| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

The Carpenter Co.,Tupelo Division operates  the facility with attention and  a   serious commitment to the implementation of safe work procedures and the protection of the environment.  The Tupelo Division utilizes an Integrated Contingency Plan (ICP) to manage emergency response activities at the facility.  The implementation of the ICP at the facility is directed related to the degree of training given to the Tupelo Division employees in regard to chemical releases and emergencies, fire evacuations and preparation for response to the effects of natural disasters.  The Tupelo Division's attention to Accidental Release Prevention is evidenced directly by the operation not having any reportable quantity (RQ) releases of Toluene diisocyanate during the previous 5 reporting years.                    
2.  FACILITY DESCRIPTION & REGULATED SUBSTANCES HANDLED                                                                 The Tupel 
o Division is located at 184 Lipford Drive, in the Tupelo-Lee Industrial Park located approximately 10 miles South of the city of Tupelo.  The Tupelo Division employs approximately 215 full time employees.  The facility manufactures polyurethane foam products for the use in furniture, cushioning, bedding, and other applications.  The polyurethane foam manufacturing process utilizes toluene diisocyanate (TDI) [unspecified isomers], CAS# 2647-62-5, in the respective process.  The Tupelo Division facility has a total TDI storage capacity of  approximately 3,250,000 pounds.  The facility maintains two railcars with approximately 185,000 pounds each of TDI, one day tank (T-15) with approximately 193,040 pounds of TDI, and two storage tanks (T-16 & T-17) with approximately 1,343,152 pounds of TDI each.  All TDI process tanks are maintained inside of the manufacturing facility with the railcars being located outside.  The railcar unloading station is equipped with secondary containment diking 
and a sump capable of retaining the volume of one railcar. 
The Tupelo Division utilized the modified Offsite Consequence Guidance (Lookup Tables) developed for the Polyurethane Foam Manufacturing Industry.  These tables were approved for use by the EPA.  The Worst-Case Scenario consisted of the loss of one railcar of TDI, approximately 185,000 pounds at approximately 130 F, into a diked sump area of approximately 4,000 square feet.  The use of the diked sump area limits the exposed surface area of the pool to  approximately 4,000 square feet, thereby limiting the total estimated quantity of TDI released to approximately 10,000 pounds, with a toxic endpoint distance of approximately 335 feet or 0.06 miles.  The only receptors within this distance would be another polyurethane foam manufacturer, located immediately west (~120 feet) of the Tupelo Division facility.  
The Tupelo Division considered one Alternative Case 
Release Scenario with respect to the release of TDI.  
It consisted of the release of approximately 1,250 pounds of TDI due to a railcar transfer hose failure.  This scenario utilized a release rate of approximately 0.3 pounds per minute for a period of 60 minutes.  The wind speed of 3.0 meters per second, Urban topography, and an atmospheric stability class of D was utilized in the scenario.  The toxic endpoint distance was determined using the modified lookup tables used in the Worst Case Scenario.  The toxic endpoint was determined to be approximately 105 feet or 0.02 miles.  This scenario would not have any impact off of the Tupelo Division facility property, due to the nearest adjacent facility being approximately 120 feet. 
At the time of this RMP submittal, the Tupelo Division is not subject to the OSHA Process Safety Management (PSM) program, however, the facility is preparing for the implem 
entation of the PSM program should TDI be added to the list of PSM regulated chemicals, as expected.  The Tupelo Division has implemented the RMP Program 2 Prevention Program, as described in the RMP regulations, at this facility which includes the following elements:  TDI Safety Information - TDI Production Process & TDI properties, Health Considerations, Environmental Considerations, Emergency Procedures, & MSDS Sheets; Hazard Review utilizing "What-If Checklists"; Standard Operating Procedures & Policy Statement - TDI Unloading Procedures, Transfer Pump Operating & Shutdown Procedures, Recirculation Pump Operating & Shutdown Procedures, Metering Pump Operating & Shutdown Procedures, Pour Line Operation; TDI Training; Mechanical Integrity Procedures - TDI System Inspection, Test & Preventative Maintenance Plan and Corrective Action Report; RMP Compliance Audits; and TDI Incident Investigations.  
During the five years previous to this RMP Program develo 
pment, theTupelo Division has not experienced any Reportable Quantity (RQ) releases or accidents involving Toluene diisocyanate (unspecified isomers). 
The Tupelo Division, utilizes an Integrated Contingency Plan (ICP) to outline the emergency response activities for each type incident that may occur at the facility.  The facility works closely with the other TDI users located in the Industrial Park for a coordinated emergency notification network.  In addition, the Tupelo Division, Safety and Environmental Manager is an active participant with the local Lee County LEPC.  The facility conducts semi-annual evacuation drills in response to simulated natural disasters, fire, and or chemical emergencies.  Tupelo Division operations and support personnel receive training in hazard recognition and TDI awareness as well as a thorough MSDS review. 
The Tupelo Division, operates with an attention to employee awareness and emph 
asizes ongoing training of all personnel.  Operationally, the facility is planning on installing a cover on the TDI containment sump to further limit the volume of TDI vapor released in the event of an uncontrolled release.
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