BORDEN CHEMICAL, INC., SPRINGFIELD PLANT - Executive Summary |
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1.Accidental release prevention and emergency response policies As stated in our Worldwide Health, Safety, and Environmental Policy and Principles, Borden Chemical, Inc. is committed to health, safety, and environmental excellence. To accomplish this we integrate health, safety, and environmental planning into all business activities. This includes complying with applicable laws, responsibly managing risks, and working collaboratively with others in addressing health, safety, and environmental issues. In the Borden Chemical, Inc. Safety Manual, the Safety Policy Statement clearly states that safety will not be compromised to achieve any other operational or business objective. This manual defines requirements and guidelines developed to prevent injuries and accidental releases. Included in the Safety Manual are Emergency Response Policies that state that safety is the top priority in all emergency response situations. This policy refers to the plant Emergency Response Plan for specific procedures for handling releases of hazardous materials. 2.Stationary source and regulated substances handled This plant primarily makes formaldehyde solutions, phenol-formaldehyde resins, and urea-formaldehyde resins. The site includes two (2) formaldehyde manufacturing facilities, two (2)Urea-Formaldehyde/Melamine-Formaldehyde Resin Reactors, one (1) Polyamide/Urea-Formaldehyde/Ketone-Formaldehyde Resin Reactor and three (3) Phenol-Formaldehyde Resin reactors. Although we sell some formaldehyde, it is primarily used on site as a raw material for various types of resins. Aqua ammonia and Epichlorohydrin are used in small amounts as a raw material for urea-formaldehyde resins and polyamide resins, respectively. The regulated substances used in the plant and the maximum quantities stored are: Formaldehyde 1,123,000 lbs. Ammonia 27,000 lbs. Epichlorohydrin 79,000 lbs . 3.Worst-case release scenarios and alternative release scenarios Worst Case Release Scenario As a result of a catastrophic tank failure, Formaldehyde (51.5%) water solution spills onto the ground. A total of 493,340 lbs. of Formaldehyde is released. The distance to the EPA toxic endpoint of 0.012 mg/L (10 ppm) is 0.74 miles. The spill is directed to remote containment with diking, sloping, trenching, and berming to limit the distance to toxic endpoint. Many other controls are in place to prevent this catastrophic release from occuring. Routinely, Operations and Maintenance perform inspections to identify conditions that may lead to a storage tank failure. As a further safeguard, a preventive maintenance program is in place to inspect the integrity of the tank and prevent a catastrophic tank rupture. Inventory checks, department safety checks, and a computerized maintenance work order system are also ot her facility work practices that are in place to prevent this worst-case release scenario. Alternative Release Scenario - Formaldehyde Temperature control fails while making a batch of phenol-formaldehyde resin. As a result, the heat of reaction boils the reactor contents until the pressure reaches 5 psig, when the installed rupture discs burst. Pressure inside the reactor forces vapor and liquid through the rupture disc vent piping, discharging water vapor, formaldehyde vapor, and liquid resin into the atmosphere. The distance to the EPA toxic endpoint of 0.012 mg/L ( 10 ppm) is 0.39 miles. The duration of the exposure above 10 ppm at any distance from the reactor is predicted to be less than two minutes. .... . The model assumes that all of the formaldehyde expelled from the reactor stays coupled with the liquid and falls to earth. However, it is believed that s ome of the formaldehyde dissipates in the atmosphere without coming back to the ground. Many computerized process safety controls are in place to limit the offsite consequence of this release. Operators are trained to recognize conditions that may lead to a process upset and to take action to prevent one from occuring. Computerized process controls and shutdown systems will activate if operator control is not effective. Alternative Release Scenario - Aqua Ammonia As a result of a tank leak, 10,000 gallons of aqua ammonia (29% ammonia solution) spills into a diked area. From the resulting liquid pool, 21,740 lbs. of ammonia evaporates into the atmosphere. The distance to the EPA toxic endpoint of 0.14 mg/L is 0.19 miles. By procedure, the tank truck driver and shipping personnel remain in attendance at all times during loading/unloading operations. A spill would be discovered soon due to the driver and shipper proximity to the operations and the Aqua Ammonia odor. Tank truck valves can be closed and transfer pumps can be shut-off to stop the spill. The release is mitigated by the diked containment area. Many other controls are in place to prevent this release. Routinely, Operations and Maintenance perform inspections to identify conditions that may lead to a storage tank failure. As a further safeguard, a preventive maintenance program is in place to inspect the integrity of the tank and prevent a catastrophic tank rupture. Inventory checks, department safety checks, and a computerized maintenance work order system are also other facility work practices that are in place to prevent this aternative release scenario. Alternative Release Scenario - Epichlorohydrin As a result of a tank leak, 8,000 gallons of epichlorohydrin spills into a diked area. From the resulting liquid pool, 78,635 lbs of epichlorohydrin evaporates into the atmosphere. The distance to the EPA toxic endpoint of 0.14 mg/L is 0.06 miles. By procedure, the tank truck driver and shipping personnel remain in attendance at all times during loading/unloading operations. A spill would be discovered soon due to the driver and shipper proximity to the operations. Tank truck valves can be closed and transfer pumps can be shut-off to stop the spill. The release is mitigated by the diked containment area. Many other controls are in place to prevent this release. Routinely, Operations and Maintenance perform inspections to identify conditions that may lead to a storage tank failure. As a further safeguard, a preventive maintenance program is in place to inspect the integrity of the tank and prevent a catastrophic tank rupture. Inventory checks, department safety checks, and a computerized maintenance work order system are also other facility work practices that are in place to prevent this aternative release scenario. . 4.Accidental release prevention program and chemical-specific prevention steps This plant has a comprehensive process safety management program that is in compliance with the EPA Accidental Release Prevention Rule, the OSHA Process Safety Management Standard, and all applicable state codes and regulations. A safety management system is in place to assure on-going compliance. This management system includes the Safety Manual, a list of site safety responsibilities, a file system to maintain records of compliance, and a monthly Safety Committee meeting, where a management control checksheet is used to verify that tasks were completed on schedule. The Plant Manager has overall responsibility for this program. "Process stewards" are assigned to maintain and improve the safety of their units. Their duties include keeping operating procedures up-to-date, training operators so they can safely carry out these procedures, assuring that the plant is run safely on a daily basis, and when necessary, investigating incidents in their unit. All employees participate in the safety program to improve safety and plant operation. Each Process Steward maintains an Operating Guide that includes process safety information, operating procedures, and a training certification program. Operators use this Operating Guide as a training tool and for reference. By applying the information it contains their actions will prevent accidental releases. Process hazard analyses are conducted on an on-going basis to identify hazards and recommend safeguards that will prevent an accidental release. As a result of initial process hazard reviews, a significant investment was made in process control systems. In the formaldehyde plant, an automatic shutdown system is installed that will shut down the plant before a release occurs if safe operating conditions cannot be maintained. For the phenol-formaldehyde res in process, an automated control system will take several levels of action to prevent a release upon operator error or equipment failure. For the urea-formaldehyde resin reactor, improved procedures reduce the risk of a release. Two methods are used to assure that changes to plant equipment, procedures, or processes do not cause accidents. For equipment and procedure changes, a Change Worksheet initiates a safety review. This review may include process hazard analysis. Changes to product formulations initiate a review by a chemist, process engineer, and the plant manager. Training is performed as needed to assure that those affected by the change understand its impact. Pre-Start-up Safety Reviews are performed to assure that the plant can be started up safely after a significant change is made. A preventive maintenance program maintains the mechanical integrity of process equipment. A computer database is used to manage the preventive maintenance schedule and other corrective or improvement repairs necessary to maintain the ongoing integrity and reliability of the facility equipment. Each month scheduled equipment inspections, tests, or servicing are performed. The schedule is based on plant experience to reduce the likelihood of an accidental release caused by equipment failure The requirements in the Safety Manual include safe work practices which prevent accidental releases. One important section describes safety measures for welding or other "hot" work, which includes a permit system to reduce the risk of fire. The Safety Manual also includes requirements for locking out equipment for maintenance. These procedures reduce the likelihood that a valving error will lead to a release. Contractors, who periodically perform work in the plant, are given safety orientations to brief them on plant hazards and safety practices. Contractor safety programs and performance are evaluated prior to their selection for jobs that impact process safety. Incidents that cause or could have caused a release are investigated and recommendations are made to prevent recurrence. These recommendations may lead to improvements in equipment, procedures, operating conditions, or training. Internal Corporate Health, Safety and Environmental Audits are conducted periodically to maintain compliance with local, state and federal regulations. Regional Safety and Environmental professionals periodically review the health,safety, and environmental programs. Addressing recommendations from these audits and reviews keeps the Facility's Safety and Environmental programs effective. 5.Five-year accident history In the five year period from January 1, 1994 to June 1, 1999 there were no deaths, inuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage as a result of an accidental release of a regulated substance from our processes . 6.Emergency response program The plant Emergency Response Plan describes procedures for actual and threatened releases, including coordination with fire department responders. This plan is written in the "One Plan" format to satisfy regulatory requirements of several agencies. An emergency response drill is conducted annually to test the Emergency Response Plan and reinforce training that plant responders receive. 7.Planned changes to improve safety The following work is planned to upgrade spill mitigation capability: 7 Dikes will be added around the Formaldehyde tanks to reduce the size of a potential spill at tank truck loading and unloading stations. |