Carpenter Co., Lakeland Division - Executive Summary |
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Accidental Release Prevention and Emergency Response Policies 40 CFR ' 68.155(a) It is the policy of Carpenter Co., Lakeland Division (Carpenter) 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, Carpenter Co. is committed to protecting the health and welfare of both its employees and community residents. Carpenter seeks to prevent an accidental release by having: a. Training and testing programs b. Safety check sheet c. Equipment inspections Its emergency response is based upon the requirements in OSHA's Hazardous Waste and Emergency Operations (HAZWOPER) regulations (29 CFR ' 1910.120) as well as state and local regulations. For emergency response, it has in place the following: a. Contingency plan b. Evacuation plan c. Chemical spill procedures d. First aid and CPR training Specific details about t he accidental release prevention and emergency response policies are contained in the sections below entitled "General Accidental Release Prevention Program and Chemical-Specific Prevention Steps" and "Emergency Response Program," respectively. Stationary Source and Regulated Substances Handled 40 CFR ' 68.155(b) Carpenter, located at 5150 Frontage Road South in Lakeland, Florida, manufactures polyurethane foam for use as carpet padding. Carpenter has the potential to store more than 125,000 pounds of unspecified isomer toluene diisocyanate (TDI), CAS Number 25471-62-5, at the plant at one time. This exceeds the 10,000 pounds threshold value for RMP applicability for TDI. Carpenter maintains no other regulated substances above the threshold values for RMP applicability. Carpenter stores TDI in a 12,000-gallon (125,000-pound) tank, a mix tank that can store 17,850 pounds of TDI, and a day tank that stores a maximum of 20,000 pounds of TDI. TDI is transported to Carpenter in tank t rucks containing up to 45,000 pounds of TDI. Worst-case Release Scenario 40 CFR ' 68.155(c) The worst-case release scenario involves the release of 125,000 pounds of TDI from a 12,000-gallon storage tank. The TDI would spill on the floor within the plant. In this scenario, the maximum TDI vapor endpoint distance would be about 0.2 miles from the center of the plant. The property boundary is greater than 0.2 miles from the center of the plant in any direction. Therefore, the distance to the endpoint for the worst-case release is less than the distance to the nearest public receptor. The worst-case release scenario was evaluated using methods described in the EPA's "Offsite Consequence Analysis Guidance" and the EPA approved gaussian plume model ISCST3. In Carpenter's worst-case release scenario, the TDI was assumed to be at 120 : F or less, the tank is indoors, and an urban topography was used. General Accidental Release Prevention Program and Chemical-Specific Prevention Steps 40 CFR ' 68.155(d) Carpenter's Hazard Communication Program assures that chemicals are properly labeled and that employees understand the specific precautions they must use when working with the chemicals in the area. This helps maintain a safe working environment. In addition, Carpenter has a Storm Water Pollution Prevention Plan that requires it do monthly inspection of the facility to assure that its practices are not causing a release of materials to the storm water system. It also has a chemical hygiene plan, which describes the procedures and laboratory personnel must use when working with chemicals to assure a safe working environment. Laboratory personnel review the contents of the plan annually. Carpenter also has a TDI monitoring policy. All employees working regularly in areas where TDI is used or handled are monitored for TDI exposure at least once every sixty days. In addition, certain designated areas where a TDI spill could occur and result in employee exposure ar e monitored for TDI levels every operating day. Tanks containing pure TDI have high-level alarms that help prevent them from being overfilled. Each storage tank is connected through piping and uses valves to prevent any chance of cross-leaking. All employees who generate or otherwise manage hazardous waste are trained to assure Carpenter's hazardous waste management meets the requirements of the state and federal government. Five-year Accident History 40 CFR ' 68.155(e) Carpenter has had no accidents in the past five years that would disqualify it from Program 1 applicability. Emergency Response Program 40 CFR ' 68.155(f) Carpenter follows a document entitled, "Carpenter Co. Contingency Plan" (the Contingency Plan) as its emergency response program. The Contingency Plan contains fire emergency procedures, explosion emergency procedures, and spill response procedures. It establishes the method of notification, control, and clean up of hazardous materials in the event of an unexpe cted release at the plant. As required an updated copy of the Contingency plan will be provided to the Central Florida Regional Planning Council (District 7 Local Emergency Planning Committee), the Florida Department of Environmental Protection, and any additional appropriate agencies. Carpenter's Spill Response Team (the Spill Team) is drilled semi-annually to assure they properly respond to a spill. They are also trained in the hazardous material training required by 1910.120 of the Occupational Safety and Health Standards. Whenever new types of equipment are purchased to respond to spills, the Spill Team is trained to use the new equipment. Planned Changes to Improve Safety 40 CFR ' 68.155(g) The polyurethane operation at the Lakeland Division is a new operation and no changes are proposed at this time. |