Foamexl Tupelo East - Executive Summary |
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EXECUTIVE SUMMARY Accidental release prevention and emergency response policies At the Foamex International, Inc. Tupelo East in Tupelo, Mississippi, we handle toluene diisocyanate (TDI) which is considered hazardous and regulated by the EPA. The same properties that make TDI valuable for use at our facility also make it necessary to observe certain safety precautions in the handling of the substance. TDI is considered a toxic substance and associated safety precautions have been implemented to prevent unnecessary human exposure, to reduce the threat to our own personal health as well as our co-workers, and to reduce the threat to nearby members of our community. 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. Nevertheless, an emergency such as a fire, explosion, or tox ic release of TDI is possible. We have coordinated emergency response with local officials to help ensure that accidents will be mitigated properly without undue risk to the public, environment, employees, contractors, or other personnel within the plant. Description of the facility and the regulated substances handled The primary purpose of this facility is to produce polyurethane foam, which is sold to other facilities and used to produce furniture and a number of other products. TDI is one of the reactants required to produce our polyurethane foam. TDI is received by tank truck, and is stored in an indoor storage tank. The maximum quantity of TDI stored at our plant is about 113,250 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 customers. TDI is the only substance handled at our plant that is regulated by EPA's ri sk management program (RMP) rule. This substance is covered because the maximum quantities stored onsite exceed EPA's threshold quantity (TQ) of 10,000 pound for each substance. Offsite consequence analysis of release scenarios We performed an offsite consequence analysis (OCA) 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). We do not expect a worst case release scenario to ever occur. The main objective of performing the OCA is to determine the distance at which certain effects might occur to the public because of an accidental release (called the endpoint distance). The following effects could occur at the endpoint distance: ' Most people at the endpoint distance of a toxic substance release like TDI 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) a re likely. Some people who are particularly susceptible to the released substance could be incapacitated. Worst case release scenarios. Catastrophic failure of the TDI storage tank, having a capacity of 113,250 lbs. TDI, would be a worst case release for a toxic substance because the TDI storage tank is the largest TDI container on the plant. Because a release at a higher temperature will result in the greatest endpoint distance, we assumed the release would occur at 115 0F. We also assumed that the entire contents of the tank would be released as a liquid, form a pool that would spread to cover an area of approximately 3,430 ft2, and evaporate to form a toxic cloud that would disperse downwind. The release rate was .006 lbs/min which is less than the 1significant digit reported on section 2.6. Refined dispersion modeling predicts a distance of 99 ft. from the diked area to the TDI toxic endpoint concentration of 0.98 PPM (0.007 mg/L). Alternate Release Scenarios. No alter native scenario was performed for this facility because there are no public receptors within the end-point distance. Five-year accident history We have had no releases of TDI the last 5 years that resulted in deaths, injuries, or significant property damage on site, or known deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage off site. Emergency Response Program The overall emergency response 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 Planned changes to impr ove safety We strive to improve the safety of our plant TDI process through periodic safety reviews and a program of soliciting safety suggestions from employees. We strive to identify needed process safety improvements, some of which result in changes to the processes. The following changes are currently planned for implementation: ' ' Provide a source of water near the foam slab cutoff area so that localized hot spots could be cooled to prevent a slab fire ' Upgrade inspections and tests of selected equipment and instrumentation designed to prevent TDI releases |