Carpenter Co.-Lathrop Division - Executive Summary

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1.  Accidental release prevention and emergency response policies 
It is the policy of Lathrop Division 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, Lathrop Division is committed to protecting the health and welfare of both its employees and community residents. 
    Lathrop Division makes all efforts not to have and accidental release by having: 
     a.  Training and testing program 
     b.  Safety check sheet 
     c.  Equipment inspections 
Our emergency response is based upon the requirements in OSHA's Hazardous Waste and Emergency Operations (HAZWOPER) regulation (29 CFR 1910.120) and the Busniess Plan per state and local regulations.  For emergency response,  the company has in place: 
     a.  Contingency plan 
     b.  Evacuation plan 
     c.  Chemical spill procedures 
     d.  First aid and C 
PR training 
2.  Stationary source and regulated substance handled 
The Lathrop Division operation in Lathrop, California is located at 17100 S Harlan Rd and occupies 486,000 square feet.  Carpenter Co. is located east of I-5 and is surrounded by an industrial neighborhood.  The facility is located on 35 acres. 
Carpenter Co. Lathrop Division manufactures polyurethane foam products primarily for use in furniture, cushioning, bedding, undercarpet padding, and packaging.  The manufacturing process incorporates the use of TDI, which is reacted with polyol and water to produce flexible foam products.  Inside the building, up to 250,000 pounds of TDI are stored in two steel storage tanks.  The two tanks are located in a cement pit that functions as a spill containment area.  TDI is shipped primarily via railcar, which contains approximately 190,000 pounds. 
3.  Worst case scenario and alternative release  scenario 
Losing the entire contents of a railcar (190,000 lbs) would be the worse cas 
e release.  If this happens the contents would enter our storm drains through two nearby storm grates and would consequently be collected in our sump.  The sump and the storm drains are large enough to hold the contents of two railcars.  The sump pumps are turned on only during the rainy season or as needed.  The storm water system is not connected to the local city storm water system.  The surface area coverd by the spill would be aprroximately 7520 square feet. 
The results for the SCREEN3 run indicate that the hightest concentration of TDI is found a distance of 19 meters (62 feet) from the spill site, with a maximum one hour concentration of 40.76 ug/m3.  The toxic endpoint for TDI as listed in the California regulations is 7000 ug/m3.  Based upon these results, the toxic endpoint will not be exceeded either offsite or onsite. 
4.  General accidental relase prevention program and chemical-specific prevention steps 
The Lathrop Division is in compliance with CALARP.  To prevent an a 
ccidental release, the following are implemented: 
   a.  Procedural 
        1.  Back-up chemical unloading 
        2.  Check-off lists 
        3.  Visual check while unloading 
   b.  Training 
        1.  Hands on training and test 
        2.  VHS video training 
        3.  Unload training documentation 
5.  Five-year accident history 
During the last five years one on-site accidental injury was recorded; there were no off site injuries during this time frame.  The injury occurred while changing a process pump.  The contributing factors to the injury were: 
    a.  Management error 
    b.  Maintenance error 
6.  Emergency response program 
    The Lathrop Divison has coordination agreeements with: 
    a.  Manteca/Lathrop Rural Fire Department 
    b.  City of Lathrop Police Department 
    c.  St. Dominic's Hospital 
    d.  Manteca Physicians Associates 
    e.  Manteca District Ambulance 
    f.  OHM Corporation - major environmental incident assistance 
Lathrop Division Eme 
rgency Response Team members are First Responder Operational certified.  Safety meetings are held monthly.  Evacuation drills are conducted semi-annually.  Public notification is handled by the local Fire Department. 
7.  Planned changes to improve safety 
In order to decrease the risk of future releases a process hazard analysis was completed and the following items were recently implemented: 
   a.  High level tank alarms 
   b.  Preventive maintenance routine inspections 
   c.  Implement written procedures for unload training 
   d.  Specify overhead hazards on fork lift training
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