Lear Corporation - Detroit Operations - Executive Summary |
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EXECUTIVE SUMMARY Description of facility and regulated substance handled Lear Corporation's Detroit facility manufactures flexible foam based seating for the automotive industry. Foam based seating components are produced by the polymerization of materials in closed molding processes. The regulated substance,unspecified isomer toluene diisocyanate (TDI), is stored in a 11,200 gallon above ground epoxy lined storage tank for use as one of the foam making components. The storage of TDI is state of the art. The storage tank is installed above ground in a building and within a concrete containment area that is capable of holding 150 percent of the contents of the tank. The TDI storage tank bears a nameplate with the marking and the certification for pressure vessels that it was built in accordance with Division I Section VIII standards of the American Society of Mechanical Engineers'. The TDI storage tank and containment area were last inspected in April, 1999, by a member of the Detr oit Fire Department's Emergency Management Division. Chemical specific prevention Lear Corporation monitors the TDI storage tank local atmosphere with two sensing devices with associated alarms. The alarm system is a two-stage alarm system known as MDA-7100 Continuous Toxic Gas Monitor. The alarm system gives a yellow alert signal if the concentration of TDI reaches 5 parts per billion but below 20 parts per billion. The alarm system is monitored year round by a private company. Worst Case Scenario A toxic worst case scenario was evaluated through the use of the United States Environmental Protection Agency's "Offsite Consequences and Analysis" (OCA) Document and the Areal Locations of Hazardous Atmospheres (ALOHA) computer modeling tool. The worst case considered was the instantaneous failure of the storage tank in which a liquid pool is formed and evaporates. In the worst case assessment, the toxic release was passively mitigated by the tank's 422 square feet of containment a rea and the building in which it is located. A release rate of 0.002 pounds per minute was calculated in accordance with the OCA release rate methodology for passive mitigation and releases inside a building. (Note: The EPA electronic submittal program "RMP Submit" did not permit a value less than 1.0 pounds per minute to be entered.) This release rate was input to ALOHA as the source strength parameter. The release was modeled at at a wind speed of 1.5 meters per second and F stability, a three year high temperature of 96 F and a 30 year average humidity of 71 per cent. (The Detroit Metro Airport was the source of the temperature and humidity data and was provided by the Michigan Department of Environmental Quality.) The toxic release was modeled as a gaussian dispersion for a level of concern of 1 ppm. A distance of 60 feet was calculated by the model to the level of concern. (Note: The EPA electronic submittal program "RMP Submit" did not permit distance to endpoint values of less than 0.1 miles.) The model's calculated distance to the level of concern is within the plant property boundary in every direction. Based on the modeling result, public receptors are predicted not to be impacted in a worst case release scenario. The Emergency Response Program Written emergency plans for TDI spills have been in place in accordance Spill Prevention Control and Countermeasures and Pollution Incident Prevention Plan (SPCC/PIPP) provisions of the Federal Water Pollution Control Act (40 CFR 112) and the Michigan Natural Resources and Environmental Protection Act (NREPA) since April, 1987. The SPCC/PIPP provides the procedures to be followed in the event of a spill discovery. The Spill Coordinator is the responsible person for coordinating spill response efforts. At all times, the Spill Coordinator will be at the facility or will be on call and within one hour travel distance from the facility. In situations deemed necessary by the Spill Coordinator, Emergency M anagement of the Detroit Fire Department is to be notified for assistance. Employees receive safety and spill response video training annually. With this training, employees get the latest informaton on the proper use of safety equipment, safe handling of chemical materials, fire fighting and spill response procedures. The five-year accident history Lear Corporation has had an accident and incident free five year history operating this process. Moreover, dating back with certainty to 1986 and likely beyond that , a reportable TDI spill has not occurred at the facility. Planned changes to improve safety Lear Corporation has no planned changes to improve the safe operation of the process. |