Neste Resins Corporation - Spokane, WA - Executive Summary

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Risk Management Plan 
Executive Summary 
The Risk Management Program at Neste Resins, Spokane, Washington 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 Manage 
ment System as appropriate. 
This policy shall be communicated to all employees and made available to the public. 
Facility Information 
The primary activity at Neste Resins is the manufacture of specialty resin.  Formaldehyde is one of several ingredients, but the only substance regulated under 40 CFR 68. 
Worst Case and Alternate Case Scenarios 
The worst case release would be the result of a broken transfer line during kettle charging with the rupture occurring outside the tank storage containment area.  The maximum quantity released would be 30,000 gallons of solution that is 50% by weight formaldehyde at a spill rate of 180 gallons per minute.  The maximum quantity released to the atmosphere assuming an initial spill temperature of 65 degrees C would be 20.8 lbs/minute.  The potential distance to the toxic endpoint (point of dispersion to 0.012 mg/liter) is 0.81 miles. 
The alternative scenario for formaldehyde would be the release of 1,907 lbs of formaldehyde.  The maximum quantit 
y released to the atmosphere assuming an initial spill temperature of 65 degrees C would be 1.1 lbs/minute.  It is estimated that the release would be stopped by an employee in no more than 5 minutes. 
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 wit 
h 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 procedures 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.
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