Johnson Polymer, Waxdale Plant - Executive Summary |
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WAXDALE RISK MANAGEMENT PLAN EXECUTIVE SUMMARY JOHNSON POLYMER Introduction Johnson Polymer is a leading global supplier of environmentally compliant polymer products (emulsions, solid and liquid resins, and resin solutions) for the graphic arts, architectural and industrial coatings, and adhesives industries. U.S. manufacturing operations are primarily conducted at the Company's Waxdale Manufacturing Plant located six miles west of Racine, Wisconsin. RMP Regulated Chemicals and Processes Johnson Polymer stores, transfers and processes one chemical in quantities exceeding the applicable risk management plan (RMP) threshold on EPA's list of regulated chemicals. Aqueous Ammonia (30% concentration) is used in the manufacture of Johnson Polymer's emulsions and resin solutions. There is only one area at the plant where this chemical is stored in quantities exceeding the threshold defining RMP regulated processes: 7 Ammonium Hydroxide storage - Bulk storage and use of Aqueous ammon ia (30%) Offsite Consequence Assessment Worst Case Scenario For the ammonium hydroxide process identified in the Waxdale RMP, administrative controls (operating procedures) and instrumentation (high level alarms and interlocks) are used to prevent overfilling of the storage tank. Therefore, the maximum process quantity associated with this storage vessel is limited to 95% capacity, which is approximately 23,370 gallons of ammonium hydroxide or 52,500 pounds of pure ammonia. For this regulated toxic chemical, Radian's CHARM model was employed to estimate the maximum predicted distance to the toxic endpoint of 0.14mg/L. In accordance with EPA's regulatory requirements, a complete loss of product was assumed to occur for the process, taking into account only passive mitigation systems (containment dike). Based on the process storage quantity modeled and the containment dike surface area, offsite impacts were predicted for the ammonia hydroxide storage process. The Wo rst case scenarios associated with ammonium hydroxide storage at Waxdale is extremely unlikely due to the fact that Johnson Polymer employs a comprehensive Mechanical Integrity Program, high level interlocks, tank pressure relief, emergency stop buttons, daily walkdown inspections, containment dike, etc. to name a few. Alternate Release Scenario A number of somewhat more probable, but still unlikely, scenarios associated with the storage and transfer of ammonium hydroxide were evaluated. EPA's Offsite Consequence Analysis Guidance document was employed to estimate the maximum predicted distances to the toxic endpoint of 0.14 mg/L. 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 Johnson Polymer facility meets w orld class standards for ensuring safe operations. Some of the safety measures employed by Johnson Polymer at the Waxdale facility include: 7 Documented information pertaining to the equipment, technology and chemicals used in the process. 7 A complete Process Hazard Analysis for all affected operations and equipment to identify possible release scenarios and recommendations to mitigate/eliminate such release scenarios. 7 Written operating procedures that include startup, normal operations, emergency operation, operating limits and consequences of deviation. 7 Early detection systems that include high level alarms and interlocks. 7 Mitigation systems that include spill containment dikes, tank pressure relief, etc. 7 Documented employee training on all operating procedures and safety policies and procedures. 7 Comprehensive Mechanical Integrity Program 7 Management of Change/Pre-startup Safety Review Procedure 7 Incident Investigation Procedure 7 Hot Work Permit Procedure 7 Employ ee Participation Guideline 7 Contractor Program 7 Compliance Audit schedule There have been no accidents in the last five years of Johnson's Polymer's operations that have resulted in any offsite impacts to people or the environment. Emergency Response Program Johnson Polymer utilizes 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 D epartment and the Racine County Sheriff's Department. The Brigade regularly trains with the Mt. Pleasant Fire Department. The plant also periodically participates 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. |