Amway Corporation - Ada Site - Executive Summary |
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Amway Corporation's World Headquarters and main manufacturing facility are located at a single site in Ada, Michigan. Primary activities at the Amway Ada Site include the manufacture of home and personal care products. One process at the Site is covered by EPA's Risk Management Program Rule. That process is the manufacture of aerosol products, including the storage of flammable propellants. Regulated substances used in the process, and maximum quantities stored, are as follows: Isobutane (82,000 pounds); Difluoroethane (54,000 pounds); Propane (56,000 pounds); n-Butane (15,000 pounds). The propellant process is covered under OSHA's Process Safety Management Standard, and is also regulated by EPA's Risk Management Program Rule, Subpart D - Accidental Release Prevention Program 3. It is Amway Ada Site policy to comply with these regulations in order to prevent, and/or minimize, the consequences of accidental releases. Emergency response to releases of hazardous materials is provid ed by the Site's Hazardous Materials Emergency Response Team. The Site's Security Department responds to fires at the initial stage. Additional response capability is provided by the Ada Fire Department. According to EPA requirements, the worst case scenario calculated for this Risk Management Plan involves the total, instantaneous release of isobutane from its storage tank. The storage tank is administratively controlled to 85% of its maximum capacity, thereby limiting the release quantity. In a worst case scenario, the total contents would vaporize and ignite. Using the model conditions of Section 68.25 of the RMP regulations, the resulting one pound per square inch overpressurization endpoint (centered on the isobutane tank) would extend no more than approximately 420 yards beyond the facility boundary. This scenario is highly unlikely to occur at the Ada facility because under normal circumstances the entire contents of a single tank will not vaporize nearly instantaneously. In addition, the tank and its operating system are regularly inspected to verify they are in proper working condition. The alternate case scenario would involve a pressure relief valve failure on the isobutane storage tank. Storage tank capacity is administratively controlled at 85% of its maximum, limiting the release quantity. In this scenario, the valve would open and not re-seat (fully close) allowing material to escape through the 2.5 inch top mounted valve, resulting in a vapor cloud fire. Using a dispersion modeling program (ALOHA Version 5.2.1) and the model conditions of Section 68.28 of the RMP regulations, the resulting lower flammability limit endpoint (the maximum distance at which the radiant heat effects of a vapor cloud fire might have serious consequences) would not extend off-site. The likelihood for the alternate-case release, or any release, from the storage tank is very low. Regularly-scheduled pressure relief valve inspections and replacements are perform ed to verify and ensure proper working order. The propellant process is covered under OSHA's Process Safety Management Standard which focuses on preventing, or minimizing, the consequences of accidental releases of hazardous chemicals. The Amway Ada Site is in compliance with the PSM Standard, protecting those in the workplace from chemical exposure, fires, and explosions. The propellant process is also regulated by EPA's Risk Management Program Rule, Subpart D - Accidental Release Prevention Program 3. The Site has expanded the scope of their PSM program elements to prevent, or minimize, any off-site consequences of unwanted releases of EPA/RMP-regulated substances. The Amway Ada Site has had no EPA/RMP reportable releases from the regulated process within, at least, the time frame in which documentation ex ists, which is twelve years. The Site has a current emergency response plan which has been coordinated with the Ada Fire Department, Kent County Local Emergency Planning Committee, and Kent County Emergency Management. The Plan is in compliance with the National Response Team's Integrated Contingency Plan Guidance. The Hazmat Team has conducted joint training and drills with the Ada Fire Department. Public notification and alert is done in compliance with SARA Title III and Risk Management Planning requirements. The Ada Site Emergency Response Plan has been coordinated with emergency response procedures established by the Kent County Local Emergency Planning Committee. The Amway Ada Site will continue to perform Process Safety Management Compliance Audits, and work to address any findings from these audits. The Site will include the auditing of EPA/RMP criteria as part of subsequent PSM audits. Efforts will continue to perform Process Hazard Analyses, and to address any recomm endations from these analyses. |