Borden Chemical, Inc., Demopolis Plant - 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 for specific procedures for handling releases of hazardous materials. 2. Stationary source and regulated substances handled This plant makes formaldehyde solutions, phenol-formaldehyde resins, urea-formaldehyde resins, and ketone-formaldehyde resins. The site includes a formaldehyde manufacturing facility and two resin reactors. Although we sell some formaldehyde, it is primarily used on site as a raw material for both types of resins. Aqua ammonia is used in small amounts as a raw material for urea-formaldehyde resins. The regulated substances used in the plant and the maximum quantities stored are: Formaldehyde: 800,000 lbs. Ammonia: 20,000 lbs. 3. Worst-case release scenarios and alternative release scenarios Worst Case Release Scenario Due to a storage tank failure, formaldehyde solution spills onto the ground and forms a pool as it flows to the remote containment pit. The total liquid spill is 210,000 lbs. of formaldehyde solution. From this pool, 120 lbs. of formaldehyde evaporates to the atmosphere. The distance to the EPA toxic endpoint of 0.012 mg/l is 1.2 miles. Alternative Release Scenario - Formaldehyde As a result of a hose connection failure, 81,200 lbs. of formaldehyde solution spills in the railcar unloading area. From the resulting liquid pool, 130 lbs. of formaldehyde evaporates into the atmosphere. The distance to the EPA toxic endpoint of 0.012 mg/l is 0.25 miles. This is not as far as the worst case, because less conservative atmospheric conditions are modeled. Railcar unloading is monitored by plant personnel, so the spill would be discovered and stopped within 10 minutes. The release is mitigated by the slope of the rail unloading area, which directs the spill into a concrete trench system and containment basin. Alternative Release Scenario - Aqua Ammonia As a result of a hose connection failure, 550 lbs. of aqua ammonia (29% ammonia solution) spills while a tank truck is being unloaded. From t he resulting liquid pool, 125 lbs. of ammonia evaporates into the atmosphere. The distance to the EPA toxic endpoint of 0.14 mg/l is 0.19 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. For this alternative scenario, the spill would be stopped in 2 minutes. The spill is mitigated by the slope of the unloading area, which directs the spill into a trench and containment pit. 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 mainta in 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 overall responsibility for this program. "Process stewards" are assigned to maintain and improve the safety of their units. Their duties include 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 in their unit. All employees participate in the safety program through team-based activities to improve safety and plant operation. Each Process Steward 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 haz ard 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. For the phenol-formaldehyde resin process, an automated control system will take a several levels of action to prevent a release upon operator error or equipment failure. 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, proc ess 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 integrity 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 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 lik elihood 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 year period from January 1, 1994 to December 31, 1998 there were no off-site releases of regulated substances. 6. Emergency response program The plant Emergency Response Plan describes procedures fo r 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 that plant responders receive. 7. Planned changes to improve safety No significant changes are planned. |