| Accident History | Chemicals | Emergency Response | Registration | Source | 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 Emergency 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, and urea-formaldehyde resins.  The site includes a formaldehyde manufacturing facility and three resin reactors.  Although we sell some formaldehyde, it is primarily used on site as a raw material for both types of resins.  Aqua ammonia is used in small amounts as a raw material for urea-formaldehyde resins.  It is purchased and received in tank trucks. 
The regulated substances used in the plant and the maximum quantities stored are: 
Formaldehyde                 2,350,000 lbs. 
Ammonia                            28,000 lbs. 
3.Worst-case release scenarios and alternative release scenarios 
Worst Case Release Scenario 
As a result of a catastrophic tank failure, Formaldehyde (50%) water solution spills onto the ground.  A total of  470,638 lbs. of Formaldehyde is released.  The distance to the EPA t 
oxic endpoint of 0.012 mg/L (10 ppm) is 0.68 miles. 
The spill is directed to remote containment with sloping, trenching, and berming to limit the distance to toxic endpoint.  Many other controls are in place to prevent this release.  For example, operators are trained to recognize conditions that may lead to a storage tank failure and to take action to prevent one from occurring.  As a further safeguard, a preventive maintenance program is in place to inspect the integrity of the tank and prevent a catastrophic tank rupture.  Inventory checks, department safety checks, and a computerized maintenance work order system are also other facility work practices that are in place to prevent this worst-case release scenario. 
Alternative Release Scenario - Formaldehyde 
Temperature control fails while making a batch of phenol-formaldehyde resin.  As a result, the heat of reaction boils the reactor contents until the pressure reaches 5 psig, when the installed rupture discs burst.  Pressure in 
side the reactor forces vapor and liquid through the rupture disc vent piping, discharging water vapor, formaldehyde vapor, and liquid resin into the atmosphere.  The distance to the EPA toxic endpoint of 0.012 mg/L ( 10 ppm) is 0.34 miles.  The duration of the exposure above 10 ppm at any distance from the reactor is predicted to be less than two minutes.                                                                                                          ....            .  
The model assumes that all of the formaldehyde expelled from the reactor stays coupled with the lqiuid and falls to earth.  However, it is believed that some of the formaldehyde dissipates in the atmosphere without comming coming back to the ground. 
Many process safety controls are in place to limit the offsite consequence of this release.  Operators are trained to recognize conditions that may lead to a process upset and to take action to prevent one from occuring.  Process controls and shutdown systems will a 
ctivate if operator control is not effective.  
Alternative Release Scenario - Aqua Ammonia 
As a result of a hose failure, 2,000 gallons of aqua ammonia (29% ammonia solution) spills while a tank truck is being unloaded.  From the resulting liquid pool, 400 lbs. of 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.  However, for this alternative scenario it was assumed that the unloader is unable to close the valve due to an ammonia pool under the truck.  The spill is mitigated by the slope of the unloading area, which directs the spill into a trench and containment pit. 
                                                                                                                                                                  Alternative Release Scenario -  Form 
aldehdye (Transfer Hose Leak)   .                                                                                                                                                                   As a result of a tank hose failure 1,500 gallons of 53% formaldehyde solution spills in the tank truck loading area.  The distance to the EPA toxic endpoint of 0.012 mg/L is 0.08 miles. 
By procedure, the tank truck driver and shipping personnel remain in attendance at all times during loading/unloading operations.  A spill would be discovered soon due to the driver and shipper proximity to the operations and the formaldehyde odor.  Valves can be closed and transfer pumps can be shut-off from a safe distance away to stop the spill.  The release is mitigated by the slope and berming of the unloading area, which directs the spill into a trench and containment pit.                                                                                           . 
4.Accidental release prevention program a 
nd 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 several levels of action to prevent a release  
upon operator error or equipment failure.  For the urea-formaldehyde resin reactor, automated control valves and mproved 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.  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 and other corrective or improvement repairs necessary to maintain the ongoing integrity  
and reliability of the facility equipment.  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 rec 
ommendations are made to prevent recurrence.  These recommendations may lead to improvements in equipment, procedures, operating conditions, or training. 
Internal Corporate Health, Safety and Environmental Audits are conducted periodically to maintain compliance with local, state and federal regulations.  Regional Safety and Environmental professionals also frequently conduct  comprehensive audits of the health,safety, and environmental programs.  Addressing recommendations from these audits keeps the Facility's Safety and Environmental programs effective. 
5.Five-year accident history 
In the five year period from January 1, 1994 to June 1, 1999 an incident occurred, as a result of release of a regulated substance from our process, involving an offsite construction crew who complained of irritation.  These workers were examined, released and return to work within one hour. 
6.Emergency response program 
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 and reinforce training that plant responders receive. 
7.Planned changes to improve safety 
The following work is planned to upgrade spill mitigation capability: 
7 New berms will be added to reduce the size of a potential spill at tank truck loading and unloading stations. 
7 Removable covers will be acquired for the containment pits to reduce the amount of vapor released.
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