Ashland Specialty Chemical Company-Pueblo, CO - 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 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 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 their Local Emergency Planning Committees.  Our facilities have written emergency preparedness plans that are updated regularly.   
 
Ashland facilities typically host ope 
n houses every 3 to 5 years as an opportunity for neighbors to learn about our commitment to safety.  Ashland makes an effort to support our communities through sponsorship of local activities and participation on many local organizations. 
 
A description of your facility and the regulated substances handled:   
 
This facility provides high purity chemicals to the semi-conductor industry.  The regulated substances handled are anhydrous ammonia, hydrochloric acid and ammonium hydroxide.   
 
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 of a regulated substance in a process are released.  The USEPA requires that one worst-case scenario be reported to represent all regulated toxic substances held above the threshold quantity.  Ashland reported the worst-case scenario for the anhydrous ammonia. 
 Based on our analysis using USEPA-approved methods, the worst-case release scenario could potentially affect offsite receptors.  The administrative controls and mitigation measures considered in the analysis were a limitation of storage tank capacity to 85% and containment within a totally enclosed building. 
 
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.  The USEPA requires that the results of the alternative-case release scenario analysis be reported for each toxic present.  Based on our analysis using USEPA-approved methods, the alternative-case release scenarios for anhydrous ammonia, hydrochloric acid, and ammonium hydroxide would only impact offsite commercial and industrial receptors.  The administrative controls and mitigation measures conside 
red in the analysis included: 
 
    Enclosure and limitation of tank capacity to 85% for the anhydrous ammonia storage tank; 
 
    Enclosure, diked containment, and limitation of tank capacity to 90% for the bulk ammonium hydroxide 
    storage tank; and 
 
    Enclosure of the drummed hydrochloric acid and ammonium hydroxide. 
 
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 written operating and maintenance procedures for the covered processes.  Our management system 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 coo 
rdinate emergency response with 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 an emergency.   
 
Five-year accident history: 
 
This facility began operation in 1998.  In the last year, we have not had a release of anhydrous ammonia, hydrochloric acid or ammonium hydroxide that resulted in or could have resulted in an offsite impact from our facility.   
 
The emergency response program: 
 
Our employees are trained and equipped to respond and neutralize releases of hazardous materials. Our employees regularly undergo extensive training in emergency response actions and methods.  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.  This facility has a written emergency response plan that is updated regularly.   
 
 
Planned changes to improve safety: 
 
Our facility continually evaluates and implements employee suggestions and recommendations resulting from routine hazard reviews and process hazard analyses.  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.
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