S.C. Johnson & Son, Inc. Waxdale Plant - Executive Summary
WAXDALE RISK MANAGEMENT PLAN |
S. C. Johnson & Son, Inc. (SCJ) is one of the world's leading manufacturers of consumer products. U.S. manufacturing operations are primarily conducted at the Company's Waxdale Manufacturing Plant located six miles west of Racine, Wisconsin. The plant's Consumer Products division is a formulator/packager of personal grooming, cleaning, waxing, polishing, and insect control products. The Consumer Products division encompasses approximately 1.6 million square feet of floor space and is one of the largest and most modern facilities of its kind in the world.
RMP REGULATED CHEMICALS AND PROCESSES
The Consumer Products division stores, transfers and processes five chemicals in quantities exceeding the applicable 10,000 lb risk management plan (RMP) threshold on EPA's list of regulated flammables. Butane, Isobutane and Propane are contained in LPG blends, which are used in propellants for aerosol product man
ufacturing. In addition, Pentane and Isopentane are contained in formulas used to manufacture various shave gels.
There are four areas at the plant where these chemicals are stored in quantities exceeding the threshold defining RMP regulated processes:
? LPG Tankfarm - Bulk storage and use of LPG Blends
? LPG Railcar Spur - Railroad spur on the west side of the plant where LPG tankcars are temporarily stored
? Aerosol Warehouse - Aerosol Products containing LPG Blends are stored prior to shipment
? Pentane & Isopentane Bulk storage tanks - Bulk storage and use of Pentane & Isopentane
OFFSITE CONSEQUENCE ASSESSMENT
WORST CASE SCENARIOS
For each LPG blend containing process identified in the Waxdale RMP, process quantities of Butane, Isobutane and Propane are individually identified as if each chemical constituted 100% of the LPG. Butane was selected for worst case scenario modeling because it has the highest density/heat of combustion combination of the three prope
llant constituents. Since the Pentane and Isopentane bulk storage tanks are co-located, they were treated as one RMP process. Offsite consequence modeling was performed for Isopentane, because that tank had the larger storage capacity and resulted in the greatest distance to endpoint.
Administrative controls (operating procedures) are used to prevent overfilling of the storage tanks in the LPG Tankfarm. Therefore, the maximum process quantities associated with these storage vessels are limited to 85% capacity (approximately 25,600 gallons). Predictive filing was employed for the aerosol warehouse storage process to account for the largest potentially expected future quantities of aerosol product inventory.
For each regulated flammable chemical, EPA's Offsite Consequence Analysis Guidance document was employed to estimate the maximum predicted distance to the 1 psi overpressure endpoint associated with a vapor cloud explosion. In accordance with EPA's regulatory requirements, a c
omplete loss of product was assumed to occur for each affected chemical process followed by a vapor cloud explosion. Based on the process storage quantities modeled, offsite impacts were predicted for the LPG rail spur tankcar, LPG tankfarm, and the Pentane & Isopentane storage processes.
Worst case scenarios associated with flammable chemical storage at Waxdale are extremely unlikely due to the fact the SC Johnson employs World Class process detection and mitigation systems. These systems include: deluge system, water cannons, heat resistant tank coatings, tank and piping pressure relief valves, excess flow valves, emergency shutdown interlocks, high level interlocks, Lower Explosive Limit gas detection systems (point and open path), emergency stop buttons, daily walkdown checklists, containment dikes, etc. to name a few.
ALTERNATE RELEASE SCENARIOS
A number of somewhat more probable, but still unlikely, scenarios associated with the storage and transfer of LPG blends, Penta
ne and Isopentane were evaluated. EPA's Offsite Consequence Analysis Guidance document was employed to estimate the maximum predicted distances to the lower flammability limit and radiant heat endpoints associated with vapor cloud fire and pool fire release scenarios. Where applicable, passive controls (e.g., dikes) were accounted for in these analyses, however no credit was taken for any active controls. The alternate release scenario with the largest predicted impact has an endpoint that extends slightly beyond Waxdale's property lines.
ACCIDENT PREVENTION PROGRAM
The Waxdale facility meets world class standards for ensuring safe operations. Some of the safety measures employed by SC Johnson Waxdale facility include:
? Documented information pertaining to the equipment, technology and chemicals used in the process.
? A complete Process Hazard Analysis/Hazards Review for all affected operations and equipment to identify possible release scenarios and recommendations to
mitigate/eliminate such release scenarios.
? Written operating procedures that include startup, normal operations, emergency operation, operating limits and consequences of deviation.
? Early detection systems that include high level alarms, gas detection systems, etc.
? Mitigation systems that include spill containment dikes, deluge and fire protection systems, pressure relief valves, explosion suppression, etc.
? Documented employee training on all operating procedures and safety policies and procedures. This training includes a detailed, specialized, safety training program that has also been developed and implemented for LPG system operating and maintenance personnel.
? Mechanical Integrity Program
? Management of Change/Pre-startup Safety Review Program
? Incident Investigation Program
? Hot Work Permit Procedure
? Employee Participation Guideline
? Contractor Program
? Compliance Audit schedule
There have been no accidents in the last five years of Wa
xdale's operations that have resulted in any offsite impacts to people or the environment.
EMERGENCY RESPONSE PROGRAM
Waxdale has a fully trained and equipped hazardous material and fire brigade onsite, consisting of SC Johnson employees. This brigade is equipped to respond to, contain and cleanup chemical spills and to attack structural fires. In addition to personal protective equipment for routine plant activities, the facility has a fully equipped hazardous material vehicle and both in-plant and outside fire vehicles. The Brigade's training meets OSHA's Hazardous Waste Operations' (HAZWOPER) requirements.
The Brigade also coordinates its responses to plant emergencies with offsite emergency response agencies. Primary offsite emergency responders include the Mt. Pleasant Fire and Police Departments, the Sturtevant Fire Department and the Racine County Sheriff's Department.
The Brigade regularly trains with the Mt. Pleasant Fire Department. The plant also periodically participa
tes in full-scale hazardous material response exercises involving the local fire departments.
Coordination of emergency response activities is also facilitated by the plant's inclusion in the Racine County's Office of Emergency Management offsite response plan and by compliance with the annual chemical inventory filing requirements of the Emergency Planning and Community Right to Know Program.