Establishment

of the LEPC was a requirement of the federal Emergency

and Community Right-to-Know Act (EPCRA) of 1986. Under

the law, the LEPC must be notified immediately if a

facility experiences a release of a "reportable

quantity" of any one of several hundred listed

hazardous chemicals. The reportable quantities are

established by law and, depending on the chemical, range

from one pound to 5,000 pounds. No release of any

chemical under one pound is required to be reported.

Not every

release justifies a response from emergency personnel,

and the thresholds are intended to ensure that emergency

personnel respond to incidents where they are needed.

The

incident at Wilden Plastic's facility occurred when a

piece of injection molding machinery was routinely being

changed over from one plastic raw material (nylon) to a

second (polyphenaline sulfide, or PPS), neither of which

is a listed hazardous material. The machine is located in

a "production cell," which is a 60-foot by

90-foot enclosure within the plant. The maximum amount of

material that the machinery can hold is three ounces

(less than half a pound).

While the

nylon was being purged from the machine and the PPS was

being introduced, the machine began to emit an odorous,

gaseous release. This reaction had never occurred before,

and the employees immediately shut down and emptied the

machine trying to determine the cause.

They

identified a small amount of residue (estimated at less

than one ounce) on the interior of the machine that was

the source of the gas. After several minutes, the three

employees working in the production cell reported to a

manager that they were experiencing some discomfort.

Even though

Wilden was unable to identify the chemical that was

released, it clearly was an amount not subject to

emergency notification requirements, and there was no

reason to believe that anyone outside of the plant could

become exposed.

Therefore,

Wilden's immediate concern was for the health and safety

of its employees and particularly the three who appeared

affected.

To ensure

that no one else could be exposed, the acting plant

manager ordered the plant evacuated until the air

entirely cleared. The three employees were immediately

driven to the hospital. They were released in a few hours

with no aftereffects.

When told

that the three employees had been exposed to a chemical,

the hospital called 911 and emergency personnel were

summoned to the Wilden plant. In view of the very small

amount of material involved, it is understandable that

air sampling showed no evidence of any chemical.

Since the

Oct. 29 incident, Wilden has been conducting an ongoing

investigation into the incident's cause. Immediately

after the incident, samples of residue from the machinery

were analyzed to try to identify the cause of the

chemical reaction.

At this

time, it appears that a residue of the nylon material may

have decomposed in the heated machinery. Although nylon

is not a hazardous chemical and the amount of material

involved was very small, some of the chemical compounds

resulting from the decomposition of nylon have an

unpleasant smell and are capable of causing discomfort

and temporary illness when inhaled.

Wilden has

used the same raw material in exactly the same manner for

years without problem or incident. According to the

supplier, the material's formulation has not changed.

Therefore, we have no immediate explanation as to why it

performed differently on that date.

A sample of

the nylon raw material is currently undergoing chemical

analysis to confirm its exact chemical formulation.

Depending on the outcome of that analysis, other steps

will be taken. In the meantime, Wilden has discontinued

use of this product. Wilden intends to do whatever is

necessary to assure that the reaction experienced on Oct.

29 does not recur.

It has been

noted that Wilden Plastics is not a member of the Local

Emergency Planning Committee (LEPC) for Fayette County.

EPCRA requires certain companies to become involved with

the LEPC and submit annual chemical inventory reports if

they have threshold amounts of chemicals at their

facilities.

The reason

Wilden has never become involved with the LEPC is that

the amounts of chemicals present at its facility are

below the amounts that require notification or annual

reporting to the LEPC. Even though Wilden has no

requirement to participate in the LEPC, we admire and

support its goals, and we are gratified that such an

agency is available to call on when a true emergency

arises.

Steve Soehnel

Controller

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