Perstorp Polyols, Inc. - Executive Summary

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Executive Summary 
Perstorp Polyols, Inc. is submitting this Risk Management Plan 
to fulfill the requirements of Section 112(r) of the Clean Air 
Act.  This plan contains information on the processes involving 
formaldehyde and acetaldehyde at the Perstorp Polyols' facility, 
the prevention programs for the processes, the emergency 
response program for the facility, the necessary release 
scenario using EPA criteria and guidance documents for modeling, 
and the facility's five-year accident history.  This section is 
designed to summarize the information contained in the plan and 
describe the approach to prevention of releases used by Perstorp 
Polyols in Toledo, Ohio. 
Accidental release prevention and emergency response policies 
Perstorp Polyols is committed to operating the facility in a 
safe and environmentally friendly- manner.  We have committed to 
making continuous progress toward the vision of no accidents, 
injuries, or harm to the environment.   O 
ne way that Perstorp 
Polyols demonstrates this commitment is by participating in the 
Responsible Care initiative.  Responsible Care is an initiative 
developed by the Chemical Manufacturers Association designed to 
improve performance in the areas of safety, health, and the 
environment.  Perstorp Polyols signed the Guiding Principles of 
Responsible Care in 1988 and reaffirmed our commitment in 1999 
when our President signed the newly revised Guiding Principles.  
Responsible Care includes management practices that address 
performance ideals in the areas of process safety, community 
outreach and emergency response, distribution of products and 
raw materials, prevention of pollution, employee health and 
safety, as well as product stewardship. 
Perstorp Polyols in Toledo has been recommended for 
certification under the International Standards Organization 
(ISO) 14001 standard for environmental management systems.  This 
certification means that the Toledo facility has a w 
environmental program that meets the requirements of this 
international standard as judged by an independent third party 
Perstorp Polyols has taken the ISO 14001 standard a step further 
and has applied the management system to the safety and health 
of our employees.  This step ensures that safety and health 
issues will be addressed in a systematic manner that strives for 
continuous improvement.  By addressing these matters this way, 
Perstorp Polyols is incorporating the management practices of 
Responsible Care with the international ISO 14001 standard in 
our work every day to reduce the risk of accidents that could 
result in harm to our employees, the public, and the 
environment.  Perstorp Polyols is also certified under the ISO 
9002 standard for Quality Systems. 
As part of the Risk Management Planning process, Perstorp 
Polyols has worked closely with the Lucas County Local Emergency 
Planning Committee.  This close working relationship help 

educate our emergency responders of the risks that are presented 
by our facility, the work that is on-going to prevent accidents 
from occurring and reduce the potential impact of an accident if 
it occurs, and make them more familiar with our facility.  We 
also benefit from this relationship in that we learn from the 
experience of our emergency responders in dealing with incidents 
at other facilities and the preventative actions that can be 
taken to further reduce the risk of an accident at our facility. 
Our work with the Lucas County LEPC gave us the opportunity to 
assist in educating the public about the potential risks of our 
facility posed by the chemicals covered by the risk management 
rule and the preparedness of our local emergency responders in 
the event an accident occurs at our facility.  Perstorp Polyols 
participated in an informational meeting sponsored by the LEPC 
for public officials within Lucas County and surrounding 
communities.  We also set up a boot 
h at a local mall with the 
LEPC and other companies in the county on a Saturday to 
distribute information about our risk management program, the 
prevention programs we have in place, and our release scenarios 
developed using the EPA criteria. 
Perstorp Polyols annually reports its environmental performance 
in an environmental report that is issued by the Perstorp Group 
separately from the annual financial report.  The annual 
environmental report for the Perstorp Group can be found on the 
Perstorp web-site at 
Perstorp Polyols' Toledo facility 
Perstorp Polyols, Inc. is part of Perstorp Polyols AB, a global 
company active in the application areas of chemistry and 
materials technology. Perstorp Polyols Inc began operations in 
Toledo, Ohio in 1977 with the purchase of a Pentaerythritol and 
Sodium Formate manufacturing facility. Since 1977 the operations 
have expanded to include manufacturing of Trimethylolpropane and 
In 1997, Perstorp Polyols completed construction and started a 
new state-of-the-art Formaldehyde plant. This plant was designed 
using Perstorp Polyols' own technology with stack gas recycling 
and a catalytic emission control system to reduce emissions by 
oxidizing volatile organic chemicals to water and carbon 
dioxide.   The Formaldehyde is used both in house in the 
Pentaerythritol and Trimethylolpropane manufacturing processes 
and is sold externally for use in the manufacturing of 
particleboard, clothing and pharmaceuticals.  Formaldehyde is 
one of the chemicals covered by the requirements of the Risk 
Management Planning rule and is included as part of this 
submission because it is stored at the facility in excess of 
15,000 pounds. 
Pentaerythritol and Trimethylolpropane are used in the 
production of resins for paint and coatings, inks and adhesives, 
lubricants and urethane foam. Sodium Formate is used for paper 
bleaching, leather tanning, cattle feed and in the 
production of 
liquid detergents.  Acetaldehyde is a raw material used in the 
production of Pentaerythritol.  Storage of acetaldehyde is 
included in this submission because acetaldehyde is one of the 
chemicals covered by the requirements of the Risk Management 
Planning rule and it is stored at the Toledo facility in excess 
of 10,000 pounds. 
Prevention program 
Perstorp Polyols considers prevention of accidental releases at 
all stages of the plant operation.  This prevention program 
begins with designing for safety in the processes.  All systems 
are designed according to accepted industry codes.  Perstorp 
Polyols' plants and operating systems are designed and operated 
with redundant safety systems and instrumentation.  The purpose 
of these systems is to provide back-up safety protection in the 
event a primary safety system fails.  Modern technology is used 
in the design and construction of processes.  All new or 
modified plants are inspected and reviewed befo 
re start-up.  
Tanks used to store chemicals are placed in concrete secondary 
containment areas to prevent possible leaks or releases from 
reaching soil, ground or surface water.  Most tanks are equipped 
with high level alarms that alert operators that the tanks are 
nearly full and some of these alarms are equipped to shutdown 
the pump that is supplying the tank to prevent overfilling. 
Another step of the prevention program includes the maintenance 
of the plants and their safety systems.  Preventative 
maintenance on processes is regularly conducted to protect 
against equipment failures.  While this does not guarantee that 
equipment will not occasionally break down, it reduces the risk 
that a problem will occur.  Safety systems are inspected and 
tested regularly to ensure that they will be operational if a 
problem develops within the process.  This includes annual or 
semiannual inspection and testing of fire suppression systems by 
outside contractors as well as insp 
ection and testing of 
pressure relief devices within the processes.  Systems that are 
designed to shutdown when an upset occurs are often tested 
during plant downtime to ensure they will function to shut the 
process down if the upset condition occurs. 
Perstorp Polyols employees prevent accidents by operating the 
processes in a safe and efficient manner.  Our operators are 
well trained in operating instructions for the processes.  They 
were involved in the development of many of these operating 
instructions, either by reviewing the instructions when they 
were being written or by writing the instructions themselves.  
Written unloading and operating instructions are regularly 
reviewed and kept up to date. 
Perstorp Polyols believes that safe design, good maintenance 
practices, and well-trained operators are very important parts 
of the prevention program.  However, we have found that a key 
part of managing our processes is taking a critical and 
independent look  
at our operation on a regular basis.  These 
reviews are designed and used to ensure that we do what our 
procedures say that we are doing.  Therefore, Perstorp Polyols 
conducts audits and reviews on safety and environmental systems 
as well as the operational phases of our facility.  We use 
internal reviews of procedures and operations to verify they 
reflect the appropriate level of safety, quality and 
environmental protection.  Independent third-party verifiers 
regularly review our quality and environmental management 
systems to ensure that Perstorp Polyols continuously improves 
the operation of the facility. 
In addition to the work under the ISO standards described 
earlier and the Responsible Care initiative, Perstorp Polyols 
incorporates the requirements of government requirements such as 
the OSHA Process Safety Management Standard and the EPA Risk 
Management Plan in the overall management system for safety, 
health and the environment.  This ensures that protecti 
on of the 
environment and employee safety is a part of every day 
operations at Perstorp Polyols. 
Emergency Response Program 
Despite the prevention program described earlier, Perstorp 
Polyols must prepare and plan for emergencies that may occur.  
There are many government regulations that require emergency 
plans and in 1996, OSHA, EPA, Coast Guard, and Department of 
Transportation worked together to develop a uniform plan for 
emergencies.  That plan, called the Integrated Contingency Plan, 
is used at Perstorp Polyols to provide a single source of 
information and procedures in the event of an emergency.  Copies 
of the plan have been provided to the Toledo Fire and Police 
Departments, several local hospitals, and the Ohio EPA so they 
are aware of the emergency plan at Perstorp Polyols. 
Training is provided to our employees on the plan at least once 
a year.  Evacuation drills for employees are conducted annually 
as well.  The facility is equipped with an  
emergency alarm that 
sounds throughout the facility to alert employees.  This alarm 
is tested regularly to ensure that it is operational and can be 
heard throughout the facility.  Occasionally drills are 
performed on-site in conjunction with the Toledo Fire Department 
Hazardous Materials Unit.  Perstorp Polyols also takes an active 
role in the Lucas County Local Emergency Planning Committee 
(LEPC).  Our participation in this group with emergency 
responders includes assisting in planning large-scale drills and 
public education of risks and emergency preparedness. 
Five-year accident history 
Perstorp Polyols is including data elements on two formaldehyde 
releases in the five-year accident history portion of this 
report.  The first release reported in this submission is a pump 
failure on June 13, 1997.  The release was contained on-site 
primarily to concrete and stone areas.  There was no off-site 
impact as a result of the release.  The release was reported to 
Ohio EPA, the National Response Center, the City of Toledo 
Division of Environmental Services, and the Lucas County LEPC.   
A containment area has been installed around the pump to prevent 
any future releases from spreading to the stone areas. 
The second release reported in this submission occurred in June 
and July of 1994.  A heat exchanger using water from the Ottawa 
River for non-contact cooling leaked and formaldehyde was 
released into the Ottawa River.  The leak was discovered on July 
7, 1994.  The river was depleted of dissolved oxygen as a result 
of the release, but recovered after the leak was repaired.  The 
City of Toledo Division of Environmental Services estimated the 
leak began on or about June 13, 1994.  No off-site injuries 
occurred and no evacuations were required.  A cooling tower was 
installed to provide non-contact cooling water and the use of 
river water was discontinued by March 1995. 
Perstorp Polyols has not had an accidental release of 
acetaldehyde within the past five years. 
Worst case release scenarios and alternative release scenarios 
Perstorp Polyols is submitting two situations that meet the EPA 
criteria for worst-case release scenarios.  One situation covers 
the storage of acetaldehyde and the second situation covers the 
storage of formaldehyde.  Perstorp Polyols is also submitting 
two situations that are required under EPA criteria for 
alternative release scenarios; one for acetaldehyde and one for 
formaldehyde.  All four situations have off-site impacts in that 
modeling indicates the impact will leave the facility property.  
Perstorp Polyols has used the EPA Off-site Consequences Analysis 
Guidance for modeling these situations.  Based on this guidance, 
none of the situations will have an impact on residential areas. 
Acetaldehyde is a clear, colorless liquid solution.  It has a 
pungent, fruity odor that can irritate the eyes, nose, and 
throat at low levels.  If released int 
o the air, acetaldehyde 
may form a vapor cloud that presents a fire or explosion hazard 
if not properly contained.  Perstorp Polyols stores acetaldehyde 
in pressurized tanks equipped with a nitrogen blanket to reduce 
the flammability of the vapor if released.  According to the EPA 
criteria for worst-case scenarios, Perstorp Polyols assumed that 
two interconnected storage tanks of acetaldehyde failed 
completely.  The resulting release would spill into a concrete 
secondary containment area.  The EPA criteria require us to 
assume that the tanks were 100% full and that entire amount 
would instantaneously vaporize and explode. 
The EPA criteria for alternative release scenarios require us to 
assume a more likely release situation.  The more likely 
situation chosen for acetaldehyde is a leak from a two-inch 
diameter unloading hose during transfer of acetaldehyde.  This 
situation was chosen because it had the furthest off-site impact 
of the more likely release situations  
analyzed.  The leak point 
is railroad unloading station near Dura Avenue.  The release is 
assumed to occur for 10 minutes.  A leak is unlikely to occur 
for longer than 10 minutes since an operator attends the 
unloading process at all times.  If a leak develops in this 
area, the operator would respond immediately to shutdown the 
unloading process and this action would stop the leak. 
Formaldehyde is a colorless liquid solution containing about 52% 
formaldehyde.  It has a pungent, irritating odor that can 
irritate the eyes, nose, and throat at low levels.  Formaldehyde 
is a material that auto-polymerizes; that means on standing in 
normal temperature formaldehyde solution forms a white solid 
called paraformaldehyde.  Under the EPA criteria for worst-case 
scenarios, Perstorp Polyols must assume one of the largest 
storage tanks of formaldehyde completely fails and the contents 
of the tank spill into a concrete secondary containment area.  
The formaldehyde is assumed to  
evaporate into a vapor cloud that 
may travel in any direction from the facility.  The secondary 
containment area will limit the surface area of formaldehyde 
available for evaporation to 4,540 square feet.  It is assumed 
that no actions by the plant operators is taken as the EPA 
criteria require us to assume that systems or personnel that 
could act to contain or stop the release fail to operate as 
designed or according to procedures.  
The EPA criteria for alternative releases allow evaluation of 
more likely release situations.  Perstorp Polyols has evaluated 
potential release situations and past accidents discussed in the 
five-year accident history section to determine the situation 
with the furthest off-site impact.  The alternative situation 
submitted for formaldehyde is a pump failure that causes a 
release in the concrete secondary containment area.  The 
modeling assumes the release occurs for 10 minutes and the total 
surface area covered by the release is 2,270 
square feet.  
Within 10 minutes, a plant operator will be able to shutdown the 
failing pump and isolate the storage tank or process flow to 
prevent additional leakage.  The operator would also take action 
to dilute the formaldehyde with water and reduce the amount of 
formaldehyde evaporation that would take place.  The operator 
would also begin to pump the material from the containment area 
into process tanks for reprocessing and reuse. 
Planned changes to improve safety 
Perstorp Polyols has a commitment to continuous improvement in 
the areas of safety, health and the environment.  This 
commitment is demonstrated in the semi-annual audits of our 
environmental management system by independent verifiers, the 
weekly safety and environmental training program for our 
employees, as well as our on going suggestion program for our 
employees.  The suggestion program gives our employees the 
opportunity to submit recommendations for changes with the 
plants or proc 
edures to improve safety, environmental 
protection, operational efficiency, and many other areas.  The 
next audit of our environmental management system is scheduled 
for October 1999.  Internal audits of our operations are on 
going throughout the year. 

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