Hercules Incorporated -- Portland Plant - Executive Summary

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Hercules Incorporated is a member of the Chemical Manufactures Association and is committed to the principles of Responsible Care..  The corporate Policy on Safety, Health, and Environment states: 
At Hercules, we manufacture chemical specialty products. We do so with full commitment to the chemical industry's Responsible Care. initiative. In keeping with this commitment, we are dedicated to providing a safe and healthful environment for our employees, customers, and communities. To do this, we are dedicated to and working toward continuous improvement in our operations to prevent pollution; to reduce risk; and to enhance safety, health, and environmental performance. By incorporating these beliefs and attitudes into the way we do things at Hercules, we take a key step forward in minimizing the environmental impact of our operations, satisfying customer needs, and creating shareholder value. 
We will adhere to the following basic principles in managing our business worldwide: 
We will comply with the letter and spirit of all applicable safety, health, and environmental laws, regulations, and corporate guidelines. 
We will define strategic objectives, develop tactical plans, identify clear accountability, provide necessary resources, and measure our progress on safety, health, and environmental matters on an ongoing basis. Our planning will consider both business goals and significant safety, health, and environmental aspects of our products and  
We will evaluate the safety, health, and environmental impacts of new and existing products and operations and will work to reduce the adverse impacts. 
We will provide for an open dialogue on safety, health, and environmental issues relating to our products and operations with our stakeholders, including shareholders, employees, customers, suppliers, government agencies, and communities. 
We will work to continually reduce workplace injuries; incidents with the potential for causing property damage, mat 
erial loss, or interruption of our business; waste; and releases to the environment. 
We will emphasize product stewardship and advocate its importance to our suppliers, distributors, and customers. 
Every Hercules employee, worldwide, has a role to play. All of us are responsible and accountable for adhering to the letter and spirit of this policy. All of us must incorporate safety, health, and environmental considerations into our daily business activities. It takes a total team effort to truly be a Responsible Care company. 
Facility Description: 
The primary activity at the Portland Plant is the manufacture of chemical additives, including wet strength resins, that are used in the pulp and paper industry.  Epichlorohydrin, is used in the production of wet-strength resins. These resins are used to improve the wet-strength characteristics in a variety of paper applications.  Epichlorohydrin is a raw material for the process and is consumed in a chemical reaction to make the product.   
The plant primarily receives Epichlorohydrin in tank cars however there is the capability of receiving tank trucks.  Epichlorohydrin is stored in a tank that holds a maximum of 307,700 pounds; the storage tank is provided with a containment dike and leak detectors to minimize adverse impacts from any leaks or spills.  Spill containment capability is also provided for the area where tank trucks and rail cars are unloaded. 
Worst-Case Scenario: 
The Portland Plant is reporting two worst-case scenarios.  Both scenarios include the complete failure of an entire rail car containing 223,000 of Epichlorohydrin and both scenarios were analyzed using EPA's OCAG lookup tables.  This first scenario gives a distance to the EPA toxic endpoint of 4.2 miles.  This scenario is not limited to any containment  and corresponds to a release on rail tracks leased by Hercules.  The second scenario gives a distance to the EPA toxic endpoint of 3.6 miles; however this scenario is limited by the provisions of d 
rains and containment. In addition, both scenarios require the extremely unlikely event of a catastrophic failure of the rail cars.   
Alternative Case Scenario: 
The alternative case scenario for Epichlorohydrin is a pipe leak (flange) in the process area that results in the release of 222 pounds of Epichlorohydrin.  This scenario gives a distance to the EPA toxic endpoint of 0.06 miles based EPA's OCAG lookup tables.  The impact from this scenario is mitigated by containment in the process area.  In addition, operating procedures and process monitors will limit the duration of leakage. 
Accident Prevention Program: 
The process is subject to the OSHA Process Safety Management standard (29 CFR 1910.119) and has a complete process safety management system in place.  This includes the use  of process hazards analysis to identify and address potential hazards, management of change procedures to control modifications, mechanical integrity procedures for minimizing mechanical failures, detai 
led operating procedures for process control, and operator training for the personnel involved in the process. 
Five Year Accident History: 
In the past five years, the Portland Plant has not had any accidental releases of Epichlorohydrin that have resulted in on-site injuries or damage or any off-site impacts. 
Emergency Response Program: 
The Portland Plant has a written emergency response plan and coordinates emergency response matters with the Portland Fire Bureau.  In addition, the plant is an active participant in a mutual support group that includes other companies and agencies in Portland.  The plant has provided emergency response training for all plant employees and has a trained emergency response team.
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