Ashland Specialty Chemical Company-Dallas, TX - 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, 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 Local Emergency Planning Committees. Our facilities have written emergency preparedness plans that are updated regularly. Ashland facilities typically host open houses every 3 to 5 years as an opport unity 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 manufactures, receives, stores, and ships chemicals which are primarily used in the electronics and semiconductor industry. The regulated substances handled are anhydrous ammonia 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 anhydrous ammonia. Ba sed on our analysis using USEPA-approved methods, the worst-case release scenario could potentially affect offsite public receptors. The administrative control on tank inventory and the enclosure surrounding the storage tanks were taken into consideration 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 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 scenarios for anhydrous ammonia and ammonium hydroxide could potentially impact offsite public receptors. The active mitigation associated with the emergency shutdown of the ammonia building ventilation was taken into consideration to limit the distances reported. The passive mitigation measures considered in the analysis were the diked containment of the ammonium hydroxide, the administrative controls on tank inventories, and the anhydrous ammonia tank enclosure. 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. The operations at this facility are ISO 9002 certified. The management system procedures contained in the ISO program 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 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 an emergency. Five-year accident history: This facility has never had a release of anhydrous ammonia or ammonium hydroxide that resulted in or could have resulted in an offsite impact. The emergency response program: Our employees are trained and equipped to respond offensively to accidental releases of the regulated substances and will coordinate with local emergency responders when there is a need for response. Our employees regularly undergo training in emergency response activities. This facility regularly invites the local fire department and emergency responders to tour and inspect our plant and gain familiarity with our operations. This facility has a written emergency response plan that is updated regularly. Planned changes to improve saf ety: Our facility continually evaluates and implements employee suggestions and recommendations resulting from routine hazard reviews and process hazard analyses. We have just completed the building of an enclosure around the anhydrous ammonia system to minimize potential offsite impacts of an accidental release. 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. |