Ashland Specialty Chemical Company - Commerce - 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 the Local Emergency Planning Committee. Our facilities have written emergency preparedness plans that are updated regularly. Ashland facilities typically host open house s 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 in many local organizations. A description of your facility and the regulated substances handled: This facility produces a variety of polyester resins. The regulated substance handled is toluene diisocyanate, in a mixture of toluene 2,4-diisocyanate (80 wt.%) and toluene 2,6-diisocyanate (20 wt.%). 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. Based on our analysis using USEPA-approved methods, the worst-case release scenario could potentially affect offsite receptors. In Section 2.6 of the Risk Management Plan Submittal, the RM P*Submit software has a "bug" that does not accept release rates of less than 0.1 pounds per minute. Our release rate for the worst-case release scenario is 0.0067 pounds per minute but we have input 0.1 pounds per minute into Section 2.6. Similarly, in Section 3.6 for each alternative release scenario, we have input a value of 0.1 pounds per minute as the release rate. The actual release rates for the alternative release scenarios are 0.0049 pounds per minute for toluene 2,4-diisocyanate and 0.0036 pounds per minute for toluene 2,6-diisocyanate. There were no specific administrative controls considered in the analysis to limit the distance reported. The passive mitigation considered in the analysis was the storage of the toluene diisocyanate mixture in a diked area. The alternative-case release scenario: The USEPA RMP regulations require an analysis of the alternative-case release scenarios. The alternative-case release scenario represents an accidental release that is more re asonable than the worst-case, but is still highly unlikely to occur. Based on our analysis using USEPA-approved methods, the alternative-case release scenarios for toluene 2,4-diisocyanate and toluene 2,6-diisocyanate could impact offsite public receptors. There were no specific administrative controls or active mitigation measures considered in the analysis to limit the distance reported. The passive mitigation considered in the analysis was the storage of the toluene diisocyanate mixture in a diked area. The general accidental release prevention program and chemical-specific prevention steps. This facility is operated in strict accordance with written operating and maintenance procedures. 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 accidental releases. Ashland maintai ns a 24-hour corporate emergency reporting system that can speedily coordinate 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. We have never had a release of the toluene diisocyanate mixture that has had any offsite impacts from our facility. The emergency response program. Our employees do not respond offensively to accidental releases of the regulated substance, 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 t hat are updated regularly. Planned changes to improve safety. Our facility continually evaluates and implements 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, process re-design and formulation substitution. Ashland is committed to the Chemical Manufacturers Association's Responsible CareSM Initiative Management Code on Process Safety. |