Reichhold Inc. - Executive Summary |
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Executive Summary As a participating member of the Chemical Manufacturers Association (CMA), Reichhold Chemicals, Inc., is committed to the Responsible Care . program and 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. As part of this commitment, we have established reasonable controls to prevent accidental releases from occurring. Despite these measures, should an accidental release of a hazardous material occur, we have also developed specific plans for each facility to reduce the effects of potential releases 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 Valley Park Reichhold Ch emicals, Inc. operates approximately 25 facilities in North America. We produce a wide variety of polymers and resins found in many household items. This particular facility produces various materials found in paints, varnishes, adhesives and other common items. We use several chemicals to manufacture these products. Only one of these chemicals is subject to the RMP regulation. Reichhold uses Toluene Di-isocyanate, commonly referred to as TDI. It is used to produce a variety of urethane coatings. Reichhold has one storage tank that contains 85,000 pounds of TDI. The storage tank is located inside a containment dike located within a building. In addition to TDI, Reichhold uses several other chemicals not subject to the RMP regulation. Offsite Consequence Analysis Should there be the unlikely catastrophic failure of the TDI storage tank, the toxic endpoint is 0.1 mile radius or 0.03 square miles, potentially affecting 12 households, or 30 persons (per latest census data). Based on the nature of the release, Reichhold recommends a shelter in place approach to protect from the potential toxic effects of TDI. Shelter in place involves closing all windows, turning off ventilation fans, closing fireplace flues, and remaining indoors until advised it is safe to exit. Sheltering in place is safer than evacuating in the open air while the release is occurring. Further guidance on sheltering in place is available through the CMA shelter in place guidelines available from Reichhold. General Accidental Release Prevention Program To help Reichhold Chemicals, Inc. achieve its EHS goals, this site is dedicated to continuous improvement of its comprehensive environmental, health, and safety program, which includes compliance with the Occupational Safety and Health Administrations (OSHA) Process Safety Management regulation (29 CFR 1910.119). Employees at this facility are highly trained, knowledgeable, and skilled, which results in a workforce that is very capable in their job performance. These employees are then supported with numerous sources of information about: 1. Their Job - Operating Procedures, Emergency Procedures, and Safe Work Practices 2. The chemicals they use - Material Safety Data Sheets, Exposure Limits and Exposure Prevention, and Process Chemistry 3. The processes which they operate - Equipment Design and Construction Information, Safe Operating Limits, and the Consequences and Correction of Process Upsets. The quality of both our employees and the supporting information, along with active involvement of the employees at all levels of the organization, all come together to provide a strong foundation for the Environmental, Health, and Safety programs for this facility. Traditional programs such as Hot Work, Confined Space, Lockout/Tagout, and Line Break benefit from the high level of employee involvement; however, these resources and the involvement of our employees are critical for programs such as Process Hazard An alysis, Management of Change, Incident Investigation, and Emergency Response. It is through these programs that the potential hazards of the process are identified, corrected, reviewed, and/or mitigated. Two additional programs that strengthen our Environmental, Health, and Safety programs are our Contractor Management and Mechanical Integrity efforts. The contractor program is simple and direct. Contractors and their employees will be treated as though they are our own employees while performing work at our site. They will be trained on our processes and procedures, they will be expected to follow our programs and procedures, they will participate as necessary, and they will be held to the same standards of performance as we hold our own employees. The mechanical integrity program for this facility involves the regular testing and inspection of equipment used within our hazardous processes. Equipment is expected to be purchased, installed, and maintained in accordance with appl icable codes and standards, manufacturers recommendations, and generally accepted good engineering practices. Equipment found that does not meet these requirements will be repaired, replaced, or removed from service. These same principles will be applied to spare parts and maintenance activities. Lastly, in an effort to continuously improve upon these programs, regular audits are done to determine the facilitys 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 This facility has a good safety record. All incidents with the potential to cause any injury or damage are investigated. The regulations require the reporting of events involving regulated substances that result in deaths, injuries or significant property damage on sit e or known deaths, injuries, evacuations, sheltering-in-place, property damage or environmental damage off site. There have been no releases in the last five years that require reporting under the RMP program. Emergency Response Program The site has a comprehensive emergency response plan that is coordinated with local emergency response organizations. A procedure has been developed for responding to requests for information from outside agencies. Facility tours are provided for first responders such as the local Fire Department and HAZMAT unit, police and medical personnel. Transportation of hazardous materials (inbound raw materials as well as outbound finished products) within the local area is included in planning activities. The Emergency Response Plan considers chemical distribution safety and emergency response capabilities of local agencies by utilizing TRANSCAER., state, and regional networks. The emergency response plan is reviewed annually and updated as needed. Planned Changes to Improve Safety Reichhold Chemicals constantly strives to improve the safety of its processes through its incident investigation program, solicitation of safety suggestions from its workers and the community advisory panel. This site has a plan to improve the overall safety of the site that includes: 1. Installing new, additional relief recovery tanks to capture the emergency releases from process tanks. 2. Implementing high-level shutdown devices on all of its hazardous material storage tanks. 3. Installing automated control and process monitoring systems. |