Duron Paint and Wallcoverings - Executive Summary |
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The Duron Paint and Wallcoverings facility in Atlanta, Georgia is a paint manufacturing and storage facility. The facility is regulated under RMP due to onsite flammable substance storage being in excess of the 10,000 lb. flammability RMP applicability threshold in a single process. The facility's only RMP covered process is the storage of aerosol paint canisters, and propane canisters for use on the facilities lift trucks. The covered process consists of one storage area with the maximum total capacity of 16,000 pounds for all stored canisters. Chemical Safety Overview: The facility's overall approach and commitment to chemical safety is demonstrated by the existing management, training, procedure and maintenance systems already in place at the facility. Release Scenario's: A worst-case release scenario assessment was conducted for the facility's single largest vessel based on US EPA's Offsite Consequences Analysis guidance. The vapor cloud explosion scenario was considered for the release, and since the impact zone is contained entirely within the facility's controlled site, no public receptors were determined to be located within the impact zone. The resulting worst-case impact zone is 0.02 miles. Prevention Plan: The facility was determined to qualify as Program 1 status, therefore no direct prevention plan is required under RMP guidelines. The facility does operate under air and water permits, including POTW and stormwater discharge permits, and follows OSHA safety standards. All employees are required to undergo training to inform them of the safety standards maintained onsite. Five-Year Accident History: The facility has had no RMP reportable accidents/releases of propane within the five years proceeding RMP submittal. Emergency Response Program: The facility has coordinated response with the Department of Public Safety Fire Service to ensure that they will respond to any accidental release from the covered process. The facility has also esta blished a notification mechanism to ensure the Fire Department will be properly notified when any response is needed for a propane release. Based on this coordination with the local emergency responders, the facility is not required to implement additional RMP emergency response program requirements. Safety Management and Changes: The facility is committed to ensuring its operations are safe and in accordance with all RMP requirements, and has established a senior manager responsible for RMP development, implementation and compliance. This manager is committed to maintain the safety of the RMP covered system through active adherence to the appropriate procedures and codes. To ensure that the appropriate changes occur as necessary to maintain/improve safety, ongoing hazard reviews, training, audits, maintenance and investigations will be conducted as required by RMP. Updates to the RMP will be completed as necessary in response to these activities. Summary: As documented in this submittal, the RMP for the facility has been completed in accordance with all 40 CFR 68 requirements and the facility has certified RMP compliance. |