| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

                                        ROHM AND HAAS KANKAKEE PLANT 
                                            RISK MANAGEMENT PLAN 
                                              EXECUTIVE SUMMARY 
Accidental Release Prevention And Emergency Response Policies: 
The Kankakee Polymer Plant is committed to the protection of its employees, neighbors, and the community. This objective will never be compromised and is the most basic obligation of all personnel at the plant. In fulfilling this commitment, we ensure that all Corporate Environmental, Health and Safety Policies and Principles are strictly followed.  
Collectively we have the responsibility to provide a positive impact on the Kankakee Community. This is accomplished by the elimination of hazardous exposures, injuries, fires, environmental releases, or damage to property. We are firmly committed to the protection of the health and welfare of our employees and the surrounding community. This objective will be accomplished by us 
ing a hierarchy of controls, which emphasize engineering controls followed by administrative controls and personal protective equipment. 
The plants emergency response plan is based upon a combination of governmental and company requirements. Local response capabilities have been reviewed to ensure a coordinated response with all appropriate agencies. The emergency response plan includes procedures for the notification of the local fire and police departments, governmental agencies, as well as any potentially affected neighbors. 
Kankakee Facility and Regulated Substance Handled: 
7 The primary purpose of the Rohm and Haas Kankakee Plant is to produce emulsions.  One of the raw materials used for the production of these emulsions is Vinyl Acetate, which is regulated under the EPA RMP Rule.  The finished product leaving the plant contains very low concentrations of this chemical, such that they no longer present a toxicity hazard. 
7 Vinyl Acetate is transported to the plant in both  
railcar and truck, the primary source of supply being railcar. Once received in the plant, the material is stored onsite in a 150,000 gallon above-ground  storage tank. The unloading and manufacturing systems have all the necessary equipment for the safe unloading of railcars into the storage tanks. 
7 Access to the Rohm and Haas Kankakee Plant is restricted to authorized employees, and authorized contractors.  All persons seeking to enter the plant are required to undergo training in the plant safety rules before they are allowed entry. 
Worst-Case And Alternative Release Scenarios:  
7 Worst case scenario - The catastrophic rupture (failure) of the Vinyl Acetate storage tank when it is filled to the maximum allowed level.  Although the capacity of the storage tank is 150,000 gallons, plant policy limits the maximum level of the tank to  143,500 gallons. The worst case scenario assumes the simultaneous release of a full tank, or 143,500 gallons at the same time all safety systems fai 
l.  The case does assume that the entire tank contents are released to form a liquid pool within a dike surrounding the tank.  The distance to the toxic endpoint does result in off site impacts.  
7 Alternative release scenario - Vinyl Acetate tank overfill resulting in the release of 1,123 gallons of material.  For this scenario to occur, several automated safety systems must fail to allow the pump to overflow the tank. In addition, the operator must violate several written plant procedures, which include inventory management and attended unloading. Once detected, the pump would be immediately stopped. The distance to the toxic endpoint does result in off-site impacts, but does not affect any residential areas.   
General Accidental Release Prevention Program And Chemical-Specific Prevention Steps: 
The Rohm and Haas Kankakee Plant complies with both the OSHA PSM, and the EPA RMP Rules, as well as with all applicable governmental codes and regulations.  Included in the Kankakee Plant 
s accidental release prevention plans are fully automated processes with level and flow measurement and control, minimum inventories of chemicals,  automatic emergency shut-off valves, redundant safety interlocks, preventative maintenance programs, chemical detectors, remotely operated valves to isolate and minimize a release, and annual training of employees. A comprehensive training and testing program has been developed for all plant employees to ensure that all equipment is  operated in a safe and efficient manner. 
Included in the Kankakee Plants emergency response program are fully trained incipient fire responders, fully trained Technician level HAZMAT responders, fully trained Industrial Medical Responders, fully trained Incident Commanders, onsite fire and spill response foam capability, onsite HAZMAT response equipment, fixed water spray fire protection systems, strategically located chemical sensors, onsite fire water containment basis(s), plant notification systems includ 
ing alarms ,phones, and radios, and neighbor/community notification procedures.  This personnel and equipment is maintained ready for use throughout all plant operations. 
Five-Year Accident History: 
During the past five years, we have had no releases of Vinyl Acetate with off site consequences.  
Emergency Response Program: 
The Rohm and Haas Kankakee Plant has an emergency response plan that has been coordinated with the community plan. The plan includes procedures for public notification of emergencies that may affect the surrounding community.  Our responders have participated in training and drills with the local fire department. Site HAZMAT plans are also coordinated with a private outside contractor. The site emergency response plan has been designed to meet the requirements of all relevant regulations requiring emergency response plans.  The plan is intended to prevent hazardous material spills, protect the health and well-being of Rohm and Haas employees and neighbors, pr 
otect the assets Rohm and Haas and its neighbors, protect the environment, and serve as a reference to responders in the event of an emergency. 
Planned Changes To Improve Safety: 
The Rohm and Haas Kankakee Plant has conducted risk analysis studies on all processes  handling Vinyl Acetate.  As a result of these studies, we have identified a number of ways we can improve our processes to make them safer.  We are in the process of implementing the recommendations from the most recent studies.  We will continue to review our processes periodically to identify further means of improvement.
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