Ashland Specialty Chemical Co.- Cleveland West, OH - Executive Summary |
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Accidental release prevention and emergency response policies: Ashland Specialty Chemical Company (Ashland) relies on numerous policies and programs to ensure early identification of and proper response to potential emergencies, including: 7 training and drills in emergency preparedness, hazardous materials training, disaster response and control, first-aid, and fire-and-rescue techniques; 7 frequent auditing of all preparedness programs; safety training and education; and 7 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, gain familiarity with our operations, and participate in joint emergency drills. 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 safety. Ashland makes an effort to support communities through sponsorship of local activities and participation in local organizations. Description of facility and the regulated substances handled: Ashland's Cleveland West facility repackages chemicals and manufactures a variety of phenolic resins for the foundry industry. Fifty weight percent formaldehyde (formalin) and methyl formate are the two substances present which are regulated under the USEPA Risk Management Program Rule, 40 CFR 68. 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 Cleveland West facility has never had a release of formalin or methyl formate that resulted in an offsite impact. Based on our analysis using USEPA-appro ved modeling methods, the worst-case release scenarios could potentially affect offsite receptors. 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 processes. Our management system procedures ensure rigorous training for operations employees, an effective mechanical integrity program, 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 coordinate 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 informati on readily available for use in the event of an emergency. Five-year accident history. During the past five years, we have not had any releases of a regulated substance that have resulted in or could have resulted in an offsite impact. Emergency response program: The Cleveland West employees do not respond offensively to accidental releases of the regulated substances, but rely on local and contract emergency responders. 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. This facility has a written emergency preparedness plan that is updated regularly. Planned changes to improve safety: Our facilities continually evaluate and implement employee suggestions and recommendations resulting from process hazard analyses. We make changes to improve rel iability and safety based on information developed within our organization and industry. The Cleveland West facility recently eliminated the use of sulfur dioxide based on the results of the initial USEPA offsite consequence analysis. We also significantly reduced the potential offsite impact by re-designing the formalin bulk storage system. We reduced our onsite bulk inventory and relocated the formalin to a smaller storage tank which has been totally enclosed. We have also enhanced the integrity of the formaldehyde piping system through the use of metallic gaskets. In one major chemical process, we have begun substituting 50% formalin with a much safer chemical, prilled paraformaldehyde, a solid form of formaldehyde. This substitution allowed us to store half of the amount of 50% formalin, as well as reducing the annual consumption by nearly 50%. Annually, we project that we will reduce our operating costs by more than $175,000, while reducing the area of our calculated impa ct zone and the distance to the toxic endpoint by 33%. 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. |