Ashland Specialty Chemical Co. - Easton, PA - Executive Summary |
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The accidental release prevention and emergency response policies at your facility: Ashland Specialty Chemical Company 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. Our facilities have written emergency preparedness plans that are updated regularly. Ashland facilities typically host open houses every 3 to 5 years as an opportunity for neighbors to learn about our commitment to sa fety. 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 provides high purity chemicals to the semi-conductor industry. The regulated process involves storage, blending, repackaging and shipment of the covered substances. The regulated substances are hydrochloric acid (37 wt.%), ethylenediamine, and ammonium hydroxide (29 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 are released. This event is highly unlikely and has never occurred at our facility. The USEPA requires that one worst-case scenario be reported to represent all regulated toxic substances held above the threshold quantity. Based on our an alysis using USEPA-approved modeling methods, the worst-case release scenario for hydrochloric acid could potentially affect offsite receptors. There were no specific administrative controls considered in the analysis to limit the distance reported. Diked containment was considered as a passive mitigation measure in the worst-case analysis for hydrochloric acid. 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 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 scenario for hydrochloric acid potentially could affect offsite receptors, however, the alternative-case release scenarios for ammonium hydrox ide and ethylenediamine do not impact offsite public receptors. There were no specific administrative controls or active mitigation measures considered in the analysis to limit the distances reported. Diked containment was considered as a passive mitigation measure in the alternative-case analysis for hydrochloric acid. The passive mitigation measure considered in the alternative-case analyses for ammonium hydroxide and ethylenediamine was storage in an enclosed building. 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. 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 potent ial incidents that could lead to an accidental release. Ashland maintains 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 hydrochloric acid (37 wt.%), ethylenediamine, or ammonium hydroxide (29 wt.%) that has resulted in or could have resulted in an offsite impact. Emergency Response Program: Our employees are trained and equipped to offensively respond and neutralize any release of a hazardous substance. 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 i n joint emergency drills. This facility has a written emergency response plan that is updated regularly. Planned changes to improve safety: Our facilities continually evaluate and implement employee suggestions and recommendations resulting from hazard reviews. We make changes to improve reliability and safety based on information developed within our organization and 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. |