BORDEN CHEMICAL, INC., SHEBOYGAN PLANT - Executive Summary |
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Executive Summary 1. Accidental release prevention and emergency response policies As stated in Borden's 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 Eme rgency 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 polyamide resins. The site includes two formaldehyde manufacturing units and four resin reactors. Although we sell some formaldehyde, it is primarily used on site as a raw material for resins. Aqua ammonia is used in small amounts as a raw material for urea-formaldehyde resins. It is purchased and received in tank trucks. Epichlorohydrin, used to make polyamide resins, is brought to site by rail. The regulated substances used in the plant and the maximum quantities stored are: - Formaldehyde solution 800,000 lbs. - Aqua Ammonia solution 21,000 lbs. - Epichlorohydrin 125,000 lbs. 3. Worst-case release scenarios and alternative release scenarios Worst Case Release Scenario Due to a process upset, formaldehyde liquid and vapor vents t hrough the installed rupture discs on a phenol-formaldehyde resin reactor. A total of 245 lbs. of formaldehyde is expelled to the atmosphere. The distance to the EPA toxic endpoint of 0.012 mg/L is 0.61 miles. The duration of exposure is 2.67 minutes. At this time, no administrative or mitigative controls are installed to limit the distance to toxic endpoint. However many controls are in place to prevent this release. For example, operators are trained to recognize conditions that may lead to a process upset and to take action to prevent one from occurring. As a further safeguard, a process control and shutdown system will take action if operator control is not effective. Alternative Release Scenario - Formaldehyde Alternative Case scenario is assumed to be the rupture of the largest formaldehyde storage tank (nominal capacity 16,000 gallons), with the contents spilling on to the ground and eventually leading either into the spill pit or wastewater holding area. A total of 14 6,000 lbs. of 50% formaldehyde solution is spilled. The distance to the EPA toxic endpoint of 0.012 mg/L is 0.09 miles. The amount evaporated during the 30 minutes it takes to put the release under control is 238 lbs. Alternative Release Scenario - Aqua Ammonia As a result of a hose failure, 2,000 gallons of aqua ammonia (28% ammonia solution) spills while a tank truck is being unloaded. From the resulting liquid pool, 753 lbs. of aqua 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. The spill is mitigated by the slope of the unloading area, which directs the spill into a trench and containment pit. Alternative Release Scenario - Epichlorohydrin As a result of a hose failure, 2,000 gallons of epichlorohydrin spills while a tank truck is being unloaded. From the resulting liquid pool, 155 lbs. of epichlorohydrin evaporates into the atmosphere. The distance to the EPA toxic endpoint of 0.076 mg/L is 0.06 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. The spill is mitigated by the slope of the unloading area, which directs the spill into a trench and containment pit, further mitigates it. 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 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. "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 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, 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, process engineer, and the plant manager. Tra ining 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 t o 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 preceding this report, there were no reportable off-site releases of regulated substances. 6. Emergency response program The plant has access to the Regional Hazmat Team which has a corps of trained emergency responders who can take prompt action if an accidental release occurs. The plant Emergency Response Plan describes procedures for actual and threatened releases, including coordination with fire department responders. This plan is drafted 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. |