Borden Chemical, Inc. - Executive Summary |
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Executive Summary Borden Chemical, Inc. Louisville KY facility 1.0 Accidental Release Prevention and Emergency Response; Policies and Principles Borden Chemical, Inc. is committed to health, safety, and environmental excellence. To accomplish this goal 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. Borden Chemical, Inc. has established a company-wide Safety Manual. This manual establishes requirements and guidelines that have been developed to prevent injuries and accidental releases. The Safety Policy Statement, which is maintained in the Safety Manual, clearly states that safety will not be compromised to achieve any other operational or business objective. Safety is given the highest priority in emergency response situations. Borden Chemical participates with other phen olic resin and formaldehyde manufacturers to investigate major incidents, evaluate process safety risks, and to develop process improvement plans. Recommendations for changes resulting from these collaborative efforts are distributed throughout the company, and schedules to upgrade critical safety systems are established where appropriate. The Louisville facility has developed a thorough site wide safety program, including an integrated contingency plan that is carefully coordinated with the local emergency response management agencies. Safety programs are administered by qualified professional staff, but emphasize employee involvement. Facility personnel have developed close associations with local emergency response agencies to facilitate an effective and coordinated response in the event of an actual emergency. 2.0 Description of the Facility and Regulated Substances Handled This facility produces formaldehyde solutions and phenol-formaldehyde and related resins using methanol, formaldehyde and phenol as the primary raw materials. The site includes a formaldehyde production plant and a series of phenolic resin reactors housed in four area units. Borden also grinds phenolic resin into a powdered finished product. The formaldehyde plant is comprised of two operating units and multiple storage tanks. While much of the formaldehyde is sold as a raw material to customers, a significant amount is used on site to produce phenolic resin. Virtually all of the formaldehyde is handled in closed piping systems; process equipment is hard piped to weigh tanks and reactors. Formaldehyde is pumped from storage tanks directly to rail cars and tank trucks. Two general types of phenolic resins are produced at the site, including resole (liquid) and novalac (solid) resins. Most of the finished product resins produced at the facility are non-hazardous. Handling the raw materials safely and carrying out reactions in the safest manner are keys to good process safety p erformance. Besides formaldehyde, the other regulated material covered under the risk management plan is methyl formate. Borden purchases methyl formate in drums and warehouses it on-site in a building dedicated to the storage of flammable materials. This material is shipped with resins to customers who wish to purchase both at same time; none of the methyl formate is used on-site. The regulated substances used in the plant and the maximum quantities stored are: Formaldehyde 2,600,000 lb. (100% weight basis; 5,200,000 lb of 50% solution) Methyl formate 20,000 lb. 3.0 Release Scenarios 3.1 Worst Case Release Scenario The worst case scenario at this facility assumes that a rail car of formaldehyde fails and that its entire contents (180,000 lb of 50% formaldehyde solution) are released instantaneously. It is further assumed that all active safety systems fail and that worst case atmospheric conditions exist at the time of the release. A dike around the loading station an d a gravity flow piping system convey the spill to a containment sump, thereby limiting the exposed surface area of the spill to the wetted area of the loading area dike and the surface area of the containment sump. The release rate from this incident is 12 lb/min. The distance to the EPA toxic endpoint is 0.62 miles. Although smaller loading spills may happen, it is highly unlikely that a spill of this magnitude could occur. Tanks and rail cars meet stringent design criteria, severely limiting the probability of an instantaneous failure. Plant technicians are well trained, and perform their work using standard procedures that are reviewed annually. The facility is well equipped to handle a large spill incident, having an internal hazardous materials incident response team (with 64 employees currently trained to the HAZ-MAT Technician level) and an excellent working relationship with local response agencies. The worst case scenario for a flammable substance addresses a spill and subsequent vapor cloud explosion involving methyl formate. Methyl formate is received, warehoused and shipped in 55-gallon drums at this facility, but this material is not normally transferred to other containers or otherwise handled or processed. The scenario addressed by this plan involves an accident that causes one drum of methyl formate to instantaneously spill its contents such as could occur in a forklift collision. The entire volume of material in the drum is presumed to evaporate. Following RMP guidance, 10% of the evaporated volume is presumed to participate in a vapor cloud explosion. The distance to a 1-PSI overpressure was calculated and found to be 0.04 miles (210 ft.). There is no offsite consequence associated with this event. 3.2 Alternative Release Scenarios Several alternate cases for formaldehyde were explored. Two cases having a potential off-site impact were overfilling a tank and venting of a kettle due to overpressure during a reaction. In the first case it was assumed that 5000 lb of formaldehyde solution was lost to a diked area at ambient conditions; the distance to the toxic endpoint was estimated to be 0.19 miles. Any spill would be noticed quickly because of the odor of the material. In many cases, operations personnel also have the capability of routing spilled material to containment tanks. This scenario was not formally presented in the RMP plan since an alternate release scenario involving a larger affected population (the reactor release scenario, described below) was identified. In the reactor overpressure case it was assumed that a runaway reaction resulted in the partially-reacted contents of the vessel being discharged to a containment tank that is designed for this purpose. Vapor discharged from the relief tank would contain unreacted formaldehyde, which would subsequently evaporate from the surface of the liquid within the containment tank. The distance to the toxic end point was estimated to be 0.32 miles. All re actors at the facility are equipped with relief protection devices to minimize the possibility of catastrophic failure; many have control systems that automatically shut off feeds of raw materials under high reaction rate conditions and to quench the reaction mass with water to cool and control it. 4.0 Accidental Release Prevention Program and Chemical-Specific Prevention Steps The Louisville 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, and a documentation system to maintain records of compliance. A site steering team meets monthly to review plant safety programs and to verify that all tasks are being completed on schedule. An associate safety team, which is comprised of first line supervisors, technicians and operators, also meets monthly and is responsible for improving safety performance in the plant. The Plant Manager has overall responsibility for the safety program at this site. The Louisville site has fully implemented the Process Safety Management standard. Process hazard analyses are conducted prior to startup of major project installations, and then on an on-going basis to identify hazards and recommend safeguards that will prevent an accidental release. Significant investment has been made in process control systems as a result of initial process hazard reviews. Two methods are used to ensure that changes to plant equipment, procedures, and processes do not cause accidents. A worksheet is used to initiate a safety review for equipment and process changes. This review includes a process hazard analysis where appropriate. Changes to product formulations initiate a review by a chemist, a process engineer, an d production management. Supplemental 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. The site has a documented preventive maintenance program to insure the mechanical integrity of process equipment. This program is managed using a computer database. Each month scheduled equipment inspections, tests, or servicing are performed and documented when complete. The schedule is based on plant experience and manufacturer guidelines to reduce the likelihood of an accidental release caused by equipment failure. The requirements in the Safety Manual include safe work practices that prevent accidental releases. One important section describes safety measures for performing "hot" work in the plant; one example is welding; the procedure includes a permit system to reduce the risk of fire. The Safety Manual also in cludes requirements for locking out equipment for maintenance. This procedure reduces the likelihood that a valving error will lead to a release in addition to providing protection to maintenance personnel. Plant supervision provides safety orientation training for contractors who periodically perform work in the plant. The objective of this training is to brief them on plant hazards and safety practices. 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. Major incidents and "near misses" are investigated using a formal root cause evaluation process. Borden Chemical periodically conducts assessments of its safety and environmental programs using company personnel from the site and other locations, in addition to its comprehensive third party safety and environmental auditing program. Addressing recomm endations from these audits helps to keep the safety and environmental programs up to date and effective. In addition to the scenarios covered in this risk management plan, Borden has elected to perform risk reviews of potential hazards that are not covered under the RMP standard to help ensure the safety of all production systems at the site. Borden has actively participated in community outreach programs that have been established in the Rubbertown area to provide a forum for discussing the concerns of our neighbors. Borden regularly participates on a local Community Advisory Council and neighborhood association, and was an active contributor to the Jefferson County RMPlan rollout program in the community. Associates of the plant have actively sought out opportunities to meet with interested school and community groups to discuss the RMP program. Borden maintains an open-door policy to encourage constructive dialogue between the company, its near neighbors and other interested members of the public. 5.0 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 6.0 Emergency response program Borden's on-site emergency response team is trained to meet or exceed the training requirements for hazardous materials technicians and incident commanders. Over sixty associates are trained to the hazardous materials technician level. The plant has a mobile trailer equipped to respond to hazardous material incidents that could occur on site. All facility personnel receive monthly training on the basics of recognizing and responding to various hazards that could occur in a modern chemical plant. The Louisville emergency response plan describes procedures for actual and threatened releases, including coordination with outside agencies. Borden has an very good relation with local responders and other local response groups, for example the Ru bbertown Mutual Aid Association. The Jefferson County LEPC holds a reputation as an excellent response group. 7.0 Planned changes to improve safety The Louisville plant is driven by the corporate philosophy of demonstrating continuous improvement in all aspects of its business. Promotion of a greater awareness of safety, environmental and housekeeping performance is underway at the facility. In addition, organizational changes have been made to change the culture in the plant to further increase commitment to performance by plant supervision and technicians. The business has committed a significant level of resources to leadership development, improved communication, and improvement in team work and business processes. Annually the plant develops continuous improvement programs related to safety and environmental performance. When evaluating capital projects for approval the company places high priority on those projects that minimize safety and environmental risk. This y ear the Louisville site is implementing an approved project to upgrade the safety automation on several reactors. This includes automating raw material feed shutoff systems and water deluging (quenching) systems. When this effort is complete in late 1999 all reactors on site will be automated. The facility is also evaluating options for improving the reliability of the electrical power supply to the plant. |