JLM CHEMICALS, INC - Executive Summary
Executive Summary '40 CFR 68.155 |
In June 1996, EPA finalized regulations for Section 112(r) of the Clean Air Act that required risk management planning to help prevent accidental releases of 139 hazardous and flammable substances. Because JLM Chemicals (JLM) handles, processes and stores propane and propylene above threshold quantities, the facility is required to have a Risk Management Plan for preventing possible accidents related to unintentional chemical releases.
ACCIDENTAL RELEASE PREVENTION POLICY
JLM approaches accidental release prevention by participating in multiple safety programs that focus on prevention of explosions and fires, and releases of regulated chemicals in the Cumene process. The initial approach is accomplished through the implementation of a Process Safety Management Program (PSM). The PSM program is designed to provide an overall framework of operating practices, procedures and documentation to allow for the safe operation of the facility.
a member of the Chemical Manufacturer's Association (CMA), JLM is obligated to actively participate in the Responsible Care Program initiative. The Responsible Care initiative is a commitment by JLM management to continually improve performance in the environmental, health, and safety areas. Working closely with local emergency responders such as fire departments to plan and prepare for possible accidents, continuous employee training and emergency response training are examples of the Responsible Care commitment.
STATIONARY SOURCE AND REGULATED CHEMICALS
The JLM Blue Island facility consists of a Cumene Unit, Phenol Unit, and chemical storage tanks. JLM produces phenol, acetone, and alpha-methyl styrene in the phenol unit. The process subject to Risk Management Plan requirements at the Blue Island facility is the production of cumene in the Cumene Unit.
JLM receives as a raw material, a liquefied petroleum gas (LPG) blend of propylene/propane either by pipeline, railroad cars or
tank trucks. The LPG can be fed direct to the Cumene process area or to the storage tank for later use. In the Cumene unit the propylene is reacted with benzene to produce cumene, an intermediate product used in the production of phenol and acetone. The propane undergoes no chemical reaction and is subsequently removed from the process in the depropanizer. The propane is either sold as a product or used internally as a fuel. JLM has on site in excess of 10,000 pounds each (the threshold quantity) of the flammable chemicals propane and propylene that are subject to risk management planning.
Regulated substances include:
Propylene Maximum quantity stored in one tank 30,000 gallons
Propane Maximum quantity stored in one tank 7500 gallons
WORST CASE SCENARIO
The worst-case release scenario would occur in the unlikely event that a failure of the storage tank or railcar would cause a sudden release of 30,000 gallons of propylene into a vapor cloud followed by de
tonation. Using the USEPA's OCA guidance, the worst case release of propylene, if detonated would have an overpressure endpoint of 1.0 psi approximately 0.4 mile from the release point. An overpressure of 1 psi may cause partial demolition of houses and the shattering of glass windows, either of which could result in potential injuries to people from the property damage resulting from the explosion. The 0.4-mile radius impact zone consists of open fields and forest areas, industrialized areas, small buildings, and residential areas at the north and south outer edges. Estimates are that a worst case scenario could affect approximately 50 persons residing within the 0.4-mile zone.
ALTERNATIVE RELEASE SCENARIO
The more likely, yet still improbable alternative-release scenario would involve a pump seal failure or valve packing leaking for 10 minutes that releases 1400 pounds of propylene into the air resulting in a vapor cloud fire. Using the USEPA's OCA guidance , the distance to r t
he lower flammability limit (LFL) end point is 0.06 miles. (313 ft) The LFL represents the maximum distance at which the radiant heat of a vapor cloud fire might cause serious burns. The 313 ft. radius impact zone is located within the plant boundaries and adjacent industrial areas. There are no residential areas affected by this scenario.
ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS
The following are accidental release prevention program steps that JLM has implemented to prevent previously described incidents:
* A process safety management (PSM) program to meet the requirements of the OSHA PSM rule. Elements of the PSM program have been reviewed relative to the RMP program requirements.
* Employee participation program:
* Ongoing compilation and update of process safety information
* Management of change program:
* Pre-startup safety review program:
* Hot work permit program:
* Continued employee training:
* Ongoing maintenance program to insure mechanical integrity of equipment
* VOC leak detection and repair program for pumps and valves. Program requires that pumps be monitored monthly, and valves be monitored quarterly for leaks.
* Safety valves to avoid overpressure
* Routine equipment checks by employees
* Excess flow valves on railcars and storage tank 903 to stop flow in case of line break
THE FIVE YEAR ACCIDENT HISTORY
There have been no offsite releases for covered processes within a five year period that resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage.
EMERGENCY RESPONSE PROGRAM
* Arrangements with local Fire Departments
A mutual aid agreement exists between JLM Chemicals and Clark Oil and Refining Corp. When the fire alarm is activated, the Clark Oil Refinery Corp. fire brigade will respond. The Alsip Fire Department has primary responsibility to respond to emergencies at the facility. The Blue Isl
and Fire Department is expected to respond to emergencies at the facility if necessary. Both of the above municipal departments can be contacted by phone (regular or dedicated phone line) and by radio. These communication devices are located in the Chemical Plant control room. The local fire and emergency response alarms are tested every week.
* Exemption from Emergency Response Program
Pursuant to '40 CFR 68.90(b) JLM need not comply with the Emergency Response Program because it meets the following requirements as evidenced above:
1. It is a stationary source with only regulated flammable substance and has coordinated response actions with the local fire departments and Clark Oil fire brigade.
2. Appropriate mechanisms are in place to notify emergency responders when there is a need for response.
PLANNED CHANGES TO IMPROVE SAFETY
To improve safety near the LPG storage tank, JLM plans on installing gas detection monitors at the storage tank and railcar unloading rack with alarms.