Borden Chemical, Inc. - Moreau - Executive Summary |
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1. Accidental release prevention and emergency response policies This plant began its first operation in July 1998. Less than one year later, it was acquired by Borden Chemical, on May 12th, 1999. 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 for specific procedures for handling releases of hazardous materials. 2. Stationary source and regulated substances handled This plant produces formaldehyde, Urea-Formaldehyde Concentrate (UFC), and urea-formaldehyde resin for the forest products industry. The regulated substances used in the plant and the maximum quantities stored are: Formaldehyde (58% solution): 99,750 gal. UFC (30% solution): 99,750 gal. 3. Worst-case release scenarios and alternative release scenarios Worst Case Release Scenario The worst case release scenario chosen for formaldehyde is the rupture of a 58% formaldehyde solution storage tank, which could contain up to 320,000 lbs of a solution of formaldehyde 58%. From the pool that would result from the spill, 14.6 lbs/min. would evaporate. The distance to the EPA toxic endpoint of 0.012 mg/l is 0.26 miles. A dike around the tank farm is installed to reduce the offsite impact from such a spill. The spill would be contained by a dike, which is surrounding the storage tanks area. Alternative Release Scenario - Formaldehyde (Urea-formaldehyde concentrate, UFC) The alternative case release scenario chosen for this plant is a spill of 320,000 lbs of formaldehyde solution (UFC), which is the capacity of the largest storage tank. This could result from a leaking pipe, in which case a full storage tank would empty during the night. The quantity that would evaporate and go to the atmosphere is 14.6 lbs/min. The distance to the EPA toxic endpoint of 0.012 mg/l is 0.12 mile. This spill would be discovered soon by plant operator due to the formaldehyde odor. The tank level would also alert the operator, that something unusual is happening. The UFC storage tank is located in a tankfarm, surrounded by a dike; the spill would be contained. 4. Accidental release prevention program and chemical- specific prevention steps Borden has introduced 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. The Plant Manager has overall responsibility for this program. The responsibility to maintain operating procedures up-to-date is assigned to the production manager, as well as 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. An initial Process Hazard Analysis was conducted. As a result of this study, procedures were improved to prevent an accidental release. For the formaldehyde process and the urea-formaldehyde resin reactor, improved procedures reduce the risk of a release. A preven tive maintenance program maintains the mechanical integrity of process equipment. 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. Period ically, 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 Since the beginning of its operations in July 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 Saratoga 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. An emergency response drill is conducted annually to test the Emergency Response Plan and reinforce training. 7. Planned changes to improve safety A computer database program will be put in place to better serve the PSM requirements for preventative maintenance. |