ASHTA Chemicals Incorporated - Executive Summary

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We at ASHTA Chemicals Inc. (ASHTA Chemicals) are committed to operating our processes in a manner that is safe for our workers, the community, and the environment.  As part of this commitment, we have established a Business Discipline System to help ensure safe operation of the processes at this facility.  Our mission statement reads as follows: "The ASHTA Team operates proactively to protect our employees, the public, and the environment, and to conform with mutually agreed upon requirements for product and services with customers, fellow employees, and our shareholders."  One component of this system is a risk management program (RMP) that helps manage the risks involved with having hazardous substances at our facility and that complies with the requirements of the Environmental Protection Agency's (EPA's) regulation 40 CFR 68, Accidental Release Prevention Requirements: Risk Management Programs (the RMP rule).  One of the requirements of the RMP rule is to submit an executive summar 
yin the risk management plan (RMPlan) describing the risk management program at ASHTA Chemicals.  This document is intended to satisfy the executive summary requirement of the RMP rule and to provide the public with a description of our risk management program. 
Our risk management program consists of three elements: 
1.  A hazard assessment designed to help us understand (a) the potential offsite consequences of hypothetical accidental releases and (b) accidents that have occurred during the last 5 years associated with the substances regulated by the RMP rule  see Sections 3 and 5 
2.  A prevention program to help maintain and safely operate processes containing significant quantities of substances regulated by the RMP rule  see Section 4 
3.  An emergency response program to help respond to accidental releases of regulated substances from processes covered by the RMP rule  see Section 6 
Information further describing these elements is provided in this executive summary. 
h our risk management program helps ensure that our facility is maintained and operated in a safe manner, it is only one component of the safety program.  In fact, we have a comprehensive safety program that establishes many levels of safeguards against accidental releases and against the injuries and damage that could occur. 
Limiting the use of hazardous substances.  Before using a hazardous substance, we always consider less hazardous alternatives.  When we must use a hazardous substance, we consider the potential for this substance to adversely affect our workers, the public, and the environment and take steps to prevent any such effects. 
Preventing releases of the hazardous substances used at the facility.  When a hazardous substance is used, the equipment used to contain it is carefully designed, built, maintained and operated to reduce the likelihood of an accidental release.  Industry and government standards are closely adhered to in the design, construction, and operation of 
the equipment. 
Limiting damage from a release, if such a release occurs.  We work daily to prevent accidental releases from occurring.  However, we also train our workforce to recognize accidental releases, quickly assess the severity of a release, and respond to mitigate and stop the release. We work closely with the Ashtabula Township Fire Department and the Ashtabula County Local Emergency Planning Committee to ensure appropriate plans are in place to minimize the impact of the release on our workers and the community.  Our safety program consists of a number of elements, only some of which are required by the RMP rule.  This RMPlan is primarily intended to describe those parts of the safety program required by the RMP rule. 
1.  Accidental Release Prevention and Emergency Response Policies 
We are committed to the safety of workers and the public, and the preservation of the environment, through the prevention of accidental releases of hazardous substances.  We take reasonable st 
eps to prevent foreseeable releases of hazardous substances.  These steps include (1) training programs for personnel, (2) programs to help ensure safety in the design, installation, operation, and maintenance of our processes, and (3) programs to evaluate the hazards of our processes. 
In the event of an accidental release, we will strive to control and contain the release in a manner that will be safe for workers and will help prevent injury to the public or damage to the environment.  We provide emergency response training to our personnel so that they are well prepared to handle emergency situations and execute emergency response actions. 
2.  Regulated Substances We Produce 
In one of our manufacturing processes we produce chlorine in sufficient quantity to be covered by the RMP rule.  Chlorine is covered as a toxic material by the RMP rule. 
3.  Offsite Consequence Analysis 
We performed an offsite consequence analysis to estimate the potential for an accidental release of chlori 
ne to affect the public or the environment. We evaluated one worst-case release scenario and one more reasonable (but still highly unlikely) alternative release scenario. 
We do not expect a worst-case release scenario to ever occur.  This scenario is designed to estimate the maximum possible area that could be affected by a release at our facility, but it is not a realistic scenario. An alternative release scenario was analyzed to provide emergency responders with information that should help them to improve the community emergency response plan.  The alternative release scenario represents a release that might occur at a facility like ASHTA Chemicals. 
The main objective for performing the offsite consequence analysis was to determine the distance at which certain effects on the public might occur because of an accidental release (called the endpoint distance). For exposures to chlorine, most people at the endpoint distance would be able to walk away from the exposure without any lon 
g-term health consequences, although some short-term consequences (e.g., strong eye or throat irritation) are likely.  Some people who are particularly susceptible could experience more serious effects.  At distances less than the endpoint distance, the effects would be more severe; at distances greater than the endpoint distance, the effects would be less severe. 
The following information summarizes the offsite consequence analysis.  
3.1  Worst-case Release Scenario  
The worst-case release scenario is a failure of a storage tank that can hold up to 270,000 lbs of chlorine.  When we assume that (1) the storage tank is full and (2) all the chlorine is released and vaporized over a 10-minute time period, the predicted distance to the toxic endpoint (3 ppm) extends off site 17 miles, and public receptors are within the distance to the endpoint. 
3.2  Alternative Release Scenario 
The alternative release scenario for chlorine is a malfunction of the chlorine scrubber system.  In this sc 
enario, an ASHTA Chemicals employee will stop chlorine production within 10 minutes.  During this time, an estimated 500-lb of chlorine will be released through the scrubber vent. The resulting distance to the endpoint extends less than one-quarter mile off-site; however, there are no residences within the distance to the endpoint. 
4.  Accidental Release Prevention Program and Chemical-specific Prevention Steps 
We have always believed that safety is the highest priority.  Beginning in 1992, we incorporated this belief into a prevention program that complies with the Occupational Safety and Health Administration's (OSHA's) process safety management (PSM) regulation.  For ASHTA Chemicals, the prevention program requirements of EPA's RMP rule are nearly identical to the PSM regulation.  The following sections briefly describe the elements of our prevention program that address the RMP rule requirements. 
4.1  Prevention Program 
Our accident prevention program consists of the following 
12 elements: 
4.1.1.  Process safety information.  We maintain a variety of technical documents, including an Emergency Preparedness Plan, to help ensure that our employees and local emergency responders know about the hazards associated with our facility.  These documents address (a) physical properties of the hazardous substances we handle, (b) operating parameters for our equipment, and (c) design basis and configuration for our equipment.  We ensure that this process safety information is available to all our employees. 
4.1.2.  Process hazard analysis.  We perform and periodically update process hazard analyses of our processes to help identify process hazards and make recommendations that might improve the safe operation of the processes.  To perform a process hazard analysis, a multidisciplinary team is assembled to analyze the hazards of our processes.  Each team includes personnel with engineering and process operating experience and a leader with process hazard analysis expe 
rience. The teams systematically address the hazards associated with operation of the equipment in the process areas. Each team then prepares a written report describing the results of the analysis, including a list of recommendations.  Responsibility for resolving the recommendations is assigned to area personnel, and, when appropriate, changes to enhance the safety of the processes are implemented.  Each analysis is revisited at least every 5 years to ensure it is current. 
4.1.3.  Operating procedures.  Our process engineers, operators, and managers work together to develop and maintain operating procedures to define how tasks related to process operations should be safely performed.  The operating procedures are used to train employees and serve as reference guides for appropriate actions to take during both normal operations and process upsets.  Operating procedures include: 
7  Steps for safely conducting activities 
7  Applicable process safety information, such as safe operating  
limits and consequences of process deviations 
7  Safety and health considerations, such as chemical hazards, personal protective equipment requirements, and actions to take if exposure to a hazardous substance occurs 
4.1.4.  Training.  We train workers to safely and effectively perform their assigned tasks.  Our training program includes both initial and refresher training that covers (a) a general overview of the processes (b) the properties and hazards of the substances in the processes, and (c) a detailed review of applicable operating procedures and safe work practices.  Both written and oral reviews are used to verify that employees understand the training material. 
4.1.5.  Mechanical integrity.  We maintain our process equipment to help prevent equipment failures that could endanger workers, the public, or the environment.  Our mechanical integrity (preventive maintenance) program includes (a) an inspection and testing program to help identify equipment deterioration and damage 
before the equipment fails and (b) a quality assurance function to help ensure that new and replacement equipment meet the strict design standards required for service in our processes. 
4.1.6.  Management of change.  We evaluate and specifically approve all proposed changes to chemicals, equipment, technology, and procedures to help ensure that changes do not negatively affect safe operations. All changes other than replacement-in-kind (e.g., replacing a valve with an identical valve) must be approved through the full management of change program.  This helps ensure that inadvertent consequences of process changes are prevented, safety consequences of changes are addressed, affected process safety information and procedures are updated, and affected employees are notified of the changes. 
4.1.7.  Pre-startup safety review.  We recognize that new or newly modified processes are historically more likely to be involved in accidental releases.  Therefore, we perform safety reviews of new 
or modified processes before placing them into service to help ensure their safe operation.  This review confirms that: 
7 Construction and equipment are in accordance with design specifications 
7 Adequate safety, operating, maintenance, and emergency procedures are in place 
7 Employee training has been completed 
7 For a covered process, a process hazard analysis has been performed if the process is new, or management of change requirements have been completed if an existing process has been modified 
4.1.8.  Compliance audit.  One of the cornerstones of an effective prevention program is performing thorough assessments on a regular basis.  We audit our processes every 3 years to be certain our prevention program is effectively addressing the safety issues of our operations.  To conduct an audit, we assemble a team that includes personnel knowledgeable in the PSM and RMP regulations and in our process designs.  The team evaluates whether our prevention program satisfies the requirement 
s of these two regulations and whether it is sufficient to help ensure safe operation of the processes.  The results of the audit are documented, recommendations are resolved, and appropriate enhancements to the prevention program are implemented. 
4.1.9.  Incident investigation.  We investigate all incidents that could reasonably have resulted in serious injury to personnel, the public, or the environment so that similar accidents can be prevented in the future.  We train our employees to identify and report any incident requiring investigation.  When an incident occurs, we assemble an investigation team and initiate the investigation within 48 hours of the incident. The results of the investigation are documented, recommendations are resolved, and appropriate process improvements are implemented. 
4.1.10.  Employee participation.  We have a written employee participation program for our covered processes to help ensure that the safety concerns of our workers are addressed.  We encour 
age active participation of personnel in the prevention program activities of all processes at the facility.  Employees are consulted on and informed about all aspects of our accidental release prevention program. 
4.1.11.  Hot work permits.  We have a hot work permit program to control spark- or flame-producing activities that could result in fires or explosions in our facility.  We reviewed OSHA's fire prevention and protection requirements and created a hot work permit form to comply with those requirements.  Personnel who are to perform hot work are required to fill out the form, and the appropriate supervisor reviews the completed form and the work area before work can begin.  Training on hot work activities and on the requirements of the hot work permit program is included in our safe work practices orientation. 
4.1.12.  Contractors.  We have a program in place to help ensure that contractor activities at our facility are performed in a safe manner.  We explain to the contract s 
upervisors the hazards of the processes on which they and their employees will work, our safe work practices, and our emergency response procedures.  The contractor is required to ensure that training has been performed for each of their employees who will work at the facility before that worker begins work at our facility. This training is updated annually for each contract employee. 
4.2  Chemical-specific Prevention Steps 
In addition to the required prevention program elements, special measures and safety features specific to chlorine have been implemented at ASHTA Chemicals to prevent accidents or releases. The 90-ton chlorine rail cars, which are approved by the Department of Transportation (DOT), are inspected, tested, and certified every other year. The valves on the rail cars are designed and maintained in accordance with good engineering practices established by the Chlorine Institute.  Chlorine storage tank pressures are automatically maintained at a pressure eight times les 
s than the pressure rating of the vessel. All chlorine lines transferring liquid or gaseous product are inspected for mechanical integrity at regular frequencies.  Preventive maintenance is performed on all process equipment to ensure continuous operation without incident. ASHTA Chemicals maintains a redundant chlorine vent scrubber system in which a back up scrubber is always available should the on-line system malfunction. Emergency generators will automatically provide electricity to critical systems to prevent the release of chlorine in the event of a power loss.  These are just some of the measures which help ASHTA Chemicals safeguard our employees, the public, and the environment. 
5.  Five-year Accident History 
Our accident history demonstrates the continuous safe operation of our chemical processes over the last 5 years.  Six accidental releases of chlorine have occurred over that time.  Five of these were brief leaks that exposed employees to chlorine in sufficient concentrat 
ion to require medical attention. None of the employees suffered long-term health effects due to their exposure.  The sixth was a release that was detected at a neighboring facility. No injuries occurred and neither the community nor the environment was affected in any way.  All of the releases were less than the EPA reportable quantity of ten pounds. 
6.  Emergency Response Programs 
We have established a written emergency response program to help ensure the safety of personnel who respond to accidental releases of hazardous substances.  The emergency response plan includes procedures for: 
7 Informing the Ashtabula Township Fire Department, the Ohio EPA, the Local Emergency Planning Committee, and the National Spill Response Center about accidental releases that could reasonably result in offsite consequences 
7 Providing proper first aid and emergency medical treatment for accidental human exposure to hazardous substances 
7 Obtaining outside assistance to control and contain accidenta 
l releases of hazardous substances, including the use of emergency response equipment 
7 Inspecting and maintaining emergency response equipment 
7 Reviewing and updating the emergency response plan 
We have trained our employees to recognize and report emergency situations.  All of our personnel are trained in evacuation procedures.  The Ashtabula County Emergency Management Agency is responsible for notifying the public of emergency situations, if necessary. 
The written emergency response plan complies with other federal contingency plan regulations [e.g., OSHA regulation 29 CFR 1910.38(a)], and a copy of the plan has been provided to the Ashtabula Township Fire Department. Also, an Ashtabula County Emergency Operations Plan has been developed by the Ashtabula County Local Emergency Planning Committee, of which an ASHTA Chemicals representative is a member. 
7.  Planned Changes to Improve Safety 
We constantly strive to improve the safety of our processes using recommendations develop 
ed through the prevention program and a program soliciting safety suggestions from our employees.  All recommendations received by plant management are evaluated and implemented if safety can be improved.  On an annual basis, we review all of our operating and safety procedures to ensure that they are correct, and we provide training to our employees and contractors on a wide variety of safety and operating topics.  ASHTA Chemicals is constantly being modified as new and improved equipment is placed in service, which helps to maintain the high standard of safety that the plant has achieved in the past.
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