Carpenter Co., Elkhart Div. - Executive Summary

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At Carpenter Co., Elkhart Div.  we are committed to operating and maintaining all of our processes (especially those using hazardous substances) in a safe and responsible manner.  We use a combination of accidental release prevention programs and emergency response planning programs to help ensure the safety of our employees and the public as well as protection of the environment.  This summary provides a brief overview of the comprehensive risk management activities that we have designed and implemented, including: 
*  A description of our facility and use of substances regulated by EPA's RMP regulation 
*  A summary of results from our assessment of the potential off site consequences from accidental chemical releases 
*  An overview of our accidental release prevention programs 
*  A five-year accident history for accidental releases of chemicals regulated by EPA's RMP rule 
*  An overview of our emergency response pr 
*  An overview of planned improvements at the facility to help prevent accidental chemical releases from occurring and adversely affecting our employees, the public, and the environment 
 *  The detailed information (called data elements) about our risk management program 
Our facility produces polyurethane foam products using a variety of chemicals and processing operations. We manufacture flexible polyurethane foam in prime, rebonded and molded forms. In addition we blend polyurethane systems for use by other end product manufacturers.  In our process, we use the following chemical that EPA has identified as having the potential to cause significant off site consequences in the event of a substantial accidental release: 
Toluene diisocyanate (mixed isomers) CAS No. 26471-62-5 
We have storage capacity for approximately 60,000 gallons of TDI inside the plant in eight 
bulk tanks located in tank pits or diked tank farms.  Our ra 
il siding has capacity for up to twelve tank cars and box cars.  We normally have about 3-4 tank cars of TDI on hand at any given time. A maximum of seven cars of TDI have been on site at one time in the past. A tank car of TDI contains 20,000 gallons or approximately 190,000 lbs of material.  TDI  
is only unloaded from one position (Rail spot #2).  Our accidental release prevention programs and our contingency planning efforts help us effectively manage the hazards that are posed to our employees, the public, and the environment by our use of this chemical. 
The following are brief summaries of theworst case and alternative release scenarios,  including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario: 
Worst-case Release Scenario - Regulated Toxic Chemicals 
The worst case scenario for our facility would involve the rupture of a 20,000 gallon tank car on our rail si 
ding due to structural failure of the tank car resulting in a catastrophic spill of toluene diisocyanate onto the ground surrounding our rail siding. EPA models indicate that an end point of 0.25 miles for the toxic vapor cloud from such a spill could be anticipated.  Depending on wind conditions and direction, there could be residential and industrial areas involved in such an incident.  The likelihood of such an accident is extremely remote since the tank cars are built to industry safety standards and inspected by the TDI suppliers at regular intervals for structural integrity and operation of safety devices. In addition, Carpenter Co., Elkhart Div. follows strict unloading procedures designed to prevent release of toxic materials during unloading operations.  No spills have occurred at this site in our sixteen years of operation that had any off-site consequences or were reportable to any other agency regulating our use of this product. 
Alternative Release Scenario - Regulated Tox 
ic Chemicals 
An alternative release scenario might involve a leak from an unloading hose connecting the tank car to bulk storage systems inside the facility.  The leak could occur as a result of a defective quick disconnect gasket on the unloading hose or a defect in the unloading hose itself.  Since DOT ( Department of Transportation ) regulations require that all unloading activities be attended at all time, it is assume that an leak in the unloading equipment would be observed immediately and the flow of product halted immediately to prevent any further leakage. We calculate that less than 10 gallons of product could be spilled in such an incident and that the toxic end point for such a release would be 0.06 miles. Very few public receptors would be involved in such an event;  only directly contiguous neighbors would be involved.  Neutralization of such a spill would begin immediately with supplies kept on hand. 
We have not had any release of this type in our 16 years of operation  
at this facility. 
We are using this information to help us ensure that our emergency response plan and the community emergency response plan address all reasonable contingency cases. 
We take a systematic, proactive approach to preventing accidental releases of hazardous chemicals.  Our management systems address each of the key features of successful prevention programs including: 
*  Process safety information 
*  Process hazard analysis 
*  Operating procedures 
*  Training 
*  Pre-startup review 
*  Compliance audits 
*  Incident investigation 
*  Employee participation 
*  Hot work permit 
*  Contractors 
As part of our prevention efforts, we have implemented the following chemical-specific prevention steps: 
TDI unloading is conducted in accordance with accepted industry practices and in full compliance with internal operating and safety procedures. 
These individual elements of our prevention 
program work together to prevent accidental chemical releases.  Our company and our employees are committed to the standard that these management systems set for the way we do business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention.  
We keep records for all significant accidental chemical releases that occur at our facility.  There have been no accidents involving TDI with off-site consequences during the past five years; or during the past sixteen years of operations in Elkhart. 
If such an incident were to occur, we will conduct a  formal incident investigation to identify and correct the root causes of the event. 
We maintain an integrated contingency plan, which consolidates all of the various federal, state, and local regulatory requirements for emergency response planning.  Our program provides the essential planning and training for effective 
ly protecting workers, the public, and the environment during emergency situations.  Furthermore, we coordinate our plan with the community emergency responders.  Our response capability is limited to small spills 
and limited incidents.  Large spills are to be referred to local Hazmat responders for assistance.   
The following is a list of improvements that we are planning to implement at the facility to help prevent and/or better respond to accidental chemical releases: 
1) Expand training program on the safe handling of TDI during unloading operations to include: 
             a) updating our training materials. 
             b) expanding the scope of employee training to a larger group of people. 
2) Improve our equipment inspection program to include documented routine inspections of equipment used for handling TDI.
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