Borden Chemical, Inc., PMC 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 The Dallas plant makes melamine-formaldehyde resins and urea-formaldehyde resins. The site includes a tank farm for storage of formaldehyde (50% solution), anhydrous ammonia and melamine-formaldehyde resin as well as eight reactors for the production of the resins. Seven of the reactors are non-pressurized kettles and one is a pressure vessel. Anhydrous ammonia is used as a neutralizer for formaldehyde in our exhaust air from the manufacturing process. Formaldehyde and anhydrous ammonia are purchased and received in tank trucks. The regulated substances used in the plant and the maximum quantities stored are: Formaldehyde solution (50%), 550,000 lbs. Anhydrous Ammonia 50,000 lbs. 3. Worst-case release scenarios and alternative release scenarios Worst Case Release Scenario - Anhydrous Ammonia Due to a catastrophic event the anhydrous ammonia tank ruptures. A total of 50,000 lbs. of anhydrous ammonia (NH3) is expelled into the atmosphere. The distance to the EPA toxic endpoint of 0.14 mg/L (200ppm) is 2.5 miles. At this time, no administrative or mitigative controls are installed to limit the distance to toxic endpoint. However we have taken measures to monitor and maintain the mechanical integrity of the anhydrous ammonia storage tank along with the associated valves and piping. The storage tank was tested by the NH3 Team, Inc. an outside firm specializing in the testing and handling of anhydrous ammonia tanks on September 11, 1998. The tank passed a 400 psi hydrostatic test and ultrasonic thickness measurement showed no sign of any major tank wall thickness deterioration. Relief valves were also replaced. Audio, olfactory and visual checks of the anhydrous ammonia tank along with valves and associated piping are made every four hours during normal operations. Operators are trained to recognize conditions that may lead to a release and to take action to prevent one from occurring. Alternative Release Scenario - Anhydrous Ammonia As a result of the failure of a joint in exterior ammonia piping, ammonia liquified under pressure is released to the atmosphere through a .25 inch orifice. This liquid vaporizes immediately, releasing 1,000 pounds of ammonia. The distance to the EPA toxic endpoint of 0.14 mg/Liter is 0.1 mile. Alternative Release Scenario - Formaldehyde As a result of a hose failure, 415 gallons of 50% formaldehyde solution spills in the tank truck loading area. From the resulting liquid pool, 290 lbs. of formaldehyde evaporates into the atmosphere. The distance to the EPA toxic endpoint of 0.012 mg/Liter is 0.31 miles. The spill would be discovered soon due to the formaldehyde odor. By procedure, the unloader remains by the truck during unloading and can stop the unloading process. The spill is mitigated by the slope of the unloading area, which directs the spill into a co ntainment berm. 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 Borden 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. A "Process steward" is assigned to maintain and improve the unit's safety. His 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 bas is, 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. The 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 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 in process control systems. 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. 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. Th ese 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 year period from January 1, 1994 to December 31, 1998 there were no off-site releases from covered processes that resulted in deaths, injuries, or significant property dama ge on site; or known offsite deaths, injuries, evacuations, shelterning in place, property damage, or environmental damage. 6. Emergency response program The plant does not maintain a corps of trained emergency responders, but relies on the Dallas Fire Department to provide emergency assistance. 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. 7. Planned changes to improve safety None planned |