Ashland Specialty Chemical Company- Neal, WV - Executive Summary |
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The accidental release prevention and emergency response policies at your facility: Ashland Specialty Chemical Company (Ashland) relies on numerous policies and programs to ensure early identification of and proper response to potential emergencies, including: Training and drills in emergency preparedness, hazardous materials training, disaster response and control, first-aid, and fire-and-rescue techniques; Frequent auditing of all preparedness programs, safety training and education; and Regular review, follow-up, and maintenance of all company operations and equipment. Our facilities regularly coordinate with local fire departments and emergency responders through tours, inspections, and joint emergency drills. Many of our employees are members of the Local Emergency Planning Committees, area volunteer fire departments, and local emergency response units. Our facilities have written emergency preparedness plans that are updated regularly. Ash land facilities typically host open houses every 3 to 5 years as an opportunity for neighbors to learn about our commitment to safety. Ashland makes every effort to support our communities through sponsorship of local activities and participation in local organizations. A description of your facility and the regulated substances handled: This facility produces maleic anhydride by the oxidation of butane and air in the presence of a catalyst. Butane is the single regulated substance handled above the regulatory threshold quantity. Butane is piped to the facility as a raw material from the Catlettsburg Refinery into three storage tanks. The facility also receives supplemental truck deliveries of butane. For more information, visit our web site at www.ashspec.com or contact the Plant Manager. The worst-case release scenario: The USEPA RMP regulations require the worst-case release scenario to assume that the entire contents of the largest vessel are released. This event is hig hly unlikely and has never occurred at our facility. The USEPA also requires the worst-case scenario for butane to be a vapor cloud explosion of the released material. Vapor cloud explosions are extremely rare events, even when large quantities of flammable materials are released. Based on our analysis using USEPA-approved methods, the worst-case release scenario for butane could potentially affect offsite receptors. In the worst-case analysis, a restricted volume was considered as an administrative control. The alternative-case release scenario: The USEPA RMP regulations require an analysis of the alternative-case release scenario. The alternative-case release scenario represents an accidental release that is more reasonable than the worst-case, but is still highly unlikely to occur. Based on our analysis using USEPA-approved methods, the alternative-case release scenario for butane could possibly impact offsite public receptors. In the alternative-case analysis, a restricte d volume was considered as an administrative control and an excess flow valve was considered as an active mitigation measure. The general accidental release prevention program and chemical-specific prevention steps: This facility is operated in strict accordance with the USEPA prevention program requirements. A written management system is in place with operating and maintenance procedures for the covered process. These procedures ensure rigorous training for operations employees, numerous management checks and balances, and strict attention to changes in the operations with a thorough review and examination of potential incidents that could lead to an accidental release. Ashland maintains a 24-hour corporate emergency reporting system that can speedily coordinate emergency response with top management and quickly communicate key first-aid or medical information to local health care providers. This facility has emergency medical treatment information readily available for use in the event of an emergency. Five-year accident history. During the past five years, we have not had a release of the regulated substance that resulted in or could have resulted in an off-site impact. The emergency response program. Our employees do not respond to accidental chemical releases of the regulated substance, but rely on local emergency responders. Our employees regularly undergo training in defensive emergency response activities. Our facilities regularly invite the local fire department and emergency responders to tour and inspect our plants, gain familiarity with our operations, and participate in joint emergency drills. Our facilities have written emergency preparedness plans that are updated regularly. Planned changes to improve safety. Our facilities continually evaluate and implement employee suggestions and recommendations resulting from process hazard analyses. We make changes to improve safety based on comments and information developed within ou r organization and the industry. Toward continuous improvement, we are looking at ways to minimize risk through process improvement, process re-design, and formulation substitution. Ashland is committed to the Chemical Manufacturers Association's Responsible CareSM Initiative Management Code on Process Safety. |