Borden Chemical, Inc. - Mount Jewett - 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 fo r specific procedures for handling releases of hazardous materials. 2. Stationary source and regulated substances handled This plant produces urea-formaldehyde resin for the forest products industry. The regulated substances used in the plant and the maximum quantities stored are: Formaldehyde solution (30%, as urea-formaldehyde concentrate or UFC): 900,000 lbs. Ammonia solution (29%): 67,000 lbs. Both raw materials are received in tank trucks, and the UFC solution is also received in tank cars. 3. Worst-case release scenarios and alternative release scenarios Worst Case Release Scenario The worst case release scenario chosen for formaldehyde is a spill from a tank car, which could contain up to 185,000 lbs of UFC. From the pool that would result from the spill, 2.7 lbs/min of formaldehyde would evaporate. The distance to the EPA toxic endpoint of 0.012 mg/m3 is 0.54 miles. Passive mitigation is installed to reduce the offsite impact from such a spill. The spill w ould be contained in a sump and from there would flow by gravity into the diked building area. The building is enclosed, which would further reduce the offsite impact. For the worst case scenario, the mitigation effect of being indoors was not considered because the spill would occur outside. Alternative Release Scenario - Aqua Ammonia The alternative release scenario chosen for ammonia is a spill occuring during tank truck unloading due to a hose failure. A 17,000 lbs spill of 29% ammonia solution was modeled. From the resulting liquid pool, 1,120 lbs of ammonia evaporate into the atmosphere. The distance to the EPA toxic endpoint of 0.14 mg/m3 is 0.31 miles. By procedure, the unloader remains by the truck during unloading and can stop the unloading process by shutting off the pump and closing the truck discharge valve. The unloading area is covered, and the storage tank is inside the main building. This wasn't taken into account for the calculations. Alternative Release Sc enario - Formaldehyde The alternative case release scenario chosen for this plant is a spill of 300,000 lbs of formaldehyde solution (UFC), which is the capacity of the largest storage tank. This could results from a leaking pipe, in which case a full storage tank would empty during the night. All tanks are located indoors, which reduces the amount released to the atmosphere. The quantity that would evaporate and go to the atmosphere is 260 lbs, estimated by calculation. The distance to the EPA toxic endpoint of 0.012 mg/m3 is 0.19 mile. This spill would be discovered soon due to the formaldehyde odor. The spill is mitigated by the building, the slope and the trench in that area. 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 regulatio ns. 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 Superintendant has overall responsibility for this program. The Plant Superintendant is responsible for 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. All employees participate in the safety program through team-based activities to improve safety and plant operation. The Plant Superintendent 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. 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 integri ty of process equipment. A computer database is used to manage the preventive maintenance schedule. Each month scheduled equipment inspections, tests, or servicing are performed. The schedule is based on plant experience and manufacturer's recommandations 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. 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 In the five years period from January 1, 1994 to December 31, 1998 there were no off-site releases of regulated substances. 6. Emergency response program The plant maintains a relationship with the Local Emergency Planning Committee of McKean County, which would provide help (if needed) during an emergency. 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. 7. Planned changes to improve safety No significant changes are planned at this time. |