| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

        Any accidental release of a regulated substance would be detected by strategically- located VOC    
        monitors that would immediately alert production personnel.  In addition, all drums and cylinders are 
        leakproof-tested after filling with a regulated substance.  All tank cars are physically disconnected, 
        valved off, and capped during off-hours.  Security fencing exists around the entire production facility. 
        An Emergency Response Plan has been prepared and submitted to the Colleton County LEPC and 
        the Green Pond Fire Department specifyng a response and warning system in the event of an 
        accidental release of a regulated substance.  In addition, this facility conducts quarterly evacuation 
        drills, two announced and two unannounced, according to the Emergency Response Plan. 
2. Stationary Source and Regulated Substances 
   - Primary activity i 
s the repackaging of chemicals into drums and cylinders for medical sterilization 
     businesses and for chemical synthesis customers. 
   - Regulated Substances 
       * Ethylene Oxide     
       * Propylene Oxide   
       * Methyl Chloride     
3. Release Scenario 
   - Worst Case 
       * Toxic Gas 
            Ethylene Oxide tank car rupture with release of 100% of capacity (171,000 lbs) in 10 minutes 
   - Alternative Release 
       * Toxic Gas 
            Partial Ethylene Oxide hose failure at drum filling station with maximum quantity released at one 
            drum or less (400 lbs) 
       * Toxic Liquid 
            Partial Propylene Oxide hose failure at drum/cylinder filling station with maximum quantity released 
            at one cylinder or less (785 lbs) 
       * Toxic Gas 
            Partial Methyl Chloride hose failure at cylinder filling station with maximum quantity released at one 
            cylinder or less (1350 lbs) 
4. Prevention 
   - All  
three regulated substances at the Green Pond plant are covered by the OSHA Process Safety 
     Management (PSM) standard. 
5. Five-Year Accident History 
   - There has been no accidental release of any regulated substance during the last five years. 
6. Emergency Response Program 
   - Evacuation drills have been conducted quarterly since 1997.  A critique of each drill is completed and 
     changes are made based upon the findings. 
   - Walkie-Talkies are used as a communication device in case of an emergency.  The neighboring 
     company, Triarco Industries, maintains a walkie-talkie and is part of our communication system. 
7. Planned Changes to Improve Safety 
   - Individual emergency shutoff valves on each tank car of Ethylene Oxide will be installed.  Each valve 
     can be remotely operated from two different locations in the event of an emergency.  In addition, the 
     valves will close in the event of a fire.
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