Borden Chemical, Inc. Geismar Facility - 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, managing risks, and working 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. Emergency Response Polices states that safety is a top priority in all emergency situations. This policy refers to the plant's Emergency Response Plan for Specific procedures 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. 2. Worst-Case release scenarios and alternative release scenarios Worst Case Release Scenario Elemental chlorine is used as a treatment chemical in the process cooling tower system. The worst case scenario is if one of the one ton cylinders used to store this chemical leaked to atmosphere in a 10-minute period. Alternative Release Scenario - Formaldehyde As a result of loading product, a railcar is over-filled by 8,700 pounds. The formaldehyde product spills from a rail car to a containment area. Due to the low odor threshold of formaldehyde, the spill would be quickly discovered. The sump for the containment area w ould recover the free liquids into a storage tank. Alternative Release Scenario Chlorine Shortly after the installation of a new elemental chlorine tank someone notices that a connecting line to the process is leaking. This leak results in approximately 5 lbs. of chlorine being emitted to the atmosphere over a 10-minute period. Due to the extreme odor produced from chlorine, the leak would soon be discovered and repaired. 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 man agement control checksheet is used to verify that tasks are completed on schedule. The Plant Manager has overall 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 the Operating Guide as a training tool and for reference. By applying the guidelines of the operating procedures, accidental releases should be prevented. 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. If safe operating conditions cannot be maintained, an automatic shutdown system is in place that will shut down the plant before a release occurs. Change s 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 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. 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. 3. Five-year accident history There have been no accidents or releases that meet t he minimum reporting requirements set forth in the RMP regulations. 4. Emergency response program Borden Chemical, Inc. has a contractual agreement with Cura Environmental Services to provide a well-trained and equipped Emergency Response Team. Also, we are currently in negotiations with our neighbor, Borden Chemicals and Plastics, to provide emergency response assistance. 5. Planned changes to improve safety As this facility is new, there are no major planned changes to improve safety. |