Carlisle Coatings & Waterproofing, Inc. - Executive Summary |
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Per Section 112(r) of the Clean Air Act, the U.S. Environmental Protection Agency (EPA) issued the final Accidental Release Prevention and Risk Management Program rule on June 20, 1996. This rule was published in the Federal Register on June 20, 1996 and codified in the Code of Federal Regulations (40CFR68). It requires owners and operators of a covered stationary source to submit a Risk Management Plan (RMP) by June 21, 1999. To comply with the federal and state regulations, McLaren Hart, Inc. (McLaren Hart), under contract to Carlisle Coatings & Waterproofing, Inc. (Carlisle), prepared this RMP document for its facility located at 10880 Poplar Avenue in Fontana, California. McLaren Hart senior staff visited the Carlisle facility and gathered data by inspecting applicable storage and stationary processes, interviewing appropriate facility personnel, and reviewing documents (e.g., manuals, plans and maps) during the preparation of this document. Based on the data collected and federal and state regulations applicability analysis conducted by McLaren Hart, it was determined that the toluene diisocyanate (TDI) and isophorone diisocyanate (IPDI) systems used in the coatings and waterproofing production are the covered process chemicals; because the quantity of TDI and IPDI stored at the facility exceeds either the regulatory threshold quantity of 10,000 pounds (under federal regulation) and 500 pounds (under California regulation) for TDI and the regulatory threshold quantity of 100 pounds (under California regulation) for IPDI. The facility is subject to Program 1 requirements because the offsite consequence analysis that was performed by McLaren Hart indicated that no offsite impact from the TDI and IPDI processes. Additionally, there has been no accident with offsite consequences within the past five years. The hypothetical worst-case accident for the TDI and IPDI systems are a liquid spill during a shipping receipt and vaporization from the pooled liquid that could result in impacts. Results of the hazard assessment conducted using the Risk Management Plan Program Guidance for Offsite Consequence Analysis (EPA 550-B-99-009) and the NOAA and EPA-approved Areal Locations of Hazardous Atmospheres (ALOHA) Model conservatively calculates that the furthest distance to the "toxic endpoint" of a worst-case spill for TDI remains within the plant boundaries. There are no public or environmental receptors within the vulnerable zone and thus a Program 1 Risk Management Program is required. |