Reichhold, Inc. - Executive Summary |
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Executive Summary As a participating member of the Chemical Manufacturers Association (CMA), Reichhold, Inc., is committed to the Responsible Care . program and to operating our facilities in a manner that is safe for our employees, the community and the environment. Reichhold has established a Risk Management Program (RMP) that helps the company to identify and communicate risks associated with our operations. Reichhold has established 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 Reichhold operates 27 facilities in North America. The Cheswold facility is a quality p roducer of latex emulsions including styrene-butadiene rubber latex, acrylonitrile-butadiene latex and polyvinyl acetate emulsion. Our products are used in a wide variety of applications including the production of carpet, nitrile rubber gloves, paper coatings and latex paint. We use several chemicals to manufacture these products. Three of these chemicals are subject to the RMP regulation. The three chemicals are 1,3-butadiene, acrylonitrile and vinyl acetate. Butadiene is a colorless gas at room temperature with a mild aromatic odor. It is used in the production of both styrene-butadiene rubber latex and acrylonitrile-butadiene latex. Acrylonitrile is a clear colorless liquid with a faintly pungent odor. It is used primarily in the production of acrylonitrile-butadiene latex. Vinyl acetate is a clear colorless liquid with a faintly ether-like odor. It is used in the production of polyvinyl acetate latex. Although Reichhold has on-site a 35% formaldehyde solution, the MSD S lists the partial pressure of formaldehyde in the solution as 3.4 mm Hg. The RMP rule does not cover solutions when the partial pressure of the chemical in the solution is less than 10 mm Hg. Offsite Consequence Analysis The worst case flammable release involves butadiene. The scenario is the failure of the largest tank releasing 155,100 pounds of butadiene in 10 minutes. The distance of concern is 0.43 miles. The alternate flammable release is a charge line rupture resulting in a release of 3600 pounds of butadiene. The distance of concern is 0.05 miles. The worst case toxic release involves acrylonitrile. The scenario is the rupture of the largest tank resulting in a release of 100,800 pounds of acrylonitrile in 10 minutes. The distance of concern is 2.2 miles. The alternate toxic release for acrylonitrile is a charge line rupture resulting in the release of 8,868 pounds of acrylonitrile. The distance of concern is 0.53 miles. The alternate toxic release for vinyl ace tate involves the rupture of a charge line resulting in the release of 17,040 pounds of vinyl acetate. The distance of concern is 0.10 miles. General Accidental Release Prevention Program To help Reichhold achieve its EHS goals, Cheswold is dedicated to continuous improvement of its comprehensive environmental, health, and safety program, which includes compliance with the Occupational Safety and Health Administration's (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 In formation, 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. These resources and the involvement of our employees are critical for programs such as Process Hazard Analysis, 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. An additional program that strengthens our Environmental, Health, and Safety programs is our Mechanical Integrity efforts. The mechanical integrity program for this facility involves the reg ular testing and inspection of equipment used within our hazardous processes. Equipment is purchased, installed, and maintained in accordance with applicable codes and standards, manufacturer's 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 facility's 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 insure that we are meeting the intent and requirements of our environmental, health, and safety programs. Five Year Accident History This facility strives to maintain an excellent safety record. All incidents with the potential to cause any injury or damage are investigated. The RMP regulation requires the reporting of events involving regulated substances that result in deaths, injuries or significant property damage on site or known deaths, injuries, evacuations, sheltering-in-place, property damage or environmental damage off site over the last five years. There have been no releases in the last five years that require reporting under the RMP program. Emergency Response Program Cheswold 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, primarily the fire department. 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 capab ilities of local agencies by utilizing TRANSCARE., state, and regional networks. The emergency response plan is reviewed annually and updated as needed. Planned Changes to Improve Safety Reichhold constantly strives to improve the safety of its processes through its incident investigation program, solicitation of safety suggestions from its workers and the community. Cheswold has short and long range plans to improve the overall safety of the site that includes: 1. Implementing high level shutdown devices on all of its hazardous material storage tanks. 2. Providing dikes for all hazardous material tanks over 500 gallons. 3. Installing detectors near all organic hazardous material tanks over 500 gallons. 4. Evaluating the installation of relief recovery tanks to capture the emergency releases from storage and process tanks that currently would go to the atmosphere. |