Carpenter Co.-Riverside Division - Executive Summary

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Section 1     Executive Summary 
Carpenter Co.-Riverside Division flexible slabstock polyurethane foam manufacturing facility includes one process that uses the RMP regulated substance Toluene diisocyanate (unspecified isomer) (TDI). The flexible slabstock polyurethane foam manufacturing process uses the commercial 80:20 TDI blend (i.e., 80 wt% toluene-2,4-diisocyanate and 20 wt% toluene-2,6-diisocyanate) to produce polyurethane foam and TDI in a binder with scrap polyurethane foam to produce rebond carpet padding.  No other RMP-regulated substances are used at this facility. 
1. Accidental release prevention and emergency response policies. 
It is the policy of the Riverside Division to comply fully with all federal, state and local rules and regulations regarding the proper handling, use, storage, and emergency response preparedness to prevent accidental release of chemicals toxic or otherwise.  Furthermore, the Riverside Division is committed to protecting the health and welfare  
of both its employees and community residents.  Safety depends upon the manner in which we handle TDI combined with (1) the safety devices inherent in the design of this facility, (2) the safe handling procedures that we use, and (3) the training of our personnel. 
Our emergency response program is based upon the requirements in OSHA's Hazardous Waste and Emergency Operations (HAZWOPER) regulation (29 CFR 1910.120) and the Business Plan per state and local regulations. The emergency response plan includes procedures for notification of the Riverside Fire Department (local AA). 
2. The stationary source and regulated substances handled. 
The Riverside Division is located at 7809 Lincoln Avenue, Riverside, CA 92504 and occupies a 618,100 square feet building on 39.8 acres in an industrial-zoned area surrounded by industrial and residential neighbors.  Jefferson Street boundaries the facility on the West, Lincoln Avenue on the South, and Grace Street on the East.  
The Riverside Division  
manufactures polyurethane foam products for use in furniture, carpet cushion underlayment, bedding and other applications.  The manufacturing process incorporates the use of toluene diisocyanate (TDI) as a reactant to produce the foam product.  T.D.I. is received by railcar and occasionally by tanker trucks, and is stored in three indoor storage tanks.  The TDI is pumped from the storage tanks to the pouring line through a strainer, heat exchanger and filter prior to entry into the mix head where it is mixed with other reactants to produce a slab of polyurethane foam.  The foam is moved to a large rack storage system for curing.  After curing, it is sent to cutting stations where it is cut to the size and shape specified by our customers.  Access to the site is restricted to authorized facility employees, management personnel, and contractors.  TDI is the only substance handled at this facility that is regulated by EPA's risk management program (RMP).  The total maximum inventory for T 
DI (710,000 lbs.) was assumed to be two (2) railcars (190,000) lbs. each) and three  (3) storage tanks (110,000 lbs. each).  This exceeds the TDI threshold of 10,000 lbs. 
3. The worst-case release scenario and the alternative release scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario. 
Worst-case Release Scenario: Assessment and modeling was conducted for a worst-case release of toluene diisocyanate from the Riverside Division flexible polyurethane foam manufacturing plant.  Worst-case was assumed to be an immediate release of a railcar quantity (190,000 lbs.) of toluene diisocyanate onto a graded embankment that directs the release into a diked containment area.  During the winter months, we preheat the TDI to a maximum temperature of 110 oF before unloading the railcar.  Because a release at a higher temperature will result in a greater endpoint distance, it was assumed that the release occurs at 110 oF.  TDI has a h 
igh boiling point and a low vapor pressure.  This will result in a plume that is very dilute with a density close to air-a neutrally buoyant plume.  The EPA RMP Offsite Consequence Analysis Guidance Document also indicates that TDI will have a neutrally buoyant plume.   
Modeling needs to be selected based on the type of release anticipated.  In this case, we anticipate a very large pool of a material at ambient temperature and pressure with a very low vapor pressure that will result in a slow, steady release over an extended period of time.  Although there may be a concentrated vapor area in the middle of the pool immediately above the surface of the liquid, the emissions will be very dilute.   The SCREEN3 air model was selected and modeling conducted.  Based on the results of this modeling no emissions of TDI over the toxic endpoint are expected.  The distance to the toxic endpoint concentration of 0.007 gms/m3 is less than 10 feet, which is well within the facility. The nearest facil 
ity boundary is approximately 300 feet.  
4.  The general accidental release prevention program and the specific prevention steps. 
This facility complies with EPA's Accidental Release Prevention Rule; CALEPA's CalARP Program and all applicable state codes and regulations.  To reduce the risk of a release this facility utilizes written procedures, checklists, and formal training in a classroom setting as well as on the job training with testing used for verification of comprehension. 
5.  Five-year accident history. 
We have not had any TDI releases that qualify for listing in the EPA's required five-year accident history report.  We have had two small releases of TDI in the last five years. Both releases resulted in neither onsite injuries, onsite damage, offsite injuries, nor offsite damage. 
6. The emergency response program. 
We have coordinated our program with the local emergency HAZMAT team from Riverside Fire Department (local AA).  A thorough hazop review for the TDI process 
was completed with representatives from the fire department and the local community in November 1997 for our State of California Risk Management Prevention Plan (RMPP) update.  We have given our local hospital and industrial clinic information regarding medical treatment for exposure to TDI. This facility has a trained emergency response team with adequate resources to control most incidences.  If any emergency is beyond our capibilities the local administering agency would be able to provide the necessary resources. 
7. Planned changes to improve safety. 
This facility prepared a State required RMPP in 1997 and all changes to improve safety that were documented during that process have been resolved.  No additional changes are planned at this time.
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