J.M. Products, Inc. - Executive Summary |
|
J.M. PRODUCTS, INC., 3117 JOSHUA, LITTLE ROCK, ARKANSAS 72204 FACILITY DESCRIPTION, REGULATED SUBSTANCE, ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES: J.M. Products, Inc. is a manufacturing facility that produces a variety of hair products, including Isoplus(r), Upturn(r), Black Magic(r), Oil of K(r), and Healthy Solutions(tm) Plus. J.M. Products utilizes in this manufacturing process two regulated flammable mixtures (A46 and A31/152a) in quantities that exceed EPA's threshold of 10,000 pounds. A46 is composed of Isobutane and Propane, and A31/152a is composed of Isobutane and Difluoroethane. J.M. Products commitment to providing a safe, healthy work environment for employees as well as providing a safe, healthy environment for the surrounding community is supported by J.M.'s development and implementation of an accidental release prevention program. J.M. Products is subject to Prevention Program 3 of EPA's standard 40 CFR 68, which follows the same requireme nts of OSHA's Process Safety Management Program (29 CFR 1910.119). The Process Safety Management Program is an extensive prevention program that was developed to prevent hazardous chemical releases. J.M.'s policy in the event of an uncontrolled accidental release of a flammable mixture is to evacuate the facility immediately and to contact the local fire department as well as the local emergency agencies. J.M. Products adheres to all applicable Federal, State and local safety and environmental regulations for the prevention of releases of this chemical. WORST-CASE SCENARIO: EPA has defined a worst-case release as, "a release of the largest quantity of a regulated substance from a vessel or process line failure that results in the greatest distance to a specified endpoint." Administrative controls that limit the quantity of a substance in a vessel or pipe can be considered when determining the worst-case scenario. For the worst-case scenario, the possible causes of the relea se or the probability that such a release might occur is not considered; the release is simply assumed to take place. All releases are assumed to take place at ground level. EPA only requires to document on the RMP a worst-case scenario for one flammable substance. Because the two regulated flammable substances are mixtures, the worst-case analysis is based on the predominate flammable component of the mixture or the major component of the mixture with the highest heat of combustion. The A46 mixture is comprised of Isobutane and Propane (Heat of combustion for Isobutane is 45,576 kilojoules per kilogram, and 46,333 kilojoules per kilogram for Propane). The A31/152a mixture is comprised of Difluoroethane and Isobutane (Heat of combustion for Difluoroethane is 11,484 kilojoules per kilogram). The entire weight of the mixture is used to calculate the distance to the 1 psi overpressure for the chemical with the highest heat of combustion. In this case the A46 mixture, utilizing P ropane as the major component, is used in the worst-case analysis. Meteorological conditions for the worst-case scenario are defined by EPA Guidance as atmospheric stability class F (stable atmosphere), wind speed of 1.5 meters per second (3.4 miles per hour), and ambient air temperature of 25 degrees C. Two choices are provided for topography for the worst-case scenario, rural or urban. WORST-CASE SCENARIO FOR A46 - FLAMMABLE MIXTURE According to EPA guidance document "RMP Offsite Consequence Analysis Guidance - May 24, 1996" the worst-case scenario would involve the release of the entire contents of the tank as a vapor, which finds an ignition source. As a conservative assumption, 10 percent of the flammable vapor in the cloud is assumed to participate in the explosion. For flammable substances the worst-case release is assumed to result in a vapor cloud containing the total quantity of the substance that could be released from a vessel or pipeline. The entire quantity in th e cloud is assumed to be between the upper and lower flammability limits of the substance. For the worst-case consequence analysis, the vapor cloud is assumed to detonate. The endpoint for the consequence analysis of a vapor cloud explosion of a regulated substance is an overpressure of 1 pound per square inch (psi). This endpoint was chosen by EPA as the threshold for potential serious injures to people as a result of property damage caused by an explosion (e.g. injuries from flying glass from shattered windows or falling debris from damaged houses). The worst-case scenario determined for the A46 mixture would be a rupture of a 6,000 gallon storage tank. The storage tank is assumed to be at full capacity at the time of the release (27,660 pounds). The total quantity in the tank would be released to form a vapor cloud explosion. (It should be noted that vapor cloud explosions are considered unlikely events, however, EPA requires that the release scenario be modeled using a vapor cloud explosion.) The storage tank is located outside with no passive mitigation, therefore passive mitigation measures where not considered for modeling purposes. Utilizing EPA's RMP* Comp software, the estimated distance to 1 psi overpressure is 0.2 miles with a wind speed of 1.5 meters/second, stability class F with ambient air temperature (77 degrees F). ALTERNATIVE RELEASE SCENARIO: EPA requires that an alternative scenario be analyzed for each regulated toxic chemical present above the threshold quantities. The release scenario must include consideration of the following: 1. Transfer hose releases due to splits or sudden uncoupling; 2. Process piping releases from failures at flanges, joints, welds, valves and valve seals, and drains or bleeds; 3. Process vessel or pump releases due to cracks, seal failure, drain bleed, or plug failure; 4. Vessel overfilling and spill, or overpressurization and venting through relief valves or rupture disks; and 5. Shipping container mish andling and breakage or puncturing leading to a spill. Alternative release scenarios, as required by EPA guidance, should be those that lead to endpoints beyond the facilities fence line, unless no such scenario exists. In identifying alternative scenarios, active mitigation systems are allowed to be considered, such as interlocks, shutdown systems, pressure relief devices, flares, emergency isolation systems, and fire water and deluge systems, as well as passive mitigation systems. Meteorological conditions for the alternative release scenario are defined by EPA Guidance as atmospheric stability class D, wind speed of 3.0 meters per second, and ambient air temperature of 25 degrees C and 50 percent humidity. Topography for the alternative release scenario is either rural or urban. According to EPA RMP guidance, four possible scenarios involving flammable substances include: 1. Vapor Cloud Fire 2. Pool Fire 3. BLEVE - Boiling liquid, expanding vapor explosion 4. Vapor Cloud Explo sion 5. Jet Fire Due to the characteristics of the A46 mixture it was determined that a vapor cloud fire would be the mostly likely event resulting from a release. A vapor cloud fire (flash fire) is assumed to result from dispersion of a cloud of vapor and ignition of the cloud following dispersion. Such a fire could flash back and could represent a severe heat radiation hazard to anyone in the area of the cloud. Similar to the analysis in the worst-case scenario, the alternative scenario is calculated using the chemical with the lowest lower flammability limit (LFL). The lower flammability limit for isobutane is 43 mg/L, 100 mg/L for Difluoroethane and 36 mg/L for propane. Thus, propane is the chemical used in the analysis for the distance to the lower flammability limit. The lower flammability limit represents the maximum distance at which the radiant heat effects of a vapor cloud fire might have serious consequences. Vapor cloud fires are considered instantaneous events, ther efore release duration does not need to be considered for estimating vapor cloud fire distances. ALTERNATIVE RELEASE SCENARIO FOR THE A46 FLAMMABLE MIXTURE The alternative case scenario identified for the A46 process is a failure in the piping at the discharge side of the pump. Although a complete break is considered to be an unlikely event, it was chosen as a conservative calculation. The pipe is 1 1/4" Schedule 80 carbon steel. The distance from the pump to the holding tank at the aerosol process is 250 feet. The total amount released is based on the total amount released from the pump in five (5) minutes plus the total amount that is released from the holding tank to the break in the pipe. Five minutes was determined to be the maximum amount of time necessary to shut down the pump to stop the release. The pump normally operates at 18 GPM, therefore the pump would release approximately 414 pounds in five minutes of operation. The amount released from the piping to the holdi ng tank is approximately 86 pounds. The distance to the lower flammability limit for the A46 mixture using propane's LFL of 36 mg/L, with a release rate of 100.22 lb/min, a wind speed of 3.0 meters per second and D stability in urban conditions is <0.06 miles or 316.8 feet. (This endpoint was identified using EPA's Offsite Consequence Guidance Table 21). The distance reported on the RMP data element for the alternative release scenario is 0.06 miles (although the RMP table tables indicated less than .06 miles, this is used as a conservative representation). Although this scenario could occur, preventative maintenance, scheduled inspections of the equipment in the process and monitoring by J.M. Products operator's help to identify and reduce the risk of leaks or releases due to failures of this type. ACCIDENT RELEASE PREVENTION PROGRAM: J.M. Products complies with the Process Safety Management rule of OSHA standard 29 CFR 1910.119 for the prevention of hazardous chemical r eleases. The Process Safety Management Plan is a comprehensive program with fourteen elements, including process hazard analysis, employee training, hot work procedures, incident investigations, operating procedures, mechanical integrity, pre-safety startup, contractor safety, emergency planning and response, compliance auditing, and employee participation. The Process Safety Management Program ensures that the process and the equipment in the process is designed, constructed, and maintained according to industry codes and standards and that the process is operated according to good engineering practices. The mechanical integrity element of the program includes scheduled inspections and tests of equipment and monitoring devices in the process to detect any deficiencies or defects in equipment. Preventative maintenance and replacement policies of parts and equipment ensures that deficiencies are addressed and corrected before they could potentially contribute to a release incident. All elements of the Process Safety Management Program help to ensure an uncontrolled release of the A46 and A31/152a mixture is prevented. FIVE YEAR ACCIDENT HISTORY: No accidental releases of either the A46 or A31/152a flammable mixtures have occurred at J.M. Products in the past five years that has 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: J.M. Products has developed an emergency response plan (in accordance with 29 CFR 1910.38) that includes provisions to evacuate the facility in the event of an uncontrolled release of either flammable mixture. J.M. has coordinated with the local emergency planning committee on its emergency response plan, and in the unlikely event of an uncontrolled release, the local fire department will be contact and they will respond to the release. PLANNED CHANGES TO IMPROVE SAFETY: J.M . Products is committed to continuous efforts to improve the safe operation of the flammable mixtures process by implementing preventative maintenance programs, inspection programs, and employee training in the safe operation of the equipment and the system. J.M. Products plans to pour concrete around the area of the flammable mixture storage tanks in the future to eliminate any ignitable substances (grass, etc.) from being near the storage tanks. Periodic auditing of the Process Safety Management Prevention Program ensures that the program is implemented properly. The management of change procedures ensures that any system changes or modifications are evaluated and necessary safety precautions and or safety improvements are made before the process is placed into operation. |