Borden Chemical, Inc. Hope Plant - Executive Summary |
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1. Accidental release prevention and emergency response polices 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 is Emergency Response Polices that states that safety is the top priority in all emergency response situations. This policy refers to the plant's Emergency Response Plan for sp ecific procedures for handling releases of hazardous materials. 2. Stationary source and regulated substances handled This plant is a fully integrated facility, which makes phenol-formaldehyde resins, urea-formaldehyde, formaldehyde and petroleum wax emulsions. Formaldehyde has a wide variety of uses as a feedstock for many chemical products as well as the resins that we produce onsite. The resins are primarily used in manufacture of forest products such as particleboard, medium density fiberboard, plywood and oriented strand board. Other resin uses include other building products such as fiberglass roofing shingles and fiberglass insulation. 3. Worst-Case release scenarios and alternative release scenarios Worst Case Release Scenario (Toxics) Temperature controls fail 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 re actor 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 is 2.0 miles. The duration of the exposure is seven minutes. We believe that this distance is conservative for two reasons. First, the amount of formaldehyde in the reactor at the time of a release is expected to be lower than the amount used in the model. Second, the model assumes that formaldehyde will be released at ground level, when it is actually released 30 feet in the air, which will aid dispersion. Detailed safeguards are in place to prevent a release from the resin reactor, constraints on resin manufacturing procedures, automatic process controls, a quench system, preventive maintenance, and operator training. Alternative Release Scenario (Toxics) As a result of a bottom unloading valve failure, 5,000 gallons of formaldehyde spills from a truck, which is waiting to b e unloaded. This formaldehyde flows via a slopped concrete pad into the dike formaldehyde storage tank area. The distance to the toxic endpoint of 0.12 mg/l is 0.10 miles. Due to the low odor threshold of formaldehyde, the spill would be quickly discovered. 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 monthly Health, Safety, & Environmental Steering Committee meetings, 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 operation procedures up-to-date; training operating technicians so they can safely follow theses 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, equipment information, process safety information, mechanical integrity information, and a training certification program. Operating technicians use this Operating Guide as a training tool and for reference. By applying the information it contains their actions prevent accidental releases. Process hazard analyses are conducted to identify hazards and recommend safeguards that prevent a release. As a result of initial process hazard review s, a significant investment was made in process control systems. Several control interlocks are installed to insure safety, including an automatic deluge system for phenolic resin production. Should a batch become unstable, this system floods the reactor with water, diluting the reactants while removing excess heat. It operates either automatically based on control system monitoring of the process, or manually by the technician. 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. New capital equipment is reviewed as part of the Investment Proposal system. This review may include a process hazard analysis or other safety reviews. Changes to product formulations initiate a review by a regulatory affairs specialist, a formulation chemist, a process engineer, and the plant manager. Training is then performed as needed to assure that those af fected by the change understand its impact. In addition, 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. Periodically, 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, and may include weekly, monthly, quarterly, and yearly inspections and maintenance. 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 Hot Work Permit system to reduce the risk of fire. The Safety Manual also includes requirements for locking out and tagging out equipment for maintenance. These procedures reduce the likelihood that a valving error will lead to a release. Contractors who perform work in the plant are given safety orientations on plant hazards and safety practices. Contractor safety programs and performance are evaluated prior to their selection for jobs that impact process safety using the Contractor Screening Form. Incidents that cause or could have caused a release are investigated and their root cause determined. Actions are taking to prevent recurrence. These actions may include improvements in equipment, procedures, operating conditions, or training. Periodically a safety professional from another Borden Chemical location conducts a comprehensive audit of the safety program. Addressing recommendations from this audit keeps the safety program effective. 5. Five-year accident history There have been no accidents or release, which meet the minimum reporting requirements set forth in the RMP regulations. 6. Emergency response program The plant opera ting staff is trained in Hazard Communication, First Aid, and fire prevention procedures as a part of Borden's Safety Program. In addition, Borden has a contractual agreement with an outside service provider, to provide a well-trained and equipped Emergency Response Team should an upset condition exceed the capabilities of plant personnel. This team is available on a 24 hour, seven day a week basis. 7. Planned changes to improve safety No significant changes planned at this time. |