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 its 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. Reichhold has 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 Morris Site Re ichhold Inc. operates approximately 25 facilities in North America. These facilities produce a variety of polymers and resins found in many household items. The Morris Site produces various materials found in latex paints, cultured marble tops, adhesives, automotive coatings, low VOC coatings for wood, vinyl and leather and other common items. A variety of chemicals is used to manufacture these products. Two of these chemicals are subject to the RMP regulation: vinyl acetate monomer & toluene di-isocyanate. The first regulated substance is a toxic chemical - vinyl acetate monomer (VA). VA is used in the Emulsion process, which produces emulsions and coatings that are used in products like: latex paint; and industrial glue used in the furniture, paper, and cardboard industries. The maximum quantity of vinyl acetate monomer stored on site is 500,000 pounds (64,000 gallons). Typically, only 450,000 pounds (48,000 gallons) or less of vinyl acetate monomer is stored on site at any one time. The second regulated substance is also a toxic chemical - toluene di-isocyanate, commonly referred to as TDI. TDI is used in the Spensol Process, which produces a variety of low VOC coatings. These coatings are used in the floor covering and automotive industries. Reichhold has one storage tank that will hold a maximum of 87,000 pounds (8,500 gallon) of TDI. The TDI storage tank is located inside a specially designed storage room within the production building. In addition to the materials subject to the RMP regulation, Reichhold uses several other chemicals. A separate document will be available detailing a realistic release scenario for those chemicals stored in bulk that are not listed in the RMP regulations. Offsite Consequence Analysis Reichhold - Morris used EPA's RMP*Comp model to calculate the following offsite consequence analyzes and Landview III to estimate the population density. Vinyl Acetate: Vinyl acetate monomer is stored in two (2) storage tanks that are inter-connected. Each storage tank contains 32,000 gallons (315,000 pounds). The working storage volume for each tank is approximately 30,000 gallons (295,770). Both tanks are located within a concrete secondary containment area, which is capable of containing 136% of the volume of both VA tanks. Worst Case Scenario Since the two tanks are interconnected, if one of the tanks failed, the contents of both tanks would be released into the secondary containment area. Therefore, the worse case scenario would be a release of 64,000 gallons (approximately 600,000 pounds) of VA into the secondary containment area. The offsite impact area would be 1.4 miles downwind Alternative Case Scenarios There were many alternative case scenarios discussed most of the creditable scenarios centered on the transfer and storage of the VA. The facility receives VA by railcar and tank truck. A VA railcar contains approximately19,200 gallons (190,000 pounds). The VA is transferred from the ra ilcar to the storage tanks with a positive displacement pump through a 3" pipeline. Both storage tanks are filled simultaneously through a common header. The railcar and tank truck unloading area drains to a concrete spill containment basin. The basin can retain the volume equal to two (2) railcars. The transfer piping crossed both the unloading drainage area and within the storage tank secondary containment area. The VA is transferred from the storage tanks to the process building by a positive displacement pump. A digital control system (DCS) controls the pump that transfers the amount of VA pumped from the storage tank to the process vessels. The DCS continuously compares pump rates & times, with vessel weights. If the pre-set conditions are not constantly met, then an alarm activates, and interlocks will close supply valves and shut down the transfer pump. Alternative Case #1 - Failure of the unloading line during railcar to storage tank transfer on Discharge side of pump. The pump transfers VA at a rate of approximately 1,500 lbs./minute. There is an operator in the immediately area during the unloading process. It was estimated that it would take the operator 5 minutes to notice the release and shut down the transfer pump and close the associated valves. Therefore, approximately 7,500 lbs. of VA will be release into the storage tank secondary containment area or to the concrete spill basin. The off- impact area associated with this scenario would be 0.4 miles downwind. Toluene Di-isocyanate Toluene Di-isocyanate (TDI) is stored in a storage tank inside a processing building. The storage tank contains 8,500 gallons (87,000 pounds). The working storage volume for each tank is approximately 8,000 gallons (81,820 pounds). The storage tank is located within a concrete secondary containment area inside the storage building. The containment area is capable of containing 200% of the volume of the TDI tank. Worst Case Scenario The worst case scenar io for TDI would be the failure of the storage tank releasing 8000 gallons (81,820 pounds) of TDI into the secondary containment area. The impact area associated with this scenario would be 0.6 miles downwind Alternative Case Scenarios There were many alternative case scenarios discussed most of the creditable scenarios centered on the transfer and storage of the TDI. The facility receives TDI by tank truck. A TDI tank truck contains 4,500 gallons (46,000 pounds). The TDI is transferred from the tank truck to the storage tanks by pressuring the tank truck to 14 psig with nitrogen. The TDI is displaced from the tank truck to the storage tank through a dedicated 3" pipeline. The tank truck unloading area is a contained area. The area can retain the volume equal to three (3) tank trucks. The transfer piping runs inside the process building, which is all contained. The TDI is transferred from the storage tanks to the process area by a positive displacement pump. A digital contr ol system (DCS) controls the pump that transfers the amount of TDI pumped from the storage tank to the process vessels. The DCS continuously compares pump rates & times, with vessel weights. If the pre-set conditions are not constantly met, then an alarm activates, and interlocks will close supply valves and shut down the transfer pump. Alternative Case #1 - Failure of the unloading line during a tank truck to storage tank transfer. The transfer rate during unloading is approximately 1,000 lbs./minute. There is an operator in the immediately area during the unloading process. It was estimated that it would take the operator less than 5 minutes to notice the release, shut down the nitrogen line, and close the associated valves. Therefore, approximately 5,000 lbs. of TDI will be release into the unloading area secondary containment. The off- impact area associated with this scenario would be 0.1 miles downwind. General Accidental Release Prevention Program To help Reichhold Inc . achieve its Environmental Health & Safety (EH&S) goals, the Morris Site 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 the Morris 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. Job Duties - with standard operating procedures, emergency procedures, and safe work practices 2. Chemicals used in the process - with annual review of Material Safety Data Sheets, exposure limits and exposure prevention, and the chemistry behind the manufacturing process 3. Operation of the process - with equipment design and construction information, safe operating limits, and the consequences and correction of process upsets. T he training of Reichhold employees, the supporting information available, and active involvement of the employees at all levels of the organization, all come together to provide a strong foundation for the EH&S programs for this facility. Traditional Process Safety Management (PSM) programs such as Hot Work, Confined Space, Lockout/Tagout, Management of Change, Process Hazardous Analysis, Incident Investigation and Emergency Response, Mechanical Integrity and Line Break Permitting also benefit from the high level of employee involvement. It is through these programs that the potential hazards of the process are identified, corrected, reviewed, and/or mitigated. In addition to the PSM programs, Reichhold's Contractor Safety & Management programs also the Morris facility achieve its EH&S goals. The contractor program is simple and direct. Contractors and their employees are treated as though they are Reichhold employees while performing work at the Morris site. Contractors are trai ned on Reichhold processes and procedures, expected to participate as necessary in incident investigations, and be held to the same standards of performance as Reichhold holds it's 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 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 additional training needs to be implemented. These audits also help to ensure compliance with the intent and requirements of Reichhold's EH&S program. Five Year Accident History The Morris Site 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 site 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 Morris Site has a comprehensive emergency response plan, which is coordinated with the Grundy County Local Emergency Planning Commission and surrounding Fire Departments. A procedure has been developed for responding to requests for information from outside agencies and the public. Facility tours are provided for first responders and the local HAZMAT unit of Coal City Fire Department, police (Grundy County Sheriff), emergency medical (clinic or hospital -- day and night staff), and ambulance service. The Morris Site has established a mutual network with local business neighbors for planning, communications, and sharing of information. 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 CHEMNET, 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, ideas from outside contractors and Reichhold's Corporate EH&S support staff. This site has overall safety devices and plans for the site that includes: 1. Installing high-level shutdown devices on all hazardous material storage tanks. 2. Providing dikes for all hazardous material tanks over 500 gallons. This site has a long range plan to improve the overall safety of the site that includes: 1. Constantly striving to reduce the storage volume of the most hazardous materials. 2. Installing relief recovery tanks to capture the emergency releases from storage and process tanks that currently would go to the atmosphere |