Reichhold Inc. - Executive Summary

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Risk Management Plan: Discussion Draft 
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. Should an accidental release of a hazardous material occur, despite these measures, 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 Sub 
Reichhold Seneca Site 
Reichhold Inc. operates approximately 25 facilities in North America.  These facilities produce a wide variety of polymers and resins found in many household items.  The Seneca Site produces various materials found in latex paints, adhesives for cardboard and carpets, low VOC coatings for wood & vinyl, joint compound, and other common items.  A variety of chemicals are used to manufacture these products.  Two of these chemicals are subject to the RMP regulation: vinyl acetate monomer and ethylene.   
The first regulated substance is a  toxic chemical - vinyl acetate monomer (VA). The maximum quantity of vinyl acetate monomer stored on site is 466,000 pounds (59,000 gallons).  Typically only 200,000 pounds (25,000 gallons) or less of vinyl acetate monomer is stored on site at any given time. 
The second regulated substance is a flammable chemical - ethylene. Reichhold stores ethylene on site in a rail car. A railcar contains 205,000 pounds of ethylene.  Re 
ichhold also has one ethylene storage tank on site that will hold a maximum of 94,000 pounds (20,000 gallons) of ethylene.  The ethylene rail car is located within a specially designed unloading area.  The unloading area contains a deluge system and continuous temperature and combustion monitors. 
Offsite Consequence Analysis 
Reichhold Seneca utilized RMP*Comp to calculate the following offsite consequence analyzes and Landview to estimate population densities:  
Vinyl Acetate: 
Vinyl acetate monomer is stored in a single storage tank. The storage tank contains 59,000 gallons (446,000 pounds).  The working storage volume for the tank is approximately 25,000 gallons (200,000 pounds).  The tank is located within a concrete secondary containment area, which is capable of containing 110% of the volume of the VA tanks.  
Worst Case Scenario 
The worst case scenario would be the catastrophic failure of the VA storage tank releasing 466,000 pounds of VA into the secondary containment.  The of 
fsite impact area associated with this scenario 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 19,200 gallons (190,000 pounds).  The VA is transferred from the railcar to the storage tank with a centrifugal pump through a 3" pipeline.  
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 crosses both the unloading drainage area and lies within the storage tank secondary containment area. 
The VA is transferred from the storage tanks to the process building by a gear 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 and tim 
es 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 the transfer of VA from a railcar to the storage tank, on the discharge side of the unloading pump. The unloading pump transfers VA at a rate of approximately 1,300 lbs./minute.  An operator is in the immediate area during the unloading process.  It was estimated that it would take the operator 5 minutes to notice the release and shut down the unloading pump and associated valves.  Therefore, approximately 7,500 lbs. of VA would be released into the secondary containment or the spill basin.  The off-site impact area would be 0.5 miles downwind. 
Ethylene is stored on-site in a 205,000 pound railcar. The railcar and tank truck unloading area contains a deluge system, and continuous temperature and combustible monitors.  Railcars and tanks trucks ar 
e off-loaded into an ethylene storage tank.  The ethylene storage tank capacity is 94,000 lbs. A railcar contains 205,000 pounds of ethylene and a truck contains 40,000 pounds.  Ethylene is vaporized from the storage tank into a high-pressure storage tank then into the process area. 
Worst Case Scenario 
If a full railcar fails, 205,000 pounds of ethylene would be released into the atmosphere.  The impact area would be 0.5 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 ethylene.  The facility receives ethylene by railcar and tank truck. The ethylene is transferred from the railcar or tank truck to the storage tank with a centrifugal pump. 
The ethylene is vaporized from the ethylene low-pressure storage tanks to the high-pressure storage tank.  The ethylene is transferred from the high-pressure storage tank to process building by a pressure differential.   A d 
igital control system (DCS) controls the feed valves that control the transfer of ethylene to the process area.  The DCS continuously monitors the vessel pressure. If the pressure raises over a set amount, the DCS will shut all valves and the transfer will cease. 
Alternative Case #1 - Failure of the unloading line during railcar to low pressure storage tank transfer, on the discharge side of pump.  The ethylene is transfer at a rate of approximately 800 lbs./minute.  An operator in the immediate area during the unloading process.  It was estimated that it would take the operator 5 minutes to notice the release and shut down the unloading pump and associated valves.  Therefore, approximately 4,000 lbs. of ethylene would be released into the atmosphere.  The off-impact area would be 0.09 miles downwind. 
General Accidental Release Prevention Program 
To help Reichhold Inc. achieve its Environmental Health & Safety (EH&S) goals, the Seneca 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 Seneca 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. 
The training of Reichhold employees, the supporting information available, and the active involvement of the employe 
es at all levels of the organization, combined 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, 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 Seneca 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 Seneca site.  They are trained on our processes and procedures, expected to follow our programs and procedures, participate as necessary, and 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 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 need to be implemented to ensure compliance with the intent and requirements of Reichhold's EH&S program. 
Five Year Accident History 
e Seneca Site has a good safety record.  The employees have not experienced a recordable or lost time injury in over 7 years.  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 Seneca 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.  Facility tours are provided for first responders and the local HAZMAT unit of Seneca Fire Department, police (Grundy County She 
riff), emergency medical (clinic or hospital -- day and night staff), and ambulance service. The Seneca Site has established a mutual network with local business neighbors for planning, communication, and sharing of information. 
Transportation of hazardous materials for inbound raw materials within the local area is included in planning activities (the Seneca Plant does not ship any hazardous products).  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. Considering the installation of more combustion devices. 
2. Implementing high-level shutdown devices on all of its hazardous material storage tanks.   
3. Considering the installation of fire-safe valves. 
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. Digital process control up-grades to existing process equipment.
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