Foamex, L.P. - Executive Summary |
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EXECUTIVE SUMMARY Accidental release prevention and emergency response policies Foamex, L.P. in Santa Teresa, New Mexico, is a producer of flexible polyurethane foam. The process for producing polyurethane foam requires the use Toluene Diisocyanate (TDI). TDI is listed in the Clean Air Act 112 (r) list of regulated substances. Consequently, Foamex is subject to EPA's Risk Management Program Rule (RMPR). The same properties that give TDI commercial value are the characteristics that make it a hazardous material. Prior to RMPR, Foamex recognized the chemical and physical hazards involved with TDI and has observed safety precautions in its handling. These precautions have been implemented to help limit exposure to the public, environment and our employees. It is our policy to adhere to all applicable federal and state rules and regulations. We are committed to the safety of our employees and the public, and to the preservation of the environment, through the prevention of accidental releases of hazardous substances. Effective implementation and monitoring of our accidental release prevention program helps us facilitate our Management System in the interest of reducing the possibility of accidental releases and proper mitigation in the event of an accidental release. Description of the facility and the regulated substances handled The primary purpose of this facility is to produce flexible polyurethane foam, which is sold to other facilities, the automotive industry and the furniture bedding industry. TDI is one of the reactants required to produce polyurethane foam. TDI is received primarily by rail car and is stored in indoor storage tanks. The maximum quantity of TDI stored in rail cars and in storage tanks at our plant is about 800,000 pounds. The TDI is piped to a mix head where it is mixed with other reactants to produce a slab of polyurethane foam. The foam is conveyed to cutting stations where it is cut to the size and shape specified by our custom ers. TDI is the only substance handled at our plant that is regulated by EPA's RMPR. TDI is a regulated substance because it is listed on CAA 112 (r) and our process involves a quantity that exceeds the threshold quantity (TQ) of 10,000 pounds. Offsite consequence analysis of release scenarios An offsite consequence analysis (OCA) was performed to estimate the potential for an accidental release to affect the public or the environment. The OCA consists of evaluating worst case release scenarios (WRSs) and alternative release scenarios (ARSs). We do not expect a worst case release scenario to ever occur. An ARS represents a release that might occur during the lifetime of a facility like ours. ARSs help us to work with the local emergency planning committee (LEPC) to improve the community emergency response plan. The main objective of performing the OCA is to determine the toxic endpoint distance (the distance from the release point to the point at which the concentration of TDI in air is equal to the toxic endpoint specified in the RMPR) at which certain effects might occur to the public because of an accidental release. The following effects could occur at the endpoint distance: Most people at the endpoint distance of a TDI release would be able to walk away from the exposure without any long-term health consequences, although some short-term consequences (e.g., strong eye or throat irritation) are likely. Some people who are particularly susceptible to the released substance could be incapacitated. Worst case release scenarios. Catastrophic failure of a TDI rail car, having a capacity of 200,000 lbs. TDI, would be a worst case release for a toxic substance because a TDI rail car is the largest outdoor TDI container at the plant. The TDI vendors limit the quantity of TDI loaded into a railcar to 192,000 lbs. maximum to allow space for thermal expansion during possible heating of the TDI. TDI has a melting point of 55-56 0F. At temperatures at or belo w its melting point, the TDI is pre-heated to facilitate unloading and prevent TDI solidification. During hot weather, the TDI temperature could reach the maximum ambient temperature of 100 0F. The highest daily maximum ambient temperature of 107 0F was assumed in determining the toxic endpoint distance. We also assumed that the entire contents of the railcar would be released as a liquid, form a pool that would spread to cover an area of approximately 80,000 ft2 with a depth of about 0.4 inches (1 cm), and evaporate to form a cloud that would disperse downwind. Refined dispersion modeling predicts a toxic endpoint distance of 1530 ft. from the rail car. The toxic endpoint concentration for TDI is 0.98 ppm (0.007 mg/L). Alternate Release Scenarios. Rupture of the transfer line from the railcar-unloading pump to the TDI storage tank would release TDI to the ground at the standard pump rate of 800 LB/min. We assumed that the release would continue for 15 minutes. The resulting po ol would spread to cover an area of approximately 4,620 ft2 with a depth of 0.4 inches with an evaporation rate of 0.059 lb/min. to form a cloud that would disperse downwind. Refined dispersion modeling predicts a distance of less than 57 ft. from the pool to the TDI toxic endpoint distance where TDI concentrations in air would be 0.98 ppm (0.007 mg/L). The general accidental release prevention program and specific prevention steps The plant has implemented programs and procedures that comply with EPA's Prevention Program (Program 2). Our facility is not eligible for Program 1 because our worst case release scenario for TDI indicates a potential to impact public receptors within our toxic endpoint distance; however, Foamex, Santa Teresa is not subject to OSHA's Process Safety Management Standard in that TDI is not listed on OSHA's list of Highly Hazardous Chemicals. Consequently, our covered process is not subject to Program 3, therefore we are subject to Program 2. Our accidental release program is designed to systematically accomplish the following functions: - Control the creation and retention of safety information regarding the regulated substances, processes and equipment - Conduct hazard reviews to identify, evaluate, and control process hazards associated with the regulated substances, processes, and procedures - Create, maintain, and evaluate operating procedures for activities within or near processes that use regulated substances The general accidental release prevention program and specific prevention steps (continued) - Provide training for personnel who operate covered processes so that they safely perform their jobs - Monitor and control maintenance activities that can affect the mechanical integrity of equipment used in covered processes - Confirm through compliance audits that RMP practices at the plant are consistent with our written programs and that the programs are adequate to address all of the requirements of the RMP rule - Ensure tha t process incidents, particularly those of catastrophic magnitude or potential, are thoroughly investigated using our incident investigation procedures and that relevant findings are communicated throughout the company to help prevent recurrence The TDI process at our plant has hazards that are carefully managed to ensure continued safe operation. The prevention program outlined above is applied to the TDI process. Collectively, these prevention program activities help prevent potential accidental releases that could be caused by equipment failures, human errors, and by management system failures. In addition to the accidental release prevention program, our plant has safety features on many units to help (1) contain or control a release, (2) quickly detect a release, and (3) reduce the consequences of or mitigate a release. The following types of safety features are used in various units of the TDI process: Release Containment/Control - TDI storage tanks located inside an encl osed building - Automated shutdown systems for critical process parameters (e.g., high pressure)}high level alarms have been addressed and proposed in the process hazard analysis. - Pressure/vacuum relief devices on vessels to prevent rupture or collapse - Magnetic drive TDI centrifugal pumps without seals - Valves to permit isolation of the process - TDI railcar inner tank is surrounded by an outer shell filled with insulation - TDI railcars are top unloaded through a nozzle in the top of the tank The general accidental release prevention program and specific prevention steps (continued) Release Mitigation - Fire suppression and extinguishing systems - Trained emergency response personnel - Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus, breathing air stations) Five-year accident history We have had no releases of TDI in the last 5 years that resulted in deaths, injuries, or significant property damage on site, or known deaths, injuries, evacuations, sheltering-in-place, property damages, or environmental damage off site. We have had 2 small releases of TDI over the past 5 years. These releases either occurred inside an operating building and/or were too small to result in injuries or significant damage. Emergency Response Program Our emergency response program is based on the requirements in OSHA's emergency action and fire prevention plan regulation, OSHA's hazardous waste and emergency operations regulation, and EPA's emergency response program requirements in its RMP rule. Our program consists of procedures for responding to a release of TDI. The procedures address all aspects of emergency response, including proper first aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post-incident cleanup and decontamination requirements. In addition, the plant has pr ocedures that address maintenance, inspection and testing of emergency response equipment. Employees receive training in these procedures as necessary to perform their specific emergency response duties. The emergency response program is updated when necessary, based on modifications made to plant processes or other facilities. Personnel affected by changes in the program are informed and trained on those changes. The overall emergency response program for the plant is coordinated with the LEPC. This coordination includes participation in periodic meeting of the committee, which includes local emergency response officials, local government officials, and other industry representatives. The plant has around-the-clock communications capability with the appropriate LEPC officials and emergency response organizations such as the fire department. This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident. The pla nt also conducts periodic emergency drills that involve the local Fire Department and emergency response organizations. Planned changes to improve safety We strive to continuously improve the safety of our plant TDI process through periodic safety reviews and a program of soliciting safety suggestions from employees. Our hazard review and incident investigation programs are especially designed to identify needed process safety improvements, some of which result in changes to the processes. The following changes are currently planned for implementation: * Upgrade inspections and tests of selected equipment and instrumentation designed to prevent TDI releases * Revise operating procedures to resolve findings from the latest TDI process hazard review Alternate Emergency Contact: Tom Poquette, Chemist, Phone (505) 874-5517, 24 hour phone (915) 485-3371. |