Ashland Specialty Chemical Company - Houston, TX - Executive Summary |
|
The accidental release prevention and emergency response policies at your facility: Ashland Specialty Chemical Company (Ashland) relies on numerous programs to ensure early identification of and proper response to potential emergencies, including: Training and drills in emergency preparedness, 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 invite local fire departments and emergency responders to tour and inspect our plants, participate in joint emergency drills, and gain familiarity with our operations. Many of our employees are members of the Local Emergency Planning Committee. Our facilities have written emergency preparedness plans that are updated regularly. Ashland facilities typically host open houses every 3 to 5 years as an opp ortunity for neighbors to learn about our commitment to safety. Ashland makes an effort to support our communities through sponsorship of local activities and participation in many local organizations. A description of your facility and the regulated substances handled: This facility receives and stores chemicals used primarily for water treatment and the marine industry. This facility handles only one chemical, cyclohexylamine, which is regulated by the USEPA Risk Management Program regulations. Cyclohexylamine is received in heavy-duty stainless-steel containers, diluted with water in a blend tank, and transferred to smaller containers that are sold to our customers. The threshold quantity of cyclohexylamine is only exceeded in the flammable storage area. 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 conten ts of the largest vessel are released. This event is unlikely and has never occurred at our facility. Based on our analysis using USEPA-approved methods, the worst-case release scenario for cyclohexylamine could potentially affect offsite receptors. There were no specific administrative controls or mitigation measures considered in the analysis to limit the distance reported. 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 cyclohexylamine could possibly impact offsite public receptors. There were no specific administrative controls or mitigation measures considered in the analysis to limit the distance reported. The general accidental release prevention p rogram 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. The operations at this facility are ISO 9002 certified. The ISO program ensures 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 accidental releases. 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: We have never had an accident involving cyclohexylamine that resulted in or could have resulted in an offsite impact. We have never had any significant spill of cyclohexylamine at our facility. The emergency response program: Our employees do not respond offensively to accidental releases of the regulated substances, but rely on local emergency responders when there is a need for response. Our employees regularly undergo training in defensive emergency response activities. Our facilities regularly invite local fire departments 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 routine hazard reviews. We make changes to improve safety based on comments and information developed within our organization and the industry. Toward continuous improvement, we are looking at ways to minimize risk through process improvement and re-design. Ashland is committed to the Chemical Manufacturers Association's Responsible CareSM Initiative Management Code on Process Safety. |