Johns Manville Corporation, Willows, CA - Executive Summary |
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Johns Manville International, Inc. Willows, California RMP EXECUTIVE SUMMARY 1) Brief Description of the Willows, California Facility: The Johns Manville (JM) Plant in Willows, California was constructed in 1973. The facility manufactures fiberglass building insulation which is sold in the commercial, residential, and retail markets. The facility currently encompasses approximately 701,250 square feet under roof and is set in 478 acres of rural area. There are presently about 375 full time employees who operate the Plant 24 hours a day, 365 days a year. Johns Manville places a strong emphasis on safety and environmental leadersh ip. The Company fosters a proactive philosophy to ensure that employees work in a safe environment and that each facility remains in full compliance with all applicable federal, state, county and local regulations. JM is also committed to environmental leadership within the community served. This commitment is exemplified in the Willows Facilitys strong recycling and waste minimization program development. The Companys long term goal is to have zero process wastes taken to disposal facilities, with all residual materials either recycled or used for beneficial purposes. The facility maintains a good working relationship with all federal, state, county and local agencies. 2) Brief Description of the Accidental Release Prevention and Emergency Response Policies at the Johns Manville Facility in Willows, California: The Johns Manville fiberglass manufacturing plant in Willows, California qualifies for the USEPA 112R (40 CFR 68) requirements due to the use of formaldehyde. The facility exceeds the qualifying threshold of 15,000 pounds of this material onsite for a single process. Liquid resin solution containing formaldehyde (above 1% mixture) is delivered to the facility via truck transport. Resin solution is stored in cold storage until it is mixed with water and other materials to make a binder solution (less than 1% formaldehyde) which is applied to fiberglass. This binder solution is applied in the fiberglass manufacturing process as a low VOC binder which acts to bind glass fibers. The formaldehyde containing resin solution is stored as a liquid in numerous storage tanks (ranging in size from 4,500 to 6,000 gallon maximum capacity) located inside the facility. The storage vessels are constructed and operated in accordance with ASME specifications. The resin storage process is designed to minimize spills in the event of an accidental release. The resin storage room is equipped with trenches that minimize the surface area of a spill. In addition, the resin storage room is maintained at 50 degrees F to reduce the volatility of the material. Although not a qualifying mitigation measure for the 112R program, low storage temperatures give plant personnel adequate time to react to the situation by reducing the volatilization rate of the resin material. As a result of these factors, Johns Manville has not experienced an accidental release of formaldehyde over the entire life of the facility. Modeling impacts indicate that a worst-case release of formaldehyde from the resin storage tanks would not impact the public beyond the Facilitys property line and therefore is qualified as a Program 1 facility. With the exception of minor incidents, it is the Facilitys policy to immediately contact and rely on outside emergency responders in the event of a significant unforeseen or accidental release of formaldehyde-containing liquid resin. Outside responders would include the community fire department and other community or contractor services as required. 3) Brief Description of the Worst Case Scenario, including Administrative Controls and Mitigation Measures to Limit the D istances for each Reported Scenario: According to 40 CFR 68, the worst-case scenario is to be based on the release of the greatest amount held in a single vessel, taking into account administrative controls that limit the maximum quantity. Under a worst-case scenario, a single vessel containing 6,000 gallons of liquid resin, which includes about 12.0% formaldehyde, is assumed to spill with complete indoor containment in the resin room and adjacent water room. Distance to the toxic endpoint of 12.0 mg/m3 is calculated for Willows using AFTOX, a dispersion model that will determine toxic chemical concentrations at hazard distances. According to AFTOX, a worst-case resin spill and subsequent formaldehyde vaporization onsite at Willows will result in a distance of 0.06 miles to the toxic endpoint. A plant and topographic map analysis indicates that 0.06 miles from the location of the resin tank is completely onsite. Therefore, the formaldehyde-containing liquid resin process at Willows does not qualify for Program 2 of 112R. 4) Brief Description of the Five Year Accident History (68.42): The Willows facility has never had an accident involving formaldehyde-containing liquid resin that caused deaths, injuries, pro perty or environmental damage, evacuations, or sheltering in place. 5) Brief Description of the Emergency Response Program (68.90 68.95): In the event of an emergency involving the Facilitys formaldehyde-containing liquid resin system, it is the Facilitys policy to notify the local fire department and other emergency responders and request that they respond to the emergency. Plant personnel have discussed this policy with the fire department; members of the fire department have inspected the facility. In addition to the emergency action and notification procedures described earlier in this document, Johns Manville complies with and maintains numerous other operational programs for the purpose of promoting employee safety and minimizing potential hazards to the surrounding community. These include, but are not limited to: a. Emergency Hotline notifications b. Spill, Prevention, Control and Countermeasure Plan and equipment. c. RCRA Contingency Plan d. Hot Work Permit Program e. Safety Lockout-Tagout Program f. Extensive safety programs throughout the location g. Fire Prevention Plan h. Bomb Threat Plan i. Agency, insurance and physicians inspections j. Job Safety Analyses k. Confined Space Entry procedures l. Injury Investigation Procedure and Root Cause Analysis m. New and Altered Equipment Inspection (Management of Change) n. Outside Contractor Review Policy o. Community Emergency Response Coordination Policy p. Various emergency communication systems throughout the facility such as audible alarms, paging systems, hand-held radios, phones, visual alarms. q. Right-To-Know Notification Programs issued to State and local agencies (Emission Release Reports, SARA Title III, etc) r. Extensive and detailed employee training in all phases of job related safety, chemical awareness, handling potential spills, HAZCOM, RTK, emergency procedures, noti fication and numerous other programs |