Ashtabula Complex Plant 1 - Executive Summary

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The Ashtabula Complex, Plant 1 facility is a world class chemical manufacturing facility located in Ashtabula, Ohio.  It is one of several facilities throughout the world that are owned and operated by Millennium Inorganic Chemicals Inc. to produce titanium dioxide, a nonhazardous pigment used in a diverse range of coatings, plastics, papers, and elastomers.  Millennium Inorganic Chemicals takes pride in ensuring that the Ashtabula Complex, Plant 1 is designed and operated to prevent hazards in our workplace and maintains well established contingency plans in place in the unlikely event of a mishap.   
Controlling risks from hazardous substances is a major part of our "Commitment to Safety and Environment", which states: 
"There is no activity or job at the Ashtabula Complex which is so important or urgent that it must be done by jeopardizing the safety or health of any employee, visitor, or contractor, or at the risk of damaging the environment. Any employee at the Ashtabula Complex  
has the authority and obligation to stop any activity or job which they feel may jeopardize the safety or health of any employee or contractor, or may risk damaging the environment." 
To ensure that we operate according to this policy, we have programs in place that provide layers of protection for preventing releases and protecting the public and environment, including: 
- Operating programs that are consistent with the Chemical Manufacturers' Association Responsible Care. code of practices 
- A management system that is certified as conforming to ISO-9002 International Standards 
- Continuing compliance with all applicable federal and state regulations and permits, including OSHA "process safety management" and EPA "risk management program" standards 
- Coordination of our emergency contingency plans with local response agencies 
Hazard Assessments 
The Plant 1 facility includes two primary processes that handle substances that have been classified as "hazardous" by EPA.  These processe 
s are called the Chlorination and Oxidation processes and each handles and stores chlorine and titanium tetrachloride as an important part of their operation.  We have assessed the risks that our handling and storage of these substances could present to public health and environment by performing offsite consequence analyses in "worst case" and "alternative release" scenarios.   
Our analysis of the offsite consequences for both processes determined that the worst case release would be represented by a release of the contents of a railcar containing chlorine, which, although very unlikely to occur, could result in a release of 180,000 lbs. of chlorine.  Under winds of 3.4 mph the resulting plume could affect a portion of an area within 14 miles of the facility before being reduced below the toxic endpoint.  This area includes an estimated population of 43,000 persons, residences, schools, hospitals, recreation areas and major commercial, office and industrial areas.  It also includes p 
arks, forests and federal wilderness areas.   
Our continuing analysis of release scenarios also includes more credible situations that reflect actual operating conditions for each process.  These include situations such as tank overflows, pipe ruptures and equipment failures.  This analysis has determined that the most serious of such releases could impact a portion of an area within 0.4 miles of our facility in the case of chlorine and 0.2 miles in the case of titanium tetrachloride.   
Accident History 
One release, reportable under EPA regulations, has occurred at the facility in the past five years.  This was a release on June 22, 1996 that resulted in five employees being treated for exposure to titanium tetrachloride. There were no other injuries or damages associated with this release. 
Emergency Response 
Contingency plans are in place at our facility for responding to accidental releases, treating any persons who have been affected by a hazardous substance and rapidly informi 
ng local response agencies.  Our emergency response plan has been coordinated with the Ashtabula County Emergency Management Agency and the Ashtabula Township Fire Department. 
Operations at all Millennium Inorganic Chemicals' facilities, including Ashtabula Complex, Plant 1, are continually reviewed by onsite and corporate management to ensure we use the most up to date release prevention and emergency response programs and meet all applicable regulations.  Whenever methods for safer operation are found in any of our facilities, these are immediately applied, to the extent applicable, at our other facilities throughout the world.  In this way we will continue to maintain a high standard for safety and environmental protection in all of our facilities.
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