Fomo Products, Inc. - Executive Summary

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40 CFR 68.155 requires an executive summary as follows: 
 
"The owner or operator shall provide in the RMP an executive summary that includes a brief description of the following elements:  
 
(a) The accidental release prevention and emergency response policies at the stationary source;  
 
(b) The stationary source and regulated substances handled;  
 
(c) The worst-case release scenario(s) and the alternative release scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario;  
 
(d) The general accidental release prevention program and chemical-specific prevention steps;  
 
(e) The five-year accident history;  
 
(f) The emergency response program; and  
 
(g) Planned changes to improve safety." 
 
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICY 
 
It is the policy of Fomo Products to conduct all its operations and activities in a manner that will ensure proper safety and health protection for all employees as well as for the g 
eneral public.  The prevention of occupationally induced injury or illness is of such consequence that it is given precedence over productivity whenever necessary.  Safety is every employee's job. 
 
STATIONARY SOURCE DESCRIPTION 
 
Fomo Products, Inc. fills containers with an isocyanate and a polyol (resin) initiator blend along with various propellant materials, thereby creating aerosol containers that, when discharged, provide a polyurethane foam that polymerizes into a solid shortly after exposure to ambient air and moisture.  The propellant for many of the containers is either (1) 1,1-difluoroethane or (2) a mixture of dimethyl ether, isobutane, and propane.  These propellants are stored as liquids under pressure in two separate storage tanks outside the Fomo Products plant.  The nominal volume of the 1,1-difluoroethane tank is approximately 11,000 gallons and that of the dimethyl ether/isobutane/propane tank is approximately 18,000 gallons.  The propellant materials are delivered to  
a specially designed, fire-safe gas house via hard piping.  Inside this gas house, the propellants are dispensed into the various containers via an automated gas dispensing system.  The bulk storage tanks will never be filled to more than 85% of their respective nominal volumes. 
 
WORST CASE AND ALTERNATIVE RELEASE SCENARIOS 
 
The worst-case release scenario analyzed was a release of the entire contents of the dimethyl ether/isobutane/propane tank followed by a vapor cloud explosion.  The impact was evaluated by calculating the distance to an overpressure of one pound per square inch using the TNT-equivalency method.  The analysis showed that the distance to a 1 psi overpressure would be 0.42 miles. 
 
The alternative release scenario considered is one in which a pressure relief valve that serves each of the bulk storage tanks fails, thereby creating a flammable vapor cloud.  The criteria for this evaluation was the lower flammability limit (LFL).  Using the methodology (for a flammable, d 
ense gas) for estimating the distance to LFL outlined by U.S.EPA's Offsite Consequence Analysis Guidance (look-up tables), the distance to the LFL for a release from either tank would be less than 0.06 miles. 
 
ACCIDENTAL RELEASE PREVENTION PROGRAM 
 
The primary hazard associated with handling of the flammable gases is a release of flammable gases at the point at which the gases are dispensed into containers.  To mitigate this hazard, Fomo Products has installed a specially designed gas house.  This gas house includes flammable material (hydrocarbon) analyzers which would stop the flow of gas to the gas house if the concentration exceeds a set point less than the lower flammability limit.  In addition, the gas house includes an automated fire suppression system and a deflagration panel that would vent the deflagration away from the employees and the plant in the event of an explosion. 
 
In addition to the gas house, Fomo Products has installed hydrocarbon analyzers near each bulk storage  
tank that would sound an alarm if the hydrocarbon concentration in the area exceeds the concentration set point.  Fomo Products also provides safety training to employees and conducts routine safety audits of facility equipment and procedures. 
 
FIVE-YEAR ACCIDENT HISTORY 
 
Fomo Products has not had any reportable accidents (i.e., fires, explosions, etc.) involving the regulated chemicals in the past five years. 
 
EMERGENCY RESPONSE 
 
Fomo Products has developed a detailed emergency response plan that stipulates persons who will perform key procedures including, but not limited to, (1) evacuation of the building (including a set meeting point), (2) notifying the local fire department, (3) emergency first aid and health care procedures, (4) transportation of injured persons to a health care facility, and (5) notification of neighboring residents/businesses. 
 
PLANNED SAFETY CHANGES 
 
In the near future, the Norton, Ohio Fire Department will use Fomo Products as a training facility for its fir 
efighters.  This will allow the fire department to enhance its skills in emergency response and will also make the fire department more familiar with the Fomo Products site and its operations.  In addition, Fomo Products will soon be installing a "Knox Box" on the outside of the plant building.  This box will contain keys to the facility, a facility map, and material safety data sheets identifying contents of system storage tanks that could be used by the fire responders should an emergency occur.
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