Carpenter Co., Conover Division - Executive Summary |
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The Carpenter Co., Conover Division was initially built to produce flexible polyurethane foam for the furniture industry. The pouring line has been expanded and modified several times over the ensuing years in order to improve the process, both with respect to equipment and with respect to chemistry, to conform to new state and federal regulations, and to meet ever increasing and changing demands by our customers. A bonded polyester fiber batting has subsequently been added. Two RMP regulated substances are used at this facility. The line uses TDI (toluene-2,-4 diisocyanate and toulene-2,-6 diisocyanate), and pentane as a blowing agent. Pentane is flammable but nontoxic. No other RMP-regulated substances are used at this facility. 1. Accidental release prevention and emergency response policies Carpenter Co., Conover Division is committed to comply fully with all federal, state, and local rules and regulations regarding the proper handling, use, storage, and emergency response p reparedness to prevent accidental release of chemicals, toxic or otherwise. Furthermore, Carpenter Co. is committed to protecting the health and welfare of its employees, the community residents, as well as the environment. An Emergency Response procedure for Carpenter Co. Conover Division has been developed and is located in the Contingency Plan. This plan includes the procedures for informing the public and emergency response agencies when an accidental release occurs, documentation of proper first-aid and emergency medical treatment necessary to treat accidental human exposure, and procedures and measures for emergency response after an accidental release of a regulated substance. 2. The stationary source and regulated substances handled The Conover Division, located at 2009 Keisler Dairy Road, manufactures polyurethane foam products for use in furniture, carpet cushion underlay, bedding and other applications. The manufacturing process incorporates the use of TDI as a reactan t to produce the foam product. TDI is received primarily via railcars which holds approximately 190,000 lbs although tank trucks may be used if conditions warrant. When required, the rail carrier moves the railcar from an outside holding area to the indoor unloading area. Transfer hoses and associated equipment are connected and the unloading process is initiated. TDI is transferred from the railcar to three 12,000 gallon storage tanks located in the interior tank farm near the pouring station. TDI is pumped from the storage tanks to the pouring line through a strainer and heat exchanger prior to entry into the mix head. In the mix head, TDI is combined with polyol, pentane, and other minor raw materials to initiate the foam production reaction. Pentane is used as a blowing agent. It is received by the facility in railcars which are off-loaded into a 30,000 gallon storage tank placed within a concrete containment. Pentane is held under a nitrogen blanket. Pentane is pumped direc tly from the storage tank to the pouring line where it enters the mix head. There are monitors in the process areas to insure the accumulation of pentane is well below an explosive mixture. 3.The worst-case release scenario and the alternative release scenario, including administrative controls and mitigation measures to limit the distance for each reported scenario. Worst Case Scenario (WCS) for TDI Based on the RMProgram regulation, the input required for the worst-case scenario is the worst-case release amount, release time, mandated meteorological conditions, and the toxic endpoint. For the TDI system, the worst-case release amount is the quantity of the single largest container (190,000 lbs). Because TDI is a liquid at ambient temperature, the worst-case release amount (190,000 lbs) is completely spilled, forming a pool as specified in the RMProgram regulation for toxic liquids. The liquid release of 190,000 lbs results in an evaporation rate of 0.532 lb/min. As required by the RMProgram regulation, the meteorological conditions for a WCS are a wind speed of 3.4 miles per hour (mph) and F stability class. For this extremely conservative WCS, the distance to the toxic endpoint for the WCS is 0.27 mile that encompasses an affected area of 0.23 square miles. It is estimated that a population of 100 is located within the affected area. Public receptors within the impact area include residential areas, and commercial/industrial areas. There are no environmental receptors affected. Alternate Release Scenario (ARS) for TDI As determined by the PHA under the Accident Prevention Program, the ARS for the TDI process is the TDI transfer line from the railcar fails during transfer resulting in a liquid release. It was assumed that the release was mitigated within ten (10) minutes of the initiating event. No credit was taken for passive mitigation, since the release would not be in a contained area. The liquid release rate is 800 lb/min, with a release dur ation of ten (10) minutes, resulting in an evaporation rate of 0.0016 lb/min. The ARS meteorological conditions are a wind speed of 6.14 mph and AB@ stability class. In order to determine the typical wind speed and temperature for the ARS, meteorological data for Station 13881 (Asheville) for 1992 and 1993 were obtained from the National Oceanic and Atmospheric Administration in Asheville, North Carolina. The modal or prevalent temperature (62 oF) and wind speed (6.14 mph) were used as the typical weather conditions for the ARS. Worst Case Scenario (WCS) for Pentane Based on the RMProgram regulation, the input required for the worst-case scenario is the worst-case release amount, mandated meteorological conditions, and the overpressure endpoint. Because pentane is a liquid at ambient temperature, the worst-case release amount (157,500 lbs) is completely spilled into the diked area forming a pool as specified in the RMProgram regulation for flammable liquids. The liquid release of 157,500 lbs results in an evaporation rate of 158 lbs/min, with a release duration of 10 minutes. Given pentane is a volatile flammable liquid, the worst-case release amount (1,580 lbs) is released in a vapor cloud. A vapor cloud explosion is assumed to result from the release as specified in the RMProgram regulation for volatile flammable liquids. As required by the RMProgram regulation, the meteorological conditions for a WCS are a wind speed of 3.4 miles per hour (mph) and F stability class. 4.The general accidental release prevention program and the specific prevention steps. This facility complies with EPA's Accidental Release Prevention Rule and all applicable North Carolina requirements. Personnel training with protective equipment and practice drills for emergencies and spill response are an important part of our safety and preventive measures. 5. Five Year Accident History. Carpenter Co., Conover Division has not had any TDI or pentane releases in the past five years fr om Carpenter Co., Conover Division. 6. The Emergency Response Program An Emergency Response procedure for Carpenter Co. Conover Division has been developed and is located in the Contingency Plan. This plan includes the procedures for informing the public and emergency response agencies when an accidental release occurs, documentation of proper first-aid and emergency medical treatment necessary to treat accidental human exposure, and procedures and measures for emergency response after an accidental release of a regulated substance. 7. Planned Changes to Improve Safety Employees are regularly scheduled for Hazardous Materials Handling training as well as spill drills. Emergency response training for the employees identified as responders is conducted regularly. Also, numerous safety topics are addressed and discussed which promotes and emphasizes the importance of safety awareness at the Conover Division. |