E. R. CARPENTER L. P. - TEMPLE DIVISION - Executive Summary

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

                                                                 CARPENTER CO. 
                                                                 Temple Division 
Executive Summary 
The Carpenter Co., Temple Plant was initially built in 1966 to produce prime flexible polyurethane foam for the furniture industry.  The prime 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. New product lines added over the years include bonded carpet underlay, made from flexible foam trim and recycled foam, and bonded polyester fiber batting. 
Two RMP-regulated substances are used at this facility.  The prime line uses TDI (toluene-2,-4 diisocyanate and toluene-2,-6 diisocyanate), and pentane as a blowing agent.  Pentane is flammable but nontoxic.  The rebond process uses TD 
I blended with polyol to make a binder to bond the particles together.  No other RMP-regulated substances are used at this facility. 
1.  Accidental release prevention and emergency response policies. 
Carpenter Co., Temple Division is committed 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 its employees, the community residents, as well as the environment. 
Our emergency response program is based on the requirements in OSHA's Hazardous Waste and Emergency Operations (HAZWOPER) regulation (29 CFR 1910.120) and both state and local regulations.  The Contingency Plan for the Temple Division includes procedures for notifications of the local fire department, the police department, and the local hospital, when and if such notification becomes 
2.   The stationary source and regulated substances handled. 
The Temple Plant of Carpenter Co., initially constructed in 1966, currently occupies over 532,913 square feet, and is located at 2611 General Bruce Drive in Temple, TX, 76501.  The plant is bound by Interstate I-35 on the north, industrial neighbors on the west, and the Santa Fe tracks and residential neighbors on the west.  Several hundred feet of vacant lot owned by Carpenter Co., bind the south side of the plant. 
The Temple Division manufactures polyurethane foam products for use in furniture, carpet cushion underlay, bedding and other applications.  The manufacturing process incorporates the use of toluene diisocyanate (TDI) as a reactant to produce the foam product.  TDI is received by railcar with approximately 185,000 pounds, and is stored in several indoor storage tanks.  The largest of which holds 12,000 gallons.  All TDI tanks are located inside the plant within containments.  The TDI is pumped to the 
mixing head where it is mixed with other reactants to produce a continuous slab of flexible polyurethane faom.  The foam is cut into 50 and 100 foot slabs and stacked in the slab room to cure. 
Pentane is used in some foam formulations as a blowing agent.  It is received in tank trucks and is stored outside in a 76,125-pound capacity tank placed within a concrete containment.  The pentane is held under a 3-4 pound per square inch pressure nitrogen blanket.  The pentane is pumped through underground welded, double wall lines to the process equipment inside.  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 Release Scenario 
TDI: Assessment and modeling was conducted for a worse case release of toluene diisocyanate from the Templ 
e Division.  The worst case was assumed to be the immediate release of (185,000 lbs.) Of toluene diisocyanate at 120 F, (during the winter months, TDI must be heated to prevent freezing and stratification of the isomers) onto the rail dock unloading area which is located inside the plant.  TDI has a high boiling point and a low vapor pressure.  This will result in a neutrally buoyant plume close to the density of air.  The EPA RMP Offsite Consequence Analysis Guidance Document also indicates that TDI will have a neutrally buoyant plume.  
Modeling based on the release of 185,000 lbs of TDI @ 120 F onto an area of 4,263 square feet located inside the plant would result in a worst case scenario of 277 feet or 0.052 miles.  This would place the toxic endpoint beyond the fence line on the other side of the rail tracks.  It would not extend to the residential areas at 0.1 miles. 
Pentane: The worse case for a pentane release is a vapor cloud explosion resulting from a rupture of a 76,125-po 
und capacity tank in a dike area.  According to EPA guidance for pentane vapor cloud explosions, the impact radius is 0.4 miles.  The residential population within this end point is estimated to be approximately 202 persons. 
Alternative Release Scenario 
TDI: The alternative case for a TDI spill is the rupture of a 120,000-pound tank in the enclosed building with a dike around the area.  According to EPA Guidance for TDI spills at a temperature of 140 F (the maximum temperature at which TDI is stored awaiting use in the process), the impact radius is less than 0.1 miles. 
Pentane: The alternative case for a pentane release is a liquid pool fire resulting from a rupture of a 76,125-pound capacity tank in a dike area.  According to EPA guidance for pentane liquid pool fires, the impact radius is 0.2 miles.  The residential population within this end point is estimated to be approximately 50 persons. 
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 State of Texas codes and regulations required by the Texas Natural Resource Conservation Commission.  Personnel training with air packs and practice drills for emergencies and spill response are an important part of our safety and preventive measures. 
5.  Five Year Accident History. 
We have had one reportable TDI release in the past five years.  It was less than 200-pounds and was in containment inside the plant.  Emissions were estimated to be less than one-pound.  There were no injuries, and no personnel exposure.  It was the result of an employee disregarding operating procedures.  The employee was reprimanded. 
6.  The Emergency Response Program. 
This program is referred to as the Contingency Plan for the Temple Division.  It was last revised December 1, 1997.  It includes a listing of the trained Environmental (Spill) Response Team by name, shift, and phone number and the trained Fire Eme 
rgency Action Team.  The teams are trained and drilled to response to an emergency or spill when the alarm is sounded.  Information with regards to the hazardous chemicals has been given to the local fire department, the police, and the local hospitals and clinic. 
7.Planned Changes to Improve Safety. 
Employees are regularly scheduled for Hazardous Materials Handling training as well as spill drills.  Training in the use of SCBA equipment is conducted regularly on the spill teams.
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