Borden Chemical, Inc. Geismar Facility - Executive Summary |
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1. Accidental relase 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 environnmental excellance. 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 collagoratiely 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. The manual defines requirements and guidelines developed to prevent injuries and accidental releases. Included in the Safety Manual are Emergency Response Polices that state that safety is a top priority in all emergency situations. This policy refers to the plant's Emergency Response Plan for Specific proc edures for handling releases of hazardous materials. This plant manufactures formaldehyde solutions. The facility has the capability of producing products ranging from 30 to 50 percent formaldehyde; the balance of the solution is water. The regulated substance used in the plant and the maximum quantities stored are: ? Formaldehyde solutions as (50%) 3,850,000 lbs. 3. Worst-Case release scenarios and alternative release scenarios Worst Case Release Scenario Due to a rupture in a formaldehyde storage tank, 80,000 gallons of 50%formaldehyde solution spills into the diked storage area as well as the impoundment area. The distance to the EPA toxic endpoint of 0.012 mg/l is 1.5 miles. The area around the tank farm is diked and trenched in a manner that directs spills and tank overflows into a recovery storage tank, also known as the dilute tank, without human intervention. offsite disposal with minimal equipment of setup time. Alternative Release Scenario - Formaldehyde As a resu lt of over-filling a railcar 8,700 pounds of formaldehyde spills from a rail car, that is in the process of being loaded for shipment. Due to the low odor threshold of formaldehyde, the spill would be quickly discovered. The sump for the containment area would quickly recover the free liquids into a storage tank. 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 over all responsibility for the safety program. All employees participate in the safety program through team-based activities to improve safety and plant operation. The plant manager 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. Changes to plant equipment, procedures, or processes are reviewed using a process hazard analysis. 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 the process equipment. Each month scheduled equipment inspections, tests, or preventive maintenance are performed. The schedule is based on plant experience to reduce the likelihood of an accidental release caused by equipment failure. An electronic database is used to document these inspections as well as provide useful information for continuous improvement of equipment reliability and performance. 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 l ocking 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. 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. 4. Five-year accident history There have been no accidents or releases which meet the minimum reporting requirements set forth in the RMP regulations. 6. Emergency response progra m Borden has a contractual agreement with Cura Environmental Services to provide a well-trained and equipped Emergency Response Team. 7. Planned changes to improve safety None planned at this time as the facility is new. |