Borden Chemical, Inc., Fayetteville Plant - 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 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 Emergen cy 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 and urea-formaldehyde resins, and hexamethylene tetramine (hexamine). The site includes four formaldehyde manufacturing facilities, five resin reactors, and a hexamine manufacturing facility. Although we sell some formaldehyde, it is primarily used on site as a raw material for both types of resins and hexamine. Anhydrous ammonia is a raw material used for hexamine, and is received in railcars. Aqua ammonia is used in small amounts as a raw material for both types of resins. It is received in tank trucks and reusable tote bins. The regulated substances used in the plant and the maximum quantities stored are: Anhydrous Ammonia, 260,000 lbs. Formaldehyde solution, 3,000,000 lbs. Ammonia solution, 22,500 lbs. 3. Worst-case release scenarios and alternative release scenarios Worst Case Release Scenario As defined in the EPA RMP regulations, it is assumed that the entire contents of the largest anhydrous ammonia tank is released to the atmosphere over a ten minute period. There are two 30,000 gallon pressurized tanks containing liquid anhydrous ammonia. Administrative controls limit the amount in each tank to 129,500 lbs. Therefore, it is assumed that one of these tanks containing a total of 129,500 lbs. of ammonia is released. The distance to the EPA toxic endpoint of 0.14 mg/l is 4.4 miles. At this time, no administrative or mitigative controls are installed to limit the distance to the toxic endpoint. However there are several controls in place to prevent this release. For example, each pipe connection to the anhydrous ammonia tanks, the connections on the incoming railcars, and the transfer pump are equipped with excess flow valves. These valves shut immediately upon an excess flow condition such as w ould be experienced if a transfer pipe broke. In addition, a guard rail exists along the plant roadway to prevent passing trucks from running into the storage tanks or transfer lines carrying anhydrous ammonia. The tanks themselves are constructed of solid welded carbon steel 1" thick. They are designed to withstand pressures up to 250 psig, well above the typical storage pressure of 80 - 150 psig. Even with this administrative control, the tanks are equipped with pressure relief valves which will vent excess pressure in a controlled manner if necessary. Alternative Release Scenario - Anhydrous Ammonia As a result of a vehicle accident, the transfer lines to the hexamine process and the railcar unloading lines are ruptured. All of the material in the pipelines will vaporize and vent to the atmosphere. A total of 940 lbs of ammonia is released to the atmosphere. The distance to the EPA toxic endpoint of 0.14 mg/l is 0.31 miles. The interruption in flow to the hexamine proce ss will result in an automatic, computer controlled shutdown of the hexamine process and ammonia delivery pump. Excess flow valves on the railcar and the storage tank will prevent any additional ammonia from escaping. Alternative Release Scenario - Formaldehyde As a result of a hose failure while unloading a railcar, 42,000 lbs. of formaldehyde spills in the railcar spill containment area and then drains to a concrete containment basin. From the resulting liquid pool, 53 lbs. of formaldehyde evaporates into the atmosphere. The distance to the EPA toxic endpoint of 0.012 mg/l is 0.17 miles. The spill would be discovered soon due to the formaldehyde odor, and the operation is monitored in a nearby control room via closed circuit television. After donning the appropriate protective chemical suit, the spill can be stopped by closing the valve on the railcar. The release is mitigated by the slope of the concrete unloading area, which directs the spill into a transfer trench and then into a containment basin. Alternative Release Scenario - Aqua Ammonia As a result of a hose failure, 6,000 lbs. of aqua ammonia (29% ammonia solution) spills while a tank truck is being unloaded. From the resulting liquid pool, 1250 lbs. of ammonia evaporates into the atmosphere. The distance to the EPA toxic endpoint of 0.14 mg/l is 0.31 miles. By procedure, the unloader remains by the truck during unloading and has a respirator. He can stop the unloading process by shutting off the pump and closing the truck discharge valve. It was assumed that it would take 2 minutes for the unloader to don the respirator and stop the spill. The spill is mitigated by the slope of the unloading area, which directs the spill into a trench and covered lift station. 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 Proc ess 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 check sheet 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 includ es 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. In the formaldehyde plant, automatic shutdown systems are being 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 takes 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. The anhydrous ammonia storage system was checked a gainst ANSI K61.1-1989 (Safety Requirements for the Storage and Handling of Anhydrous Ammonia) for compliance with accepted industry safety standards. 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 a 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 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 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 of regulated substances exceeding reporting requirments. There was a single onsite release of formaldehyde in June 1994 which resulted in federal and state notification under CERCLA. No material migrated offsite and no permanent environmental damage resulted. 6. Emergency response program The plant maintains a corps of trained emergency responders who can take prompt action if an accidental release occurs. This includes containment of spills and other releases. The plant Emergency Response Plan describes procedures for actual and threatened releases, including coordination with fire department responders. 7. Planned changes to improve safety The following work is planned to upgrade spill mitigation capability: 7 A remote acutated water fogging system will be evaluated for the anhydrous ammonia storage. This system will release a large quantity of water in fine droplets over the entire storage system in the event of a release from the storage tanks or transfer pump. The water will absorb the ammonia gas as it falls to the ground, significantly reducing the distance to the toxic endpoint. |