Hercules Incorporated - Milwaukee Plant - Executive Summary |
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HERCULES INCORPORATED - MILWAUKEE PLANT RMP EXECUTUVE SUMMARY Hercules Incorporated is a member of the Chemical Manufactures Association and is committed to the principles of Responsible Care. The Corporate Policy on Safety, Health, and Environment states: "At Hercules, we manufacture chemical specialty products. We do so with full commitment to the chemical industry's Responsible Care initiative. In keeping with this commitment, we are dedicated to providing a safe and healthful environment for our employees, customers, and communities. To do this, we are dedicated to and working toward continuous improvement in our operations to prevent pollution; to reduce risk; and to enhance safety, health, and environmental performance. By incorporating these beliefs and attitudes into the way we do things at Hercules, we take a key step forward in minimizing the environmental impact of our operations, satisfying customer needs, and creating shareholder value. We will adhere to the foll owing basic principles in managing our business worldwide: -We will comply with the letter and spirit of all applicable safety, health, and environmental laws, regulations, and corporate guidelines. -We will define strategic objectives, develop tactical plans, identify clear accountability, provide necessary resources, and measure our progress on safety, health, and environmental matters on an ongoing basis. Our planning will consider both business goals and significant safety, health, and environmental aspects of our products and operations. -We will evaluate the safety, health, and environmental impacts of new and existing products and operations and will work to reduce the adverse impacts. -We will provide an open dialogue on safety, health, and environmental issues relating to our products and operations with our stake holders, including shareholders, employees, customers, suppliers, government agencies, and communties. -We will work to continually reduce workplace injuries; incidents with the potential for causing property damage, material loss, or interruption of our business; waste; and releases to the environment. -We will emphasize product stewardship and advocate its importance to our suppliers, distributors, and customers. -Every Hercules employee, worldwide, has a role to play. All of us are responsible and accountable for adhering to the letter and spirit of this policy. Alll of us must incorporate safety, health, and environmental considerations into our daily buismess activities. It takes a total team effort to truly be a Responsible Care company." FACILITY DESCRIPTION: The primary activity at the Milwaukee Plant is the manufacture of chemical additives used in the pulp and paper industry. For example, epichlorohydrin is used in the production of wet-strength resin. These resins are used in paper towels, napkins, tissues, etc. so that they will not come apart easily when wet. Epichlorohydrin is a raw material for the process and is con sumed in a chemical reaction to make the product. The plant receives epichlorohydrin in tank trucks and railroad tank cars and stores the material in a storage tank. The storage tank is provided with a containment dike and leak detectors to minimize adverse impacts from any leaks for spills. WORST-CASE SCENARIO: The worst-case scenario for epichlorohydrin is the failure of an entire railcar of epichlorohydrin. This scenario would result in off-site impact, but it requires the extemely unlikely event of a catastrophic failure of the railcar. The railcar is unloaded from the top, which means that an unloading hose failure can not cause the release of the entire car. ALTERNATIVE CARE SCENARIO: The alternative case scenario for epichlorohydrin is a leak in a line downstream of the pump and outside of containment. The impact from this scenario would result in an off-site impact, but would be limited by the fact that plant personnel are present during this process. Operaitng proc edures and process monitors will limit the duration of leakage. ACCIDENT PREVENTION PROGRAM: The process is subject to the OSHA Process Safety Management standard (29CFR 1910.119) and has a complete process safety management systems im place. This includes the use of process hazards analysis to identify and address potential hazards, management of change procedures to control modifications, mechanically integrity procedures for minimizing mechanical failiures, detailed operating procedures for process control, and operator training for personnel involved in the process. FIVE-YEAR ACCIDENT HISTORY: Two OSHA injuries have occurred in the last 5 years due to epichlorohydrin. Both were the result of burns due to employees contacting the material. One event occurred within a builiding and the other was a small amount leaking onto an employees boot during the unloading process. Corrective actions to prevent such injuries have been implemented. EMERGENCY RESPONSE PROGRAM: The Milwau kee Plant has a written emergency response plan and coordinates emergency response matters with the local fire department. The plant has provided emergency response training for all plant employees and has a trained emergency response team. PLANT IMPROVEMENTS: The Milwaukee Plant has a major capital project underway that will provide 100% containment of the liquid contents of a rail car or a tank truck spill on-site. It is expected that this project will be completed in early 2000. |