Faultless Starch/Bon Ami Company - Executive Summary
EXECUTIVE SUMMARY FOR RMP |
This executive summary briefly describes the Risk Management Program for the propellant system at the Faultless Starch/Bon Ami Company manufacturing plant located in Kansas City, Missouri.
SOURCE AND PROCESS DESCRIPTION
The Faultless Starch/Bon Ami Company is a privately owned business whose principal enterprise is manufacturing and marketing laundry and household cleaning products to consumer and commercial markets. The Faultless Starch/Bon Ami Company operates a manufacturing plant located in Kansas City, Missouri. The plant manufactures various household consumer goods, including aerosol products, such as aerosol spray starch.
As part of manufacturing the aerosol products, a small amount of propellant is added to the aerosol cans. The propellant used is a mixture of n-butane and propane, which is considered a regulated flammable mixture under the Risk Management Program regulations in 40 CFR Part 68. The regulated process, called the Pr
opellant System, consists of propellant stored outside in an aboveground storage tank and pumped to an explosion-proof room inside the plant building where the propellant is added to the aerosol cans by state-of-the-art equipment. Multiple safety and preventative measures are utilized to ensure that the propellant is safely stored and handled at the plant.
SUMMARY OF MAJOR HAZARDS
The propellant is composed of a flammable mixture of n-butane and propane, which is a liquid under moderate pressure and a gas at normal room temperatures and atmospheric pressure. Because of its flammability hazard, a fire or an explosion is an event that could potentially occur.
According to the Risk Management Program regulations, the flammable mixture is assumed to have a worst-case release scenario that involves a release of the entire contents of the storage tank (73,000 lbs), which ignites and produces a vapor cloud explosion. The worst-case scenario considers the administrative control of 85% max
imum liquid fill volume for the storage tank, in accordance with an operating procedure. The worst-case release scenario is predicted to reach offsite endpoints and nearby public receptors. The worst-case release scenario is unlikely to occur because of the on-going prevention program activities, process controls, mitigation systems, and monitoring/detection systems which ensure that the risks are much lower than the scenario suggests.
The alternative release scenario considered is the release of the contents of the tank's unloading hose (20 lbs of a flammable mixture), which is assumed to ignite and produce a vapor cloud explosion. With a small calculated end-point distance located in a relatively unoccupied area, the alternative release scenario is predicted to have only minimal impact offsite, with no known offsite impacts on residential population or the environment.
HOW RELEASES ARE PREVENTED
The plant operates the propellant system in accordance with a Risk Management Program
which serves as the accidental release prevention program for the flammable mixture in accordance with regulation 40 CFR Part 68. The Risk Management Program has several elements including hazard assessment, prevention program, and emergency response. The prevention program consists of maintaining process safety information; regularly conducting process hazard analyses and compliance audits; implementing operating procedures, safe work practices, hot work permit procedures, mechanical integrity procedures, and training; and implementing specific plans for management of change, pre-startup review, incident investigation, employee participation, and contractors. The goal of the Risk Management Program is to reduce the likelihood of accidental release.
The likelihood of accidental release from the propellant system is further reduced with the use of process controls (emergency shutdown and interlock systems, relief valves, check valves, vents, manual shutoffs, alarms, procedures, exc
ess flow device, and grounding equipment), mitigation systems (blast walls, extinguishing deluge system, and enclosure), and monitoring/detection systems. The propellant system equipment also adheres to applicable engineering codes and standards.
STEPS TAKEN TO ADDRESS HAZARDS
Five-year accident history: The plant has had one accidental release in the past five years, which resulted in injuries to two employees and onsite damage to the building and equipment. The accident did not involve any impacts to offsite population or property. After the accident, the plant immediately took additional steps to prevent such an accident from occurring again. Much of the aerosol packaging line was revamped, and the equipment was replaced with state-of-the-art technology. The automatic interlock systems for the propellant process were improved, to expand the number of scenarios in which the line would automatically shutdown. The new upgraded equipment and piping system were designed to be muc
h safer for employees and the environment. These improvements have been completed and are currently in operation.
Planned changes to improve safety: The plant's Risk Management Program is an on-going program that provides a number of ways to address hazards and thus improve the propellant system and reduce risk. For example, the Risk Management Program includes several elements that generate recommendations on a regular basis, such as from the process hazard analyses, compliance audits, incident investigations, and management of change reviews. These measures are intended to provide continuous improvement to the propellant system and its safety and prevention programs.
RESPONSE ACTION IN THE EVENT OF A RELEASE
The plant has an Emergency Action Plan (EAP) which provides planned response actions for the plant employees in case of an emergency (i.e., fire or explosion). The EAP has been coordinated with the city fire department, to ensure that the fire department understands the
plant hazards and thus can plan how to respond if notified in order to minimize onsite and offsite impacts. If an accidental release occurs, the EAP provides appropriate mechanisms for the plant to notify the fire department emergency responders when there is a need for a response.
Note that Item 7.4.c should be blank, because the last PHA had no recommendations for changes (see Item 7.4.h). Reference the instructions for that item on page 40 of Chapter 2 in the User's Manual issued 1/4/1999. However, the "Check" function of the RMP*Submit program would say that there is an error if Item 7.4.c were left blank, so a date was entered to prevent an error.