Hickory Springs Mfg. Co. - Conover, NC - Executive Summary |
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Executive Summary Hickory Springs Manufacturing Co. Conover, NC 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 Conover facility manufactures flexible polyurethane (PU) foam and flexible polyethylene foam products for the furniture, bedding and construction industries. One of the major chemical ingredients used in the pu foam manufacturing process is Toluene diisocyante (mixed isomers) (TDI), CAS # 26471-62-5. 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 into a concrete containment area. The impact of this spill was evaluated using the ALOHA model and resulted in the area of concern being confined within the facility's property boundary with no public receptors being affected. The release rate, calculated by the ALOHA model, was 0.0248 lbs./min. One of the ingredients used in the flexible polyethylene foam process is isobutane (Cas # 75-28-5). Our isobutane 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 vapor cloud explosion of, the contents of the isobutane storage tank. The impact of this explosion was evaluated using EPA's RMP Comp software and resulted in an area of concern which extends 0.3 miles from the storage tank, which is beyond the facility's property boundary and does affec t public receptors. Two alternate release scenarios were also evaluated using RMP Comp-the rupture of a 1 inch pipe from the tank to the process and the rupture of a 4 inch unloading hose caused by truck driver pull away during unloading. The pipe rupture resulted in an area of concern which extends 0.07 miles from the storage vessel, which is beyond the facility's property boundary and do affect public receptors. The truck hose rupture area of concern is confined with the facility's property boundary. The isobutane system is designed, installed and maintained in accordance with NFPA-58, state law and the Company's insurance carrier. 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 Hickory fire department hazmat team will be requested. In the event of an accidental release of a flammable subs tance, the facility's Plant Emergency Organization policy requires immediate notification of the proper authorities and evacuation of the affected area. Facility personnel will only take defensive measures prior to evacuation. This facility's emergency response and contingency plan has been coordinated with the LEPC, local fire departments and the Hickory 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. No 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. |