Borden & Remington - Executive Summary |
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What are the RMP listed chemicals on site that are above thresholds found in Sec. 68? Anhydrous Ammonia Ammonia Solution above 19% Formaldehyde 37% Oleum Hydrofluoric Acid 70% What are the production units on site where each chemical is used? There are 3 production units that facilitate listed chemical use. They are; The Aqueous Ammonia Production unit where Anhydrous Ammonia and Ammonia Solution > 19% are used, the Dispersant Production Unit where Oleum and Formaldehyde are used and the Chemical Distribution production unit where Hydrofluoric Acid, Formaldehyde and Ammonia Solution are used. The Aqueous Ammonia Production Unit produces 29% Ammonium Hydroxide by mixing Anhydrous Ammonia with de-ionized water. The Dispersant Production Unit produces a dispersant which is used as a super plastisizer in concrete. Textiles also use the dispersant to disperse various pigments ancillary to the preperation of dyes. The Chemical Distribution Production Unit facilitates the distribut ion chemicals to industry and municipalities. It does not manufacture chemicals. The Chemical Distribution Production Unit procures chemicals from other manufacturers, stores the chemicals, in some cases re-packages the chemicals and then distributes them to the market place. Has process safety information been compiled for each chemical? Borden & Remington has assembled process safety information as required by 40 CFR 68.65 for each of the RMP regulated chemicals on site. The safety information includes offsite consequence analysis where theoretical worst case and alternative case chemical release migrations were plotted. The information was utilized by the different Process Safety Teams to conduct process hazard analyses for the production unit specific to the listed chemicals. The process safety information is reviewed on an annual basis and annotated if the information changes. Have Process Hazard Analyses been completed and subsequent recommendations developed? Borden & R emington has completed comprehensive Guide Word Hazard Operability Process Hazard Analyses for the production units that use listed chemicals above thresholds found in Sec. 68. Piping and instrument diagrams and other safety information were used to consider deviations from design intention. Consequence, cause and existing safeguards and their corresponding level of risk were considered when developing recommendations to reduce risk. A number of recommendations have been chosen as action items and a schedule has been developed to implement the same. Have operating procedures been developed/updated for processes utilizing the listed chemicals? Borden & Remington has developed standard operating procedures(SOPs) for every process performed by its employees. The company is ISO 9001 and ISO 9000 certified and as such has a management system in place to maintain the standard operating procedures. The SOPs for PSM and RMP listed chemicals have been updated to include safety information and warnings at crucial steps within the process. The "crucial steps" are those that the process hazard analyses have identified as intrinsically risky. If possible crucial steps have been modified or eliminated. The updated SOPs work to reduce risk through modified standardized methodologies. Do employees receive adequate training in the SOPs for RMP regulated chemicals? As of June 21, 1999 all Borden & Remington employees that work within the RMP regulated production units have been certified to posses the required knowledge, skills and abilities to safely carry out their duties and responsibilities. Borden & Remington has in place a training program that ensures that each employee is given refresher training every 3 years. Does Borden & Remington have a Preventative Maintenance Program in place that will ensure the mechanical integrity of the equipment used in the RMP regulated production units? The Preventative Maintenance Program in place at Borden & Remington requires weekly ins pection of each process unit by a licensed plumber and electrician. Maintenance inspection logs are completed on a weekly basis. Cursory inspections are performed daily by operating personnel. All storage tanks, reactors and piping comply with API and ASME standards. Vessels and piping are tested periodically as recommend by the manufacturer. The management of the Preventative Maintenance Program is achieved by the ISO 9000 procedures in place. Does the Company have in place procedures that ensure changes in process and new processes are managed safely? Management of Change and New Process Review is achieved through Borden & Remington's ISO 9001 Management Program. A system exists where technical and administrative approvals are required before a process change or new process is initiated. Have there been any reportable incidents within the last 5 years involving any RMP listed chemicals? No. Does the Company audit compliance with the its RMP ? Borden & Remington has integrated into its monthly environmental health and safety audits the components of its Program 3 RMP. The audits include line items that; 1) ensure that RMP regulated processes have not changed without proper review and annotation to process safety information 2) Process Hazard Analyses are updated as new information becomes available 3) operating procedures are reviewed every 11 months, preventative maintenance program is on going 4) Mamagememnt of Change Program is being complied with 5) Incident Investigation protocol is being followed 6) employee participation in the RMP continues 6) Hot Work Program procedures are complied with 7) Contractor Control Program is on going 7) accepted recommendations are being implemented within the planned timed period. Does the Company have a standard operating procedure for effectively investigating incidents? The Environmental Health and Safety Director(EHSD) is responsible for conducting, or appointing a team to conduct, comprehensive investigations i nto the root cause of an incident involving a release of a chemical and or deviation of a production unit in design intent.. Once the root cause is established, recommendations addressing the root cause are proposed by the investigating team. The EHSD implements accepted recommendations. The investigation criterion remains consistent as the team must complete the Borden & Remington Incident Investigation Form. Does the Company solicit it's employee's ideas relevant to process safety? The RMP was developed with input from administrative management, operations management and operating personnel. A team of Borden & Remington employees has assessed each regulated production unit. The teams are comprised of employees from every level of the Company's hierarchy. Employee input continues to be an invaluable component of Borden & Remington's Risk Management Program. The assessment teams will conduct annual reviews of the process safety information and the viability and progress of ongoing goals and programs. Does the Company have in place effective safeguards for personnel working with welding equipment? Borden & Remington has designated certain areas in which welding and other work involving ignition sources (Hotwork) may be performed. Any hotwork necessary outside of the designated areas must follow the policies and procedures of Borden & Remington's Hotwork Program. The Hotwork Program requires a permit to be completed. The permit is used as a control mechanism to ensure that the employee/s performing the hotwork have the right equipment, knowledge and procedures in place to perform their job safely. Does Borden & Remington have controls in place to ensure that contractors entering upon the site and or work on RMP regulated production unit are sufficiently trained as to the hazards of the production units? Borden & Remington restricts access to the regulated production units by unauthorized personnel and contractors. Authorization for access is given only after the hazards and emergency procedures are conveyed to the contractor. The contractor is required to sign an affidavit stipulating their awareness of the hazards and procedures. Production unit egresses are posted "Warning: Chemical Hazards! Access to this Building is Restricted to Authorized Personnel Only!" Contractors are chosen in accordance with Borden & Remington's ISO procedures. The criterion for contractor selection within the ISO procedures include the Contractor's level of HAZMAT training, safety record and quality control system. What steps is Borden & Remington taking to minimize the risk at its facility? Borden & Remington has prioritized the recommendations derived from the RMP process. A high priority action item is the installation of a deluge system to decrease significant migration in the event of an anhydrous ammonia release. Also included in Borden & Remington's recommendation implementation schedule are the installation of ultrasonic high level alarms, i ncreased containment and the incorporation of redundant checks within existing standard operating procedures. Borden & Remington has embraced the RMP and integrated it into the culture of the Company. It is this mindset that will result in the continued diligence towards the maintenance and improvement of the Company's Risk Management Program and subsequent lower risk to the environment and the community. As time passes the components of the RMP, i.e Contractor Control, Hot Work Program etc., will become stronger and more effective as they are reviewed and revised. It is Borden & Remington's commitment to facilitating the evolution of an ever-improving RMP that is the catalyst that will result in the significant and permanent reduction of risk. |