Plant 200 - Executive Summary
RJR Packaging Plant 200 is a production facility that includes a secondary aluminum processing operation. This process consists of remelt furnaces, annealing ovens and rolling mills. Aluminum ingots and internally recycled metals are introduced into the remelt furnaces where the aluminum is melted and alloyed. In this process, chlorine is used as a fluxing agent to remove impurities in order to produce the highest quality aluminum sheet. The aluminum process operates under the NAICS code 331315 (Aluminum Sheet Plate and Foil Manufacturing) and has a maximum of four (4) 1-ton liquified chlorine storage tanks connected to the fluxing process (only two of which are on-line at any one time). There is adjacent storage used for staging of full and empty tanks that can hold a maximum of four (1-ton) tanks giving a theoretical maximum of eight (8) 1-ton chlorine storage tanks on site. |
R. J. Reynolds Tobacco Company (RJRT) facilities operate strictly adhering to regulations pertaining to
environmental, community, and worker protection. Environmental and safety issues are specifically addressed with employees through company publications, intranet, training classes and the Job Safety and Health Analysis (JSHA) system which lists all safety and health impacts for each job. All safety and environmental incidents are reported and handled in accordance with applicable regulations as well as company-specific policies and procedures. Audits are conducted at major facilities to ensure compliance with applicable regulations and good manufacturing practices.
RJRT has emergency response (ER) and evacuation procedures in place at each facility and designated employees at each location trained to respond to any emergency. This highly-trained ER team consists of site managers and staff to provide the most effective mitigation efforts. All ER employees receive 80 hours of OSHA-required training. RJR employees received over 19,000 training experiences in 1998 in one of the 74
compliance training subjects offered by the company. The Emergency Services Department operates 24 hours a day, 7 days a week and 365 days each year.
In 1998, there were 35 environmental inspections with no findings of non-compliance. RJR's Chemical Management Computer System makes available information to emergency responders and local fire departments on a real-time basis regarding identities, quantities and locations of hazardous chemicals in all company facilities. In 1998, an RJR facility became the first site in Forsyth County to attain Carolina Star certification by the NC Dept. of Labor. This certification recognizes superior workplace safety practices and has only been achieved by 17 sites statewide.
The worst-case release scenario is failure of a chlorine cylinder containing 2000 pounds of chlorine resulting in the release of the entire contents into the atmosphere. Since this facility is located in a populated area, the toxic cloud formed by the vaporizing chlorine wo
uld reach offsite endpoints and nearby public receptors within a 1.3 mile radius of the chlorine storage cylinders.
The alternative release scenario selected was one which used the worst-case event but instead used more typical weather conditions. This was selected because it was the only alternative scenario which resulted in an offsite impact (as required by the regulation). In this scenario the toxic endpoint extended to a 0.3 mile radius surrounding the storage tank.
The most likely alternative release scenario based on maintenance records from similar processes is a check valve failure. In this scenario, a maximum quantity of 100 pounds of chlorine would be released to the atmosphere. The assumption here is that the release goes undetected for a 5 minute duration thus producing a toxic cloud with 700-foot radius. Even in this most extreme circumstance, the model does not indicate a toxic endpoint offsite. However, such a release would trigger in-plant Emergency Response pr
ocedures which include notifying local response agencies of the occurence. It is worth noting that an undetected release for a duration of 5 minutes is extremely remote due to 24-hour ADT (fire/security contractor) monitoring of the chlorine vapor leak detection panel.
This Packaging facility received a 1998 Safety Award from NC Dept. of Labor. This award is presented to facilities that are 50% below the state average incidence rate for their industry with no fatalities. In addition, RJRP has implemented a Safety "CHAMPS" program which involves employees performing safety observations on their co-workers. This program promotes employee involvement and provides feedback to employees regarding their safety practices.