Carpenter Co., Richmond Division - Executive Summary |
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EXECUTIVE SUMMARY Accidental Release Prevention and Emergency Response Policies 40 CFR ' 68.155(a) It is the policy of Carpenter Co., Richmond Division (Carpenter) to comply fully with all federal, state, and local rules and regulations regarding the proper handling, use, storage, and emergency response preparedness to prevent accidental release of chemicals, toxic or otherwise. Furthermore, Carpenter Co. is committed to protecting the health and welfare of both its employees and community residents. Carpenter makes all efforts not to have an accidental release by having: a. Training and testing program b. Safety check sheet c. Equipment inspections Its emergency response is based upon the requirements in OSHA's Hazardous Waste and Emergency Operations (HAZWOPER) regulation (29 CFR ' 1910.120) as well as state and local regulations. For emergency response, it has in place the following: a. Contingency plan b. Evacuation plan c. Chemical spill procedures d. First aid and CPR training Specific details about accidental release prevention and emergency response policies are contained in the sections below entitled "General Accidental Release Prevention Program and Chemical-Specific Prevention Steps" and "Emergency Response Program," respectively. Stationary Source and Regulated Substances Handled 40 CFR ' 68.155(b) Carpenter, located at 2400 Jefferson Davis Highway in Richmond, Virginia, manufactures various types of polyurethane foam products as well as blended chemical products. The foam products are used in the manufacture of furniture, bedding, carpet padding, and similar uses. The blended chemical products are sold to outside companies that combine them to make their own specialty products. Carpenter has the potential to store up to 1,200,000 pounds of unspecified isomer toluene diisocyanate (TDI), CAS Number 25471-62-5, at the plant at one time. This exceeds the 10,000 pounds threshold value for RMP applicability for TDI. Carpenter maintai ns no other regulated substances above the threshold values for RMP applicability. Carpenter stores TDI in 10,000-gallon tanks, an 8,400-gallon tank, and an 800-gallon tank. TDI is transported to Carpenter in railcars containing up to 195,000 pounds of TDI and tank trucks containing up to 45,000 pounds of TDI. Worst-case Release Scenario 40 CFR ' 68.155(c) The worst-case release scenario involves the release of 95,000 pounds of TDI from a tank in the virgin foam pouring area. The TDI would spill on the floor within the plant. In this scenario, the TDI vapor endpoint distance would be about 260 feet from the center of the tank. The property boundary is about 350 feet from the center of the tank. The distance to the endpoint for the worst-case release scenario is less than the distance to the nearest public receptor. The worst-case release scenario was evaluated using methods described in the EPA's "Offsite Consequence Analysis Guidance" and the tables providing endpoint distanc e information for TDI at temperatures other than 770 F and boiling in the Polyurethane Division of the Society of the Plastics Industry, Inc.'s "Risk Management Program (RMP) Coverage Assessment Package Customized for TDI Users." The endpoint distances in these tables are based upon a Gaussian plume model applied to the evaporation rate of the TDI. In Carpenter's worst-case release scenario, the TDI was assumed to be at 1020 F or less, the tank is indoors, and an urban topography was used. General Accidental Release Prevention Program and Chemical-Specific Prevention Steps 40 CFR ' 68.155(d) Carpenter's Hazard Communication Program assures that chemicals are properly labeled and that employees understand the specific precautions they must use when working with the chemicals in their area. This helps maintain a safe work environment. In addition, Carpenter has a Storm Water Pollution Prevention Plan that requires it do a monthly inspection of the facility to assure that its practi ces are not causing a release of materials to the storm water system. It also has a chemical hygiene plan, which describes the procedures laboratory personnel must use when working with chemicals to assure a safe working environment. Laboratory personnel review the contents of the plan annually. Carpenter also has a TDI monitoring policy. All employees working regularly in areas where TDI is used or handled are monitored for TDI exposure at least once every sixty days. In addition, certain designated areas where a TDI spill could occur and result in employee exposure are monitored for TDI levels every operating day. Tanks containing pure TDI have high-level alarms that help prevent them from being overfilled. The north tank farm is diked to contain any release of TDI or other chemicals maintained in the tank farm. Both tank trucks and railcars of TDI are unloaded inside of the building in areas designed to contain any release of TDI while unloading. Portable drip pans or simil ar devices are used beneath hose connections to tank trucks and rail cars when chemicals are unloaded. All employees who generate or otherwise manage hazardous waste are trained to assure Carpenter's hazardous waste management meets the requirements of the state and federal government. Five-year Accident History 40 CFR ' 68.155 (e) Carpenter has had no accidents in the past five years that would disqualify it from Program 1 applicability. Emergency Response Program 40 CFR ' 68.155(f) Carpenter follows a document entitled, "Carpenter Company Hazardous Waste Management Contingency Plan" (the Contingency Plan) as its emergency response program. The Contingency Plan contains fire emergency procedures, explosion emergency procedures, and spill response procedures. It establishes the method of notification, control, and clean up of hazardous materials in the event of an unexpected release at the plant. Every year an updated copy of the Contingency Plan is submitted to the Virginia Department of Environmental Quality, the Richmond Police Planning Division, the Richmond Fire Prevention agency, Capital Medical Center in Richmond, Richmond's Fire Station #21, the Richmond Local Emergency Planning Committee (LEPC), and Richmond's Department of Emergency Services. Every year Carpenter's Tier II Emergency And Hazardous Chemical Inventory report is sent to the Virginia Emergency Response Council and to the Richmond LEPC, which is also the local fire department with jurisdiction over the facility. The Tier II report provides information about the amount and specific location of chemicals around the plant. Carpenter's Spill Response Team (the Spill Team) is drilled quarterly to assure they properly respond to a spill. They are also trained in the hazardous material training required by 1910.120 of the Occupational Safety and Health Standards. Whenever new types of equipment are purchased to respond to spills, the Spill Team is trained to use the new equipment. Pla nned Changes to Improve Safety 40 CFR ' 68.155(g) Carpenter is planning to install permanent drip pans beneath the railcar unloading area in the rail dock. When this improvement is in place, it will be faster and easier to clean up an accidental release of chemicals in that area. This will minimize the employees' exposure to a release. |