Carpenter Co. - Russellville Division - Executive Summary |
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EXECUTIVE SUMMARY ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES It is the Carpenter Co.'s policy to adhere to all applicable federal and state rules and regulations. Safety depends on the manner in which the facility handles TDI, the safety devices inherent in the design of the facility, the safe handling procedures used, and the training of its personnel. The Carpenter Co. - Russellville Division has a corporate health and safety policy, environmental policy, and work procedures in place to prevent accidents and releases from happening. THE STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED The Carpenter Co.-Russellville Division is located at 200 Forrest Park Drive, Russellville, Kentucky, and manufactures various types of polyurethane foam padding products, including foam-cushioning products for furniture, carpet padding, and similar uses. The RMP regulations cover the unspecified isomer toluene diisocyanate (TDI) process at this facility. An evaluation of the chemical usage, accident history, and worst-case release scenario at the Russellville Division indicates that Program 2 requirements of the Risk Management Program (RMP) apply to this plant. The Russellville Division has the potential to maintain up to 1,225,000 pounds of TDI, CAS Number 26417-62-5, at the plant at one time. This is in excess of the threshold value for RMP applicability. The threshold value for TDI is 10,000 pounds. The Russellville Division maintains no other regulated substances above the threshold value for RMP applicability. THE WORST-CASE RELEASE SCENARIO AND THE ALTERNATIVE RELEASE SCENARIO, INCLUDING ADMINISTRATIVE CONTROLS AND MITIGATION MEASURES TO LIMIT THE DISTANCES FOR EACH REPORTED SCENARIO Worst-Case Scenario - The worst-case release scenario would be the loss of the entire contents of a railcar of TDI forming a "liquid release" over a period of one hour. There is passive mitigation for this area and the surface are a of the "liquid release" would be 12,000 square feet containing 20,459 gallons or 208,272 pounds of TDI. Because the facility has passive mitigation in place, only 23.1 pounds of TDI would be released to the atmosphere. Additionally, TDI is heated to a maximum of 1300 F to facilitate pumping. Without the current mitigation systems in place the release of TDI to the atmosphere would be much greater. The distance to the end point for the worst case scenario is 124 yards or .07 miles. However, this scenario is highly unlikely, due to regular inspections, proper training of personnel, and past historical data and is reported here only as required by provisions of the RMP regulations. A much more realistic scenario is presented as the alternative release scenario. Alternative Release Scenario - The alternative release scenario chosen is based on a hose coming loose during the transfer of TDI to the storage tanks. This could occur both at the railcar unloading and at the tank truck u nloading. In the railcar unloading, the unloading is from the top of the rail car and the amount released would represent the amount in the hose at the time it came loose. This would amount to 0.98 gallons (2-inch ID and 6 foot length hose) of TDI. In the tank truck unloading, if the hose came loose, the amount of material spilled would be based on the amount of material in the hose that is 2 inches in diameter and 20 feet long. The volume of the hose is 0.56 ft3. This equates to 4.19 gallons (42.64 pounds). The puddle will cover an area of 1.58 square meters with a depth of 1 centimeter. The distance to the end point for the alternative release scenario is 10.9-yards or .006 miles. This would place the impact zone on the property of the Carpenter Co.-Russellville Division and there would be no public or environmental receptors impacted. In making its calculations, the ambient temperature utilized by the Russellville Division was taken from the EPA standard temperature of 770 F. The three-year average temperature was not used because it is below the freezing point for TDI. Also, urban modeling setting was used instead of rural. THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND SPECIFIC PREVENTION STEPS The Russellville Division has in place a prevention program encompassing elements consistent with the US EPA Clean Air Act 112(r) (7) Accidental Release Prevention Requirements: Risk Management Programs (RMP) (40 CFR Part 68). The facility has implemented the following: 1. A comprehensive Process Safety Information program, which ensures complete and accurate written information concerning process chemicals, process technology, and process equipment. This information is included in the employee training programs. 2. Process Hazard Analysis (PHA) is conducted to identify and analyze the potential hazards associated with the processing or handling of highly hazardous chemicals. 3. The preparation of operating procedures that describe tasks to b e performed, operating conditions to be maintained, data to be recorded, and safety precautions to be taken. 4. An employee training program to ensure that all employees, including maintenance and contractor employees involved with chemicals, fully understand the potential hazards of each chemical. 5. A maintenance program to assure the integrity of process equipment. It ensures that all maintenance personnel are trained and that the equipment is tested and inspected as recommended. 6. Compliance audits to review all relevant documentation, verify process safety information, inspect the physical facilities and conduct interviews with representative plant personnel. 7. An Incident Investigation to be conducted in the event of any chemical release or "near miss" by a team of experienced individuals familiar with the process. Any recommendations are documented and discussed. 8. An emergency response program for the entire facility in the event of a chemical release. FIVE-YE AR ACCIDENT HISTORY During the past five years, the Russellville Division has had no chemical releases which created an emergency situation outside the plant boundaries nor resulted in any deaths, injuries, or significant property damage onsite or known offsite deaths, injuries, evacuations, sheltering in place, property damage or environmental damage. THE EMERGENCY RESPONSE PROGRAM The Russellville Division has "Emergency Procedures" in place to inform employees how to communicate with local agencies and how to respond to an accidental release. Plant personnel are trained in emergency procedures and emergency notifications. Trained personnel respond to emergencies in their area with the local Fire Department as a back up. This program has been discussed with the Logan County Emergency Planning Committee (LEPC) and the Russellville City Fire Department to ensure good communication and operational effectiveness. PLANNED CHANGES TO IMPROVE SAFETY The Russellville Division plans t o continue to evaluate the regulated process as required under the RMP standards to ensure safe operations. |