Borden Chemical, Inc. Diboll Plant - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

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 s 
pecific procedures for handling releases of hazardous materials.  
 
2. Stationary source and regulated substances handled 
 
This plant is a fully integrated facility, which produces formaldehyde, formaldehyde solutions, phenol-formaldehyde resins, urea-formaldehyde, and wax emulsions. 
 
The formaldehyde and formaldehyde solutions are used in a wide variety of chemical applications, as a building block for more complex chemicals.   The resins that are produced at this facility are used primarily in the manufacture of forest products and building materials.  These products include but are not limited to items such as particleboard, medium density fiberboard, plywood and oriented strand board (OSB).  Other resin uses include other building products such as fiberglass roofing shingles and fiberglass insulation. Wax emulsions are used as slip agents in the manufacturing process of building materials as well. 
 
The regulated substances used in quantities above the minimum thresholds are: 
 
Formal 
dehyde solution (50 %)  
Methylamine 
 
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 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 is 0.7 miles.  The duration of the exposure is 1.4 minutes. 
 
 
Alternative Release Scenario (Toxics)  
 
A shipment of formaldehyde has just arrived and is being prepared to be unloaded.  As a result of a hose connection failure the 45,000 lbs. of formaldehyde solution flows into the containment area.  The resulting formaldehyde release to the toxic end point of 0.012 mg/l  would be 0.10 miles.    
 
Worst Case Scenar 
io  (Flammables) 
 
Due to a hose failure while unloading a shipment of monomethylamine the entire contents is lost.  As a result, a vapor cloud explosion is triggered.  The distance to the end point limit of 1 psi overpressure is 0.20 miles. 
 
Alternative Release Scenario Flammables  
 
Due to a valving error on the bottom of the reactor the entire charge of monomethylamine is spilled to the containment area.  The resulting pool fire from the release would raeach the regulated endpoint of 5 kw/m2 at a distance of 0.05 miles. 
 
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 train 
ing 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 reviews, 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 p 
rocess 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 affected 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 releas 
es. 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 taken 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 recomme 
ndations from this audit keeps the safety program effective. 
 
5. Five-year accident history 
 
There have been no releases or accidents that meet the critera for the Risk Management Program within the last five years. 
 
6.  Emergency response program 
 
The plant operating staff is trained in Hazard Communication, First Aid, emergency response, and fire prevention procedures as a part of Borden Chemical's Safety Program.  In addition, Borden has a contractual agreement with an out-side environmental contractor 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. 
 
This Borden facility is located in a rural community whose fire department is staffed by volunteers.  Should a spill situation arise that is beyond the scope of this department, they may request assistance from the Lufkin fire department.  The Lufkin fire department maintains a well-trained an 
d equipped Hazmat team.  This team is available on a 24 hour, 7 day a week basis and is located within 10 miles of the facility. 
 
7.  Planned changes to improve safety 
 
No significant changes are planned at this time.
Click to return to beginning