Neste Resins Corporation - Toledo, OH - Executive Summary |
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Risk Management Plan Executive Summary The Risk Management Program at Neste Resins, Toledo, Ohio facility, incorporates a Risk Management Plan that assimilates the following elements: Environment and Safety Policy of Neste Resins Corporation Neste Resins is committed to a clean, safe and healthy environment through the implementation of a formal management system dedicated to the prevention of pollution and continual improvement of our environmental, health and safety procedures. We are committed to comply with applicable governmental laws and regulations and to meet the requirements of other organizations to which we subscribe. Our employees are our most important asset, and an integral part of the success of our environmental, health and safety programs. We will properly train, equip and direct employees to perform their jobs in a safe and environmentally responsible manner. We review our performance against our objectives and targets and update the Environmental Management Sy stem as appropriate. This policy shall be communicated to all employees and made available to the public. Facility Information The primary activities at Neste Resins are the manufacture of formaldehyde and the production of specialty resins. Formaldehyde is produced from the processing of methanol delivered to the plant via rail car. The maximum quantity of formaldehyde in storage in one vessel is 50,000 gallons at a concentration of 52% by weight. Worst Case and Alternate Case Scenarios The worst case release scenario would be the total release of a 50,000-gallon HCHO storage tank over a 10-minute period into the diked storage area. Formaldehyde will evaporate from the pool over a 10-minute period resulting in a hazard zone with a radius of 0.62 miles. The alternate release scenario for formaldehyde would be the release of HCHO solution in a transfer line that has been valved closed. If ruptured, the transfer line would spill forming a 1 cm deep pool covering 530 square feet. The potential distance to the toxic endpoint of the release (point of dispersion to 0.12 mg/l) would be 0.19 mile. Accidental Release Prevention Program All covered processes at Neste Resins are in Program 3 and meet the requirements of the OSHA Process Safety Management (PSM) program. The existing OSHA PSM-required accidental release prevention program meets nearly all RMP requirements. Where the programs differ, the NESTE Resins' program elements have been modified to incorporate RMP issues. An example would be that the compliance audit procedures required as part of Neste's PSM program have been modified to include evaluations of the RMP implementation. Another example would be that pre-startup review procedures have been modified to incorporate reevaluation of the facility accident scenarios to determine whether the worst case and alternate case scenarios for releases are still consistent with the design and operation of the process being started. Five Year Accident History Neste Resins has had no accidental releases of formaldehyde in the last five years that have caused any deaths, injuries, or significant property damage at the facility nor have there been any accidents which led to off-site deaths, injuries, evacuations, sheltering in place, property or environmental damage. Emergency Response Program Neste Resins has established a facility emergency response plan that meets the requirements of both the OSHA PSM program and the EPA RMP program. This response plan describes the procedures for informing the public and local emergency response agencies of a release, provides documentation of proper first-aid and emergency medical treatment for accidental exposures, and procedures and measures for emergency response after a release. Local emergency response and medical treatment personnel have worked with Neste to provide for the safe control and treatment of releases of formaldehyde. Neste employees receive mandatory training on emergency response p rocedures and emergency response equipment use, inspection, testing, and maintenance. Emergency response procedures are reevaluated as part of the management of change and pre-startup review requirements of the PSM and RMP programs. |