Borden Chemical, Inc. - Executive Summary |
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Executive Summary 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 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 melamine -formaldehyde resins. The site includes five resin reactors for resin manufacture. Formaldehyde is imported by truck and used on site as a raw material for resin. The maximum quanities of formaldehyde stored are: Formaldehyde Solution (55%) 135,000 lbs. Formaldehyde Solution (37%) 338,500 lbs. 3. Worst-case relase scenarios and alternative rease scenarios Worst Case Release Scenario A failure of a 15,000 gallon tank containing 55% formaldehyde occurs, releasing 132,600 lbs. of formaldehyde solution. A total of 26 lbs. of formaldehyde is expelled to the atmosphere over a 10 minute period. The distance to the EPA toxic endpoint of 0.012 mg/l is 0.5 miles. The entire contents of the tank would be contained in a 87ft. by 40 ft. concrete diked area. This reduces the liquid pool surface area, limiting the distanc e to the toxic end point. Alternative Relase Scenario - Formaldehyde As a result of a hose connection failure on the bottom outlet of a the tank truck, 665 gallons of 55% formaldehyde solution spills in the truck unloading area. The unloading area is a concrete slab surrounded on all sides by a concrete drain trench leading to a 15' 7" square impoundment basin. All formaldehyde spilled is capture either on the slab or in the trenches and impoundment basin. From the resulting liquid pool, 26lbs. of formaldehyde evaporates into the atmosphere. The distance to the EPA toxic endpoint of 0.012 mg/l is 0.11 miles. The truck unloading operation is attended. Personal protective equipment is available in the shipping office near the unloading area. It would take approximately 2 minutes for the attendant to put on the necessary protective equipment and shut off the flow. An emergency pump stop switch is located in the shipping office. Stainless steel braided hoses are used with cam locks and velcro straps in the unloading process to minimize the risk of a hose failure. 4. Accidental relase prevention program and chemical - specific prevention steps This plant has a comprehensive process safety management program that is 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 overall responsibility for this program. Lead Operators are responsible for maintaining and improving the safety of their shifts. Their duties include keeping operating procedures up-to-date, training operators so they can safel y carry out these procedures, assuring that the plant is run safely on a daily basis and when necessary, investigating incidents in their shift. All employees participate in the safety program through team-based activities to improve safety and plant operation. The Safety and Training Specialist 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 to improve process safety. A Nitrogen blanket system was installed for several reactors which produce resins using flammable solvents. This minimizes the possibility of a fire or explosion during the manufacturing process. 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 it's 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 to 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 au dit of the safety program. Addressing recommendations from this audit keeps the safety program effective. 5. Five-year accident history There have been no reportable accidents or off-site releases of regulated substances in the last five years. 6. Emergency Response Program The plant Emergency Response Plan describes procedures for actual and threatened releases, including coordination with the Morganton Fire Dept. and Burke County Hazmat 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 for various scenarios including evacuation. 7. Planned changes to improve safety We are investigating further automation using fail closed valving, monitoring devices and programming to further reduce the chance of an accidental release. |