E.A.R. Specialty Composites Corporation - Executive Summary

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Accidental release prevention and emergency response policies:  At E-A-R Specialty Composites, Aearo Company, in Newark, DE, 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. In the event of an emergency involving toluene diisocyanate mixed isomers (TDI), our policy is not to respond with our personnel, but to contact outside agencies and request that they respond to the situation. 
Facility description and regulated substances: The facility manufactures flexible polyurethane foam, using toluene diisocyanate mixed isomers (TDI) as one of the raw materials. The TDI is received in tank trucks which we pump into our storage tank. The vapor space of the tank is connected to 
the truck to make a closed loop system for the vapors displaced from the tank. The TDI is circulated through an external loop, which can pass through a heat exchanger to keep it warm in the winter time. If a foam recipe calls for the addition of TDI, the line operator enters that information into the controller. An automatic valve on the circulating loop opens and the TDI is pumped to the mixing head station on the foam line. It reacts with other components and is deposited on a carrier as polyurethane foam. 
Release scenarios: The worst-case scenario for toluene diisocyanate mixed isomers, as defined in the Risk Management Program regulations, is the tank instantaneously losing its maximum quantity of  5,600 gallons (approx.  57,000 pounds) to form a liquid pool which then evaporates. The tank farm's diked area is 1,193 sq. ft. with a 34 inch (2.83 ft.) wall, which would hold approximately 25,000 gallons (3,375 cu. ft.). The dike would therefore hold the contents of the tank and is c 
onsidered passive mitigation, along with the building containing the tank. Using both the EPA's Offsite Consequence Analysis (OCA) guidelines and RMP*Comp, the distance to the toxic endpoint, which is 0.007 mg/L (0.98 ppm) for toluene diisocyanate, is calculated to be 0.06 miles (317 feet).  
The alternative release scenario is a failure of the hose as a truck of TDI is being unloaded. The driver, who is required by DOT regulations to be within 25 feet of the truck during unloading, is able to shut the manual valves on the truck after five minutes. The total material loss is 300 pounds (approximately 30 gallons). There is no containment around the truck unloading area. Using both the EPA's Offsite Consequence Analysis (OCA) guidelines and RMP*Comp, the distance to the toxic endpoint, which is 0.007 mg/L (0.98 ppm) for toluene diisocyanate, is calculated to be 0.06 miles (317 feet). 
General accidental release prevention program and chemical-specific steps: We take a systematic, proacti 
ve approach to preventing accidental releases of hazardous chemicals.  Our management systems address each of the key features of successful prevention programs including: 
o Safety information 
o Hazard review 
o Operating procedures 
o Training 
o Maintenance 
o Compliance audits 
o Incident investigation 
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. 
Five-year accident history:  Within the past five years, the process has had no accidental releases of TDI that resulted in deaths, injuries, or significant property damage on site; or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. 
Emergency response program:  In the even 
t of an emergency involving TDI, it is our policy to notify the Aetna Fire Department and/or Global Environmental and request that they respond to the situation.  
Planned changes to improve safety:  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: 
The facility is considering the installation of spill containment for the truck unloading area.
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