Clark Foam - Executive Summary |
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This Risk Management Plan (RMP) was developed to meet the requirements of the California Accidental Release Prevention Program (CalARP), located in the California Code of Regulations (CCR), Title 19, Division 2, Chapter 4.5 and Part 68 of Title 40 of the Code of Federal Regulations (40 CFR 68). CLARK FOAM uses Toluene Diisocyanate (TDI) in amounts above the threshold quantity as specified in Tables 1 and 3 of Section 2770.5 of the CCR in a process that will be referred to as the "TDI Process". The purpose of this RMP is to conduct a comprehensive evaluation of the TDI Process. The objective of the RMP is to protect public health, safety and the environment from any release which may occur by minimizing the potential damage of any release. The methodology includes assessing the potential consequences posed by hazards and examining the means of detecting and correcting potential release that may result from predicted hazards. CLARK FOAM's RMP was originally developed when the Risk M anagement and Prevention Program (RMPP) was required by the State of California. CalARP regulations replaced the RMPP regulations in 1998. This RMP document is actually a modified RMPP document. CLARK FOAM's RMPP program was accepted by the Orange County Fire Authority (OCFA) on February 28, 1996. Ms. Kim Thress is the Plant Manager with overall responsibility for implementing and maintaining CLARK FOAM's RMP. The TDI Process involves the delivery of TDI by tanker truck, in quantities of approximately 23,000 pounds, on a "just-in-time" (JIT) basis and converted within 24 hours to less toxic material by partially reacting the TDI with a hydroxyl bearing polyester type resin. During processing, the TDI is piped into Tank #61 and converted to a prepolymer resin ("prepol") with the addition of a polyester resin. The prepol is transferred to Tank #62 for storage, and then pumped to the weighing and mixing station to be poured into molds. The air dispersion of a "worst-case scenar io", a release of the entire contents of Tank #61 (23,000 pounds), was modeled using SLAB software. The worst-case scenario, which would occur within a building structure, had dispersed before reaching the toxic endpoint of 0.007 mg/l (1 ppm). The release rate of TDI vapor into the air was calculated using the program, "Automated Resources for Chemical Hazard Incident Evaluation", or ARCHIE. The windspeed used to calculate the release rate is 1 mph (0.45 m/s). The release rate, as calculated by ARCHIE, is 2.95 x 10-4 kg/s, or 0.039 lbs/min. RMP*Submit would not allow a value of 0.039 lbs/min to be entered, therefore, a value of 1.0 lbs/min is shown. Based on the Offsite Consequence Analysis (OCA), the worst-case release scenario would not impact any receptors. Within the previous five years, there have been no accidents involving TDI that have resulted in incidents as defined by 19 CCR 2740.9. However, should an incident occur, CLARK FOAM has an Incident Investigation Procedu re to determine the cause of the incident and implement corrective action. CLARK FOAM has an emergency response program that requires employees to have all standard CLARK FOAM training, fully understand "TDI and Prepolymer Spill Instructions", understand MSDSs for TDI, be thoroughly qualified to use a standard CLARK FOAM live air respirator, and have a signed copy of "TDI and Prepolymer Spill Instructions" in the permanent employee file. In addition, CLARK FOAM has an "Emergency Action Plan" which outlines steps to take in an emergency, for example, TDI release due to fires, earthquakes, landslides, and large chemical spills. |