Hickory Springs of California - Commerce, CA - Executive Summary |
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Executive Summary Hickory Springs Manufacturing Co. Hickory Springs of California, Inc. Commerce, CA Hickory Springs Manufacturing Co. and its subsidiary operations are committed to operating and maintaining its facilities and processes in a safe and responsible manner, which provides safe conditions for Company employees, the surrounding community and the environment. Our Commerce facility manufactures flexible polyurethane (PU) foam products for the furniture and bedding industries. One of the major chemical ingredients used in the pu foam manufacturing process is Toluene diisocyante (mixed isomers) (TDI), CAS # 26471-62-5 which is commercial blend containing approximately 80% TDI 2-4 (CAS # 584-84-9) and 20% TDI 2-6 (CAS # 91-08-7). Our TDI inventory is maintained above 10,000 lbs. In accordance with the provisions of 40 CFR 68 (Risk Management Program Regulations - RMP), the worst case scenario was defined as the rupture of, and the immediate spillage of, the contents of a TDI railcar. The impact of this spill was evaluated using the ALOHA model and resulted in the area of concern affecting public receptors within a 219 yard radius of the railcar unloading station which classifies the pu foam manufacturing process at this facility as a Program Level 2. The release rate, calculated by the ALOHA model, was 1.07 lbs./min. Two alternate scenarios-the rupture and spillage of TDI from the largest storage tanks, which are located within concrete containment areas, were also evaluated using the ALOHA model and resulted in the areas of concern being confined within the facility's property boundary and no public receptors being affected. The release rates for the alternate scenarios, calculated by the ALOHA model, were from 0 .0101 to 0.0177 lbs./min. This facility has a hazmat team, which will provide initial response to any and all spills, despite the substance or size. This facility also has contracted professional emergency responders as back-up. If required, the assistance of the Los Angeles County fire department hazmat team will be requested. This facility's emergency response and contingency plan has been coordinated with the LEPC, local fire department and the local fire department hazmat commander. All employees responsible for the handling and control of hazardous substances are provided initial and refresher training in proper procedures as required by EPA, OSHA and DOT standards and regulations. There have been no accidents with regard to spillage of substances at this facility within the last five years. By the end of the fourth quarter 1999, a concrete containment area for the railcar unloading station will be construction. Upon completion, a worst case Offsite Consequence Analysis (O CA) will be conducted and this facility will resubmit an RMP to reclassify the pu foam manufacturing process as a Program Level 1. No other changes to the procedures or methods of pollution prevention are to be made at this time. Procedural changes may be implemented in the future if revaluation deems them necessary. |