Melamine Chemicals, Inc. - Executive Summary |
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Melamine Chemicals, Inc. LDEQ ID Number 2694 1. Accidential release prevention and emergency response policies. Melamine Chemicals, Inc., a subsidiary of Borden Chemical, Inc., is committed to maintaining a world-class health, safety and environmental system. The major focus is on excellence in operation and training of personnel to regulatory requirements. Safety, health and environmental concerns are a major consideration for all business activities. Personnel on site are required to comply with all applicable safety and environmental laws covering our facility. The corporate safety manual provides guidance for operation of the facility in a safe manner and emphasizes the importance and position of safe work practices in every day work activities. These procedures are also designed to help everyone conduct their work in a safe manner thereby reducing the potential for personal injury or accidential releases. Emergency response policies and corporate environmental policie s cover the procedures and methods to be imployed for handling releases of hazardous materials. 2. Stationary source and regulated substances handled Melamine Chemicals is engaged in the production of melamine crystal, a key component in melamine-formaldehyde resins. Two manufacturing units are on site. One unit uses low pressure (<90 psi) while the other production facilitie uses a high pressure process (2000 psi). Urea is imported via pipeline as the raw material. Ammonia is used and produced as a by-product in both processes. The regulated substances used in the plant and the maximum quantities present are: Ammonia (Anhydrous): 15,630 lbs in M-I or low pressure process. Ammonia (Anhydrous): 16,235 lbs in M-II or high pressure process. 3. Worst-case release scenarios and alternative release scenarios Worst Case Release Scenarios-Ammonia A total failure or rupture of the ammonia storage drum in the M-I process could cause the release of the drum content and amm onia from connected vessels. This release is calculated at 15,630 pounds of ammonia. In this particular release, the endpoint of the release is 2.13 miles. Alternative Release Scenario-Ammonia In this scenario, the assumption was made that facility personnel would not be able to stop a release from the Ammonia Drum due to a small crack in the vessel. Under normal operating conditions, the drum is never kept full, typically holding about 2000 pounds of ammonia. Based upon this volume with a crack area of 0.25 inches, the total release endpoint would be 0.35 miles. 4. Accidental release prevention program and chemical-specific prevention steps The Melamine facility has a very comprehensive process safety management program in place that complies with all the requirements of the EPA Accidential Release Prevention Rule, the OSHA PSM Standard and all applicable state codes and regulations. A well-defined safety and environmental system is in place to assure continued compliance. The system consists of detailed safety and environmental policies and procedures that are reviewed at least once a year. Updates can be initiated at any time. The facility also has defined safety responsibilities, monthly training sessions for all personnel and an internal audit system designed to periodically check on compliance requirements. The EHS & Quality Manager has overall responsibilities for maintaining the integrity of the safety and environmental programs. This position reports directly to the VP and General Manager of the complex. Two full-time safety personnel, in conjunction with operations and maintenance personnel and supervision, are assigned the responsibility to maintain and improve safety in all process units. Two individuals are assigned the responsibility to maintain an up-to-date operations manual and training program for operational personnel. Each module incorporates safe practices into the procedure. All employees undergo monthly safety training meet ings as well as periodic special safety training for selected personnel. Safety procedures, through a team effort, are reviewed prior to issue by management and hourly employees. Suggested revisions are incorporated prior to issuance of the final policy. Operations personnel job qualification testing protocol includes questions on safety related issues. New operators undergo extensive safety and environmental orientation and tours of the facilities to fully understand their responsibilities. Each operating unit has up-to-date operating procedures, designed to run the processes in an environmentally responsible manner and in a way to prevent accidental releases or injury to personnel. Process Hazard Analyses are conducted on an on-going basis to maintain a recognition of hazards and develop safeguards that will prevent accidental releases or injury to personnel. Recommendations resulting from the HazOp review have formed a continuous improvement activity list. All recommendation s are designed to produce a better operating and more safely run process. The Management of Change program at Melamine is more rigorous than requireed by PSM standards. As plant equipment is upgraded, various departments review the proposed change for safety and environmental impacts as well as potential to cause accidents or environmental releases. Any change requiring training is identified and the necessary training is implemented. The review process includes the upgrade of P&ID's. Where required, pre-start-up reviews are initiated. For several years, Melamine has implemented a preventive maintenance program. It is part of an extensive mechanical integrity process. A detailed history of work performed on all equipment is maintained on a computer database. Equipment identified for PM is automatically placed in the plant work order system when PM is to be performed. Daily printouts of work orders include PM work orders. At regular intevals, equipment is inspected, tested or serviced. All PM is designed to reduce the potential for accidential releases caused by equipment failure. Overall, the Mechanical Integrity program is designed to train, test and upgrade the quality of equipment operating at the facility. In addition to a comprehensive PM program, technicians servicing equipment are required to undergo training to better prepare them to do their jobs. This process not only extends the operating life of equipment but also assures a more safely operating facility. Work processes such as "hot work" have detailed permitting requirements designed to prevent injury to personnel, accidential releases or fires. The Lock out and Tag program addresses the isolation of equipment during maintenance activities. This procedure is designed to prevent the accidential release of material or injury to personnel working on the equipment. Resident contractors participate in all safety orientiations and training conducted by the Safety Department. Those contr actors who periodically conduct work on site are provided a safety orientation that briefs them on plant hazards and safety procedures. Contractors performing work on site are required to have a safety orientation card issued by the Baton Rouge Safey Council before being allowed to work on site. This is an additional safety precaution. Discussions with safety personnel from contractors are held regularly with resident contractors. Periodic contractors are required to have pre-job safety discussions. Any incident that results in a release is thoroughly investigated and corrective action implemented to prevent a recurrence. Recommendations could be one of any number of options which can include, more training, replacement of equipment or a change in operating procedure. Periodic audits are conducted both internally and by Borden Chemical safety professionals. Recommendations from these audits are implemented in order to continuously bring improvement to the safety efforts at Mela mine. 5. Five-year accident history In the five years from June 21, 1995 to June 21, 1999, there were no off-site releases that meet the criteria specified by 40 CFR section 68.42. 6. Emergency Response Program The facility maintains a number of trained emergency respondors who can take prompt action if an accidental release occurs. Thirty HazOp technians and fifteen support personnel have been trained. Procedures for handling emergencies are detailed in the facility Emergency Response Plan. The plan details collaboration with local fire departments, local sheriff personnel, state police and the Office of Emergency Preparedness. Our current plan is being revised to the "One Plan" format proposed by EPA. Changeover is expected within the next ninety days. Emergency response drills are conducted to test the integrity of the Emergency Response Plan and to reinforce training for plant responders. 7. Planned changes to improve safety A system of ammonia monitors will be ins talled to track concentration levels at the properly line. |