facility. We have an emergency response plan that is coordinated with these parties and is practiced yearly. In addition, we train a team of onsite personnel to recognize emergency situations as soon as they occur and respond accordingly to decrease any onsite or offsite impacts. PLANNED CHANGES TO IMPROVE SAFETY Benjamin Moore & Co. is committed to the continuous safety improvement of its processes through a documented system of process safety management. Our employees, from our engineers to the specialists who operate the process also continually critique these procedures. As opportunities and new technologies arise, changes to improve safety are implemented. One improvement that is planned as a result of the risk management process is the installation of additional monitoring and detection systems to speed response time. |