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Pearl River Polymers, Inc.

Parent Companies:
SNF Holding Company
EPA Facility ID:
100000077338
Other ID:
70452CHMLNI59NO
Facility DUNS:
69022522
Parent Company DUNS:
45496160

Location:

Address:
I-59 North, Exit 5A
Pearl River, LA 70452
County:
ST. TAMMANY
Lat / Long:
30.378, -89.741 (Get map)
Method:
Interpolation - Map
Description:
Center of Facility
Horizonal accuracy:
m
Horizontal reference datum:
Source map scale:

Owner/Operator:

Name:
Pearl River Polymers, Inc.
Phone:
(504) 863-5703
Address:
P.O. Box 1659
Pearl River, LA 70452
Foreign Address:

Person responsible for RMP implementation:

Name:
Richard Rosenkoetter
Title:
Plant Manager
Email:

Emergency contact:

Name:
Jay Richard
Title:
Quality & Regulatory Compliance Mgr
Phone:
(504) 863-5703
24-hour phone:
(504) 863-5703
Ext or PIN:
Email:

Other contacts:

Facility (or company) email:
Facility phone:
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
St. Tammany Parish LEPC
Full-Time Equivalent Employees:
55
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
July 17, 1998
Inspecting Agency:
State occupational safety agency
Using Predictive Filing:
No

Processes:

Anhydrous Ammonia Stg.
RMP ID:
33549
CBI claimed:
No
Program Level:
3
NAICS:
All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
88,000
No
Public OCA Chemical
0
No
Aqueous Ammonia Stg, 30%
RMP ID:
33550
CBI claimed:
No
Program Level:
2
NAICS:
All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (conc 20% or greater)
7664-41-7
45,000
No
Public OCA Chemical
0
No
Epichlorohydrin Stg.
RMP ID:
33551
CBI claimed:
No
Program Level:
3
NAICS:
All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Chemical name
CAS#
Quantity (lbs.)
CBI
Epichlorohydrin [Oxirane, (chloromethyl)-]
106-89-8
370,000
No
Public OCA Chemical
0
No
Ethylenediamine Stg.
RMP ID:
33552
CBI claimed:
No
Program Level:
2
NAICS:
All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ethylenediamine [1,2-Ethanediamine]
107-15-3
45,000
No
Public OCA Chemical
0
No
Formaldehyde, 37% Stg.
RMP ID:
33553
CBI claimed:
No
Program Level:
3
NAICS:
All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Chemical name
CAS#
Quantity (lbs.)
CBI
Formaldehyde (solution)
50-00-0
33,000
No
Public OCA Chemical
0
No
Dimethylamine Stg.
RMP ID:
33554
CBI claimed:
No
Program Level:
3
NAICS:
All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Chemical name
CAS#
Quantity (lbs.)
CBI
Dimethylamine [Methanamine, N-methyl-]
124-40-3
380,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
May 25, 2001
Type:
Resubmission
Reason:
Registered:
No
RMP ID:
23540

Deregistration:

Date:
Effective Date:
Reason:
Source terminated operations
Other Reason:

2. Toxics: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Anhydrous Ammonia Stg.)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
DEGADIS Model
Release duration (mins):
10.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Rural
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps

3. Toxics: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Anhydrous Ammonia Stg.)
CBI claimed:
No
Percent weight:
Physical state:
Gas liquified by pressure
Model used:
DEGADIS Model
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Rural
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Excess flow valve
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in Aqueous Ammonia Stg, 30%)
CBI claimed:
No
Percent weight:
30.0
Physical state:
Liquid
Model used:
EPA's OCA Guidance Reference Tables or Equations
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Rural
Passive mitigation
considered:
  • Dikes
not considered:
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in Epichlorohydrin Stg.)
CBI claimed:
No
Percent weight:
Physical state:
Liquid
Model used:
EPA's OCA Guidance Reference Tables or Equations
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Rural
Passive mitigation
considered:
  • Dikes
not considered:
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in Ethylenediamine Stg.)
CBI claimed:
No
Percent weight:
Physical state:
Liquid
Model used:
EPA's OCA Guidance Reference Tables or Equations
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Rural
Passive mitigation
considered:
  • Dikes
not considered:
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in Formaldehyde, 37% Stg.)
CBI claimed:
No
Percent weight:
37.0
Physical state:
Liquid
Model used:
EPA's OCA Guidance Reference Tables or Equations
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Rural
Passive mitigation
considered:
  • Dikes
not considered:
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown

4. Flammables: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Dimethylamine Stg.)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
Passive mitigation
considered:
  • None
not considered:
  • Blast walls

5. Flammables: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Dimethylamine Stg.)
CBI claimed:
No
Model used:
EPA's OCA Guidance Reference Tables or Equations
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Excess flow valve

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

Anhydrous Ammonia Stg., All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Prevention Program ID:
18849
Safety Review Date
April 1, 1997, since latest RMP submission
PHA Update Date
June 20, 1997, since latest RMP submission
PHA Techniques
  • What if
Hazards Identified
  • Toxic release
Process Controls
  • None
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
  • On the Job
Competency Testing
  • Observation
Procedure Review Date
July 3, 1997, since latest RMP submission
Training Review Date
Jan. 1, 1996, since latest RMP submission
Maintenance Review Date
March 1, 1998, since latest RMP submission
Maintenance Inspection Date
Jan. 1, 1999, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Aug. 5, 1998
Management of Change Review Date
Feb. 4, 1998
Pre-startup Review Date
None
Compliance Audit Date
May 1, 1997
Compliance Audit Change Completion Date
June 1, 1999
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Jan. 13, 1998
Hot Work Review Date
July 5, 1998
Contractor Safety Review Date
May 15, 1998, since latest RMP submission
Contractor Safety Eval. Date
Jan. 30, 1999, since latest RMP submission
Epichlorohydrin Stg., All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Prevention Program ID:
18850
Safety Review Date
Oct. 1, 1998, since latest RMP submission
PHA Update Date
Dec. 2, 1997, since latest RMP submission
PHA Techniques
  • What if
Hazards Identified
  • Toxic release
  • Fire
  • Overfilling
Process Controls
  • None
Mitigation Systems
  • Dikes
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
Competency Testing
  • Written Test
Procedure Review Date
Oct. 20, 1997, since latest RMP submission
Training Review Date
Feb. 1, 1998, since latest RMP submission
Maintenance Review Date
March 1, 1998, since latest RMP submission
Maintenance Inspection Date
Jan. 1, 1999, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Aug. 5, 1998
Management of Change Review Date
Feb. 4, 1998
Pre-startup Review Date
None
Compliance Audit Date
May 1, 1997
Compliance Audit Change Completion Date
June 1, 1999
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Jan. 13, 1998
Hot Work Review Date
July 5, 1998
Contractor Safety Review Date
May 15, 1998, since latest RMP submission
Contractor Safety Eval. Date
Jan. 30, 1999, since latest RMP submission
Formaldehyde, 37% Stg., All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Prevention Program ID:
18851
Safety Review Date
Nov. 1, 1998, since latest RMP submission
PHA Update Date
Feb. 1, 1998, since latest RMP submission
PHA Techniques
  • What if
Hazards Identified
  • Toxic release
  • Overfilling
  • Equipment failure
Process Controls
  • None
Mitigation Systems
  • Dikes
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • Classrom
Competency Testing
  • Written Test
Procedure Review Date
Jan. 13, 1998, since latest RMP submission
Training Review Date
Oct. 1, 1999, since latest RMP submission
Maintenance Review Date
March 1, 1998, since latest RMP submission
Maintenance Inspection Date
Jan. 1, 1998, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Aug. 5, 1998
Management of Change Review Date
Feb. 4, 1998
Pre-startup Review Date
None
Compliance Audit Date
May 1, 1997
Compliance Audit Change Completion Date
June 1, 1999
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Jan. 13, 1998
Hot Work Review Date
July 5, 1998
Contractor Safety Review Date
May 15, 1998, since latest RMP submission
Contractor Safety Eval. Date
Jan. 30, 1999, since latest RMP submission
Dimethylamine Stg., All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Prevention Program ID:
18852
Safety Review Date
Feb. 1, 1998, since latest RMP submission
PHA Update Date
Aug. 26, 1997, since latest RMP submission
PHA Techniques
  • What if
Hazards Identified
  • Toxic release
  • Fire
Process Controls
  • None
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None Recommended
Training Type
  • Classrom
Competency Testing
  • Written Test
Procedure Review Date
Jan. 13, 1998, since latest RMP submission
Training Review Date
Feb. 1, 1998, since latest RMP submission
Maintenance Review Date
March 1, 1998, since latest RMP submission
Maintenance Inspection Date
Feb. 1, 1999, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Aug. 5, 1998
Management of Change Review Date
Feb. 4, 1998
Pre-startup Review Date
None
Compliance Audit Date
May 1, 1997
Compliance Audit Change Completion Date
June 1, 1999
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Jan. 13, 1998
Hot Work Review Date
July 5, 1998
Contractor Safety Review Date
May 15, 1998, since latest RMP submission
Contractor Safety Eval. Date
Jan. 30, 1999, since latest RMP submission

8. Prevention Program level 2

Aqueous Ammonia Stg, 30%, All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Prevention Program ID:
12946
Safety Review Date
April 1, 1997, since latest RMP submission
PHA Update Date
, since latest RMP submission
Safety Regulations
  • None
Hazards Identified
  • Toxic Release
Process Controls
  • None
Mitigation Systems
  • Dikes
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • On the Job
Competency Testing
  • Observation
Procedure Review Date
June 27, 1997, since latest RMP submission
Training Review Date
Jan. 1, 1996, since latest RMP submission
Maintenance Review Date
March 1, 1998, since latest RMP submission
Maintenance Inspection Date
Jan. 1, 1998, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Management of Change Review Date
Pre-startup Review Date
Compliance Audit Date
May 1, 1997
Compliance Audit Change Completion Date
June 1, 1999
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Hot Work Review Date
Contractor Safety Review Date
, since latest RMP submission
Contractor Safety Eval. Date
, since latest RMP submission
Ethylenediamine Stg., All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Prevention Program ID:
12947
Safety Review Date
Sept. 1, 1998, since latest RMP submission
PHA Update Date
, since latest RMP submission
Safety Regulations
  • None
Hazards Identified
  • Toxic Release
  • Fire
Process Controls
  • None
Mitigation Systems
  • Dikes
Monitoring Systems
  • None
Changes since PHA
  • None Recommended
Training Type
  • On the Job
Competency Testing
  • Observation
Procedure Review Date
Jan. 1, 1998, since latest RMP submission
Training Review Date
Jan. 1, 1996, since latest RMP submission
Maintenance Review Date
March 1, 1998, since latest RMP submission
Maintenance Inspection Date
Jan. 30, 1999, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Management of Change Review Date
Pre-startup Review Date
Compliance Audit Date
June 20, 2002
Compliance Audit Change Completion Date
None
Incident Investigation Date
None
Incident Invest. Change Completion Date
None
Participation Plan Review Date
Hot Work Review Date
Contractor Safety Review Date
, since latest RMP submission
Contractor Safety Eval. Date
, since latest RMP submission

9. Emergency response

Facility In Community Plan:
No
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
Oct. 1, 1998
Local Response Agency:
Local Response Agency Phone:
(504) 863-3134
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

22297 LDEQ Facility ID Number

See attached text for Executive Summary.
EXECUTIVE SUMMARY







This Risk Management Plan (RMP) has been prepared to meet the requirements of the Risk

Management Program Rule.



As part of complying with the Risk Management Program Rule, Pearl River Polymers, Inc.

(PRP) has reviewed and enhanced previously existing accidental release procedures and

emergency response policies. These policies include: an emergency response sequence;

emergency response to fires, explosions, and environmental releases; notification and reporting

to regulatory agencies in the event of a reportable release; emergency response to hurricanes,

floods, and bomb threats; spill prevention control and countermeasure (SPCC) plan;

identification and training of an emergency response team; emergency coordinator and regulatory

call lists; emergency equipment list and location; sensitive materials storage list; material profiles

and material safety data sheets for major raw materials on site.



There are six substances at the PRP facility that are regulated by the Chemical Accident

Prevention Provisions defined at 40 CFR Part 68. These substances are used in various

processes throughout the facility to produce water treatment polymers. Specifically, the facility

produces cationic polymers, polyamine, Mannich products, melamine formaldehyde acid colloid,

and diallyl dimethyl ammonium chloride (DADMAC). Substances that are used by PRP that are

regulated as either toxic substances or flammable substances by 40 CFR Part 68 are as follows:





Toxic Substances:



* Anhydrous Ammonia: Anhydrous ammonia is used as a reactant in the polyamine

process. The maximum quantity of anhydrous ammonia stored on-site is 88,000 pounds.



* Aqueous Ammonia: 30 percent ammonium hydroxide (aqueous ammonia) is used as a

reactant in the polyamine process. The maximum amount of 30 percent ammonium

hydroxide
(aqueous ammonia) stored on-site is 150,000 pounds (45,000 pounds pure ammonia).



* Epichlorohydrin: Epichlorohydrin is used as a reactant in the polyamine process. The

maximum quantity stored on-site is 370,000 pounds.



* Ethylenediamine: Ethylenediamine is used as a reactant in the polyamine process. The

maximum quantity stored on-site is 45,000 pounds.



* Formaldehyde: Formaldehyde is used as a reactant in the Mannich process and in the

production of melamine formaldehyde acid colloid. Formaldehyde is received and stored

as a 37 percent solution in water. The maximum amount of 37 percent formaldehyde

stored on-site is 90,000 pounds (33,000 pounds pure formaldehyde).





Flammable Substances:



* Dimethylamine: Dimethylamine is used in the DADMAC and polyamine processes as a

reactant. It is also used to make Mannich polymers. Dimethylamine is received and

stored in anhydrous form. The maximum amount of anhydrous dimethylamine stored on-

site is approximately 380,000 pounds.





Worst-case Scenarios:



As required by the Risk Management Program Rule, worst case and alternative release scenarios

were evaluated and are discussed in this RMP. As required, worst case scenarios are presented in

the RMP for one toxic substance and one flammable substance. Alternative scenarios were

prepared for each of the toxic substances with worst case endpoints located offsite and for one

flammable substance (dimethylamine). The endpoint represents the distance at which a released

substance must travel before it disperses sufficiently to no longer pose a hazard to the public.



For the worst case scenario, EPA has defined a worst-case release as the release of the largest

quantity of a regulated substance from a vessel or process line failure that results in the greatest

distance to a specified endpoint. For the worst-case analysis, the possible causes of the

worst-case release or the probability
that such a release might occur are not considered. The

release is simply assumed to take place and the greatest amount held in a vessel is suddenly

released. The results of the worst case scenario analysis were as follows:



* Toxic Substances: The anhydrous ammonia storage tank was assumed to fail and

subsequently produce an instantaneous release of the entire tank contents. The release

was assumed to occur over a 10-minute time period. No passive mitigation controls were

considered in limiting the release impacts. The distance to the toxic endpoint was

estimated to be less than 2.0 miles.



* Flammable Substances: The dimethylamine storage tank was assumed to fail and

subsequently produce an instantaneous release of the entire tank contents that results in a

vapor cloud explosion. No passive mitigation controls were considered in limiting the

release impacts. The distance to the explosion endpoint was estimated to be less than 0.47

miles.





Alternative Release Scenarios:



Alternative release scenarios are more realistic scenarios that result in endpoints that affect public

receptors. For anhydrous ammonia, epichlorohydrin, ethylenediamine, and formaldehyde,

releases were assumed to occur as a result of the uncoupling or rupture of a transfer hose during unloading

operations for each substance. For flammable materials, the alternative release scenario assumed that

dimethylamine was released as a result of the uncoupling or rupture of a hose during unloading operations.

The durations for releasing these materials (except anhydrous ammonia) from a vessel/pipe for the

alternative release scenarios were assumed to occur over a 1-minute time period. Anhydrous ammonia was

assumed to be released within a 15 second period since the delivery vessel is equipped with a high-flow

shut-off valve. With the exception of considering that these transfer operations are monitored by personnel

a
t all times, no other mitigating controls were assumed to limit the releases. For aqueous ammonia, it was

assumed that a release occurred due to a flange leak over a 10 minute period. The results of the

alternative release scenario analysis were as follows:



Toxic Substances:

Anhydrous Ammonia - 0.62 miles

Aqueous Ammonia - 0.19 miles

Epichlorohydrin - 0.19 miles

Ethylenediamine - 0.06 miles

Formaldehyde, 37 percent - 0.06 miles



Flammable Substance:

Dimethylamine - 0.11 miles





Prevention Program:



To address potential accidental releases, an accidental release prevention program along with

chemical specific prevention steps have been developed. The key parts to the program are:



Written operating procedures and emergency shutdown procedures.

Engineering controls to include that all valves fail in the safe position on loss

of motive power. Safe position is "closed" in most cases.

Deluge system on the ammonia tank.

Emergency responders trained in the plant.

Contract emergency responders on 24-hour call.



Additionally, the facility has programs to address the OSHA Process Safety Management (PSM)

requirements for several chemicals including anhydrous ammonia, formaldehyde, and

dimethylamine.





Emergency Response Program:



The facility also has an emergency response program (ERP) that has been enhanced as part of

implementing the Risk Management Program. The ERP has historically been coordinated with

the local volunteer fire department (St. Tammany Fire District No. 11) and will continue to be

coordinated in this manner. As part of the community involvement efforts, the facility's

management attends a monthly "Mayors Meeting", and has coordinated an emergency response

drill with the local fire department, police depa
rtment, and ambulance service which took place

in October 1998. The facility has also installed a siren at the Pearl River Police Station, which is

activated by the Police in case of a 911 call from the plant.



As part of preparing the RMP, the facility's five year accident history was reviewed. No

accidental releases from covered processes have occurred that resulted in deaths, injuries, or

significant property damage on-site or off-site; or resulted in off-site evacuations or sheltering in

place.





Safety Improvement:



PRP is committed to continuous improvement of safety. Planned changes and policies to

promote this improvement include continuous review and update of the facility's ERP, continued

management of the plant Safety Work Order System, and yearly emergency drills with the

community to determine and improve upon deficiencies.