Johns Manville Corporation, Richmond, IN - Executive Summary
Johns Manville International, Inc. |
RMP EXECUTIVE SUMMARY
1) Brief Description of the Richmond, Indiana Facility:
Johns Manville International, Inc., (JM) purchased its Richmond, Indiana, facility in
1937. The facility manufactures fiberglass building insulation which is sold in
commercial, residential, and retail markets. There are approximately 750,000 square feet
under roof on 43 acres of urban property. There are presently about 140 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 leadership. The
Company fosters a proactiv
e 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 Richmond
Facilitys strong recycling and waste minimization programs. 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
2) Brief Description of the Accidental Release Prevention and Emergency Response
Policies at the Johns Manville Facility in Richmond, Indiana:
The Johns Manville fiberglass insulation manufacturing plant in Richmond, Indiana
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 on site 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 glass fibers. This binder solution is applied in the insulation manufacturing
process as a low VOC binder which acts to bind glass fibers. The formaldehyde
containing resin solution is stored as a liquid in several 3,800 gallon storage tanks 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 a dike that
minimizes 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 a release 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. Outs
ide responders would
include the local 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 Distances 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
3,800 gallons of liquid resin, which includes about 12.0% formaldehyde, is
spill with partial containment (dike) in the resin room. Liquid not contained in the resin
room is assumed to spill outside and covers an area to a depth of one centimeter.
Distance to the toxic endpoint of 12.0 mg/m3 is calculated for Richmond 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 Richmond will result in a distance of 0.04 miles to the toxic endpoint. A plant
and topographic map analysis indicates that 0.04 miles from the location of the resin tank
is completely on site. Therefore, the formaldehyde-containing liquid resin process at
Richmond does not qualify for Program 2 of 112R.
4) Brief Description of the Five Year Accident History (68.42):
The Richmond facility has never had an accident involving formaldehyde-containing
liquid resin that caused deaths, injuries, property 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:
. 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
fined 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,
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, notification and numerous other programs