Ohinewai Foam Factory Hazardous Substances Qualitative Assessment Ohinewai Hazardous Substances Assessment
IZ052900-NEM-RT-002 | Issue Rev 5 26 March 2021
Ambury Properties Limited
Ohinewai Hazardous Substances Assessment Ambury Properties Limited
Ohinewai Foam Factory Hazardous Substances Assessment
Ohinewai Hazardous Substances Qualitative Assessment
Project No: IZ052900 Document Title: Ohinewai Foam Factory Hazardous Substances Assessment Document No.: IZ052900-NEM-RT-002 Revision: Issue Rev 5 Date: 26 March 2021 Client Name: Ambury Properties Limited Project Manager: Bruce Clarke Author: Bruce Clarke File Name: Ohinewai Factory Hazardous Substances Qualitative Risk Assessment Rev 045
Jacobs New Zealand Limited
Level 8, 1 Grey Street, PO Box 10-283 Wellington, 6143 New Zealand T +64 4 473 4265 F +64 4 473 3369 www.jacobs.com
© Copyright 2019 Jacobs New Zealand Limited. The concepts and information contained in this document are the property of Jacobs. Use or copying of this document in whole or in part without the written permission of Jacobs constitutes an infringement of copyright.
Limitation: This document has been prepared on behalf of, and for the exclusive use of Jacobs’ client, and is subject to, and issued in accordance with, the provisions of the contract between Jacobs and the client. Jacobs accepts no liability or responsibility whatsoever for, or in respect of, any use of, or reliance upon, this document by any third party.
Document history and status
Revision Date Description Author Checked Reviewed Approved
01 28/11/2019 Draft for client Review B Clarke N Cooper H Anderson H Anderson
02 4/12/2019 Issue B Clarke N Cooper N Cooper K Tearney
03 25/03/2020 Revised site layout B Clarke N Cooper N Cooper K Tearney
04 11/06/2020 Minor changes B Clarke N Cooper N Cooper K Tearney
05 25/03/2021 Changes due to rail siding B Clarke N Cooper K Tearney K Tearney
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Contents Executive Summary ...... v 1. Introduction ...... 9 1.1 Purpose of the report ...... 9 1.2 RMA requirements...... 9 1.2.1 Waikato District Plan ...... 9 1.3 Hazardous substances ...... 9 2. Environmental Setting ...... 11 2.1 Land Zoning and Adjacent Land Uses ...... 11 2.2 Proposed Land Zoning and Future Adjacent Land Uses ...... 11 2.3 Wind Directions ...... 12 3. Process Description ...... 14 3.1 Base, Joinery and Assembly Shop ...... 14 3.2 Foam underlay ...... 14 3.3 Spring manufacture ...... 15 3.4 Foam manufacture process ...... 15 3.5 Foam Conversion ...... 20 3.6 Quilting and sewing ...... 20 3.7 Bed manufacture...... 20 3.8 Expanded polystyrene beads ...... 20 3.9 Polyester fibre filled pillows ...... 20 3.10 Raw material delivery ...... 20 3.11 Dispatch ...... 22 3.12 Spill Protection ...... 22 3.13 Fire Protection ...... 22 3.14 Stormwater Drainage System ...... 23 4. Hazardous Substances ...... 24 4.1 Hazardous Substances during Construction ...... 24 4.2 Hazardous Substances during Operation ...... 24 4.3 Hazardous Substances Site Controls ...... 26 5. Qualitative Risk Assessment ...... 29 5.1 General Approach ...... 29 5.2 Detailed Approach ...... 30 5.3 Hazards ...... 31 5.3.1 Incompatibility Hazard ...... 31 5.3.2 Toxic/Corrosive (Human Health) Hazard ...... 32 5.3.2.1 MDI ...... 32
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5.3.2.2 TDI...... 33 5.3.3 Ecotoxicity Hazard ...... 35 5.3.4 Process Control Failure Hazards ...... 35 5.3.5 Fire and Explosion Hazards ...... 35 5.3.6 Vandalism Hazard...... 36 5.3.7 Natural Hazards ...... 36 5.4 Fault Failure Events and Consequence Analysis of Potential Offsite Exposure ...... 37 5.4.1 Incompatibility Events ...... 37 5.4.2 Toxic/Corrosive (Human Health) Events ...... 38 5.4.3 Ecotoxicity Events ...... 42 5.4.4 Process Control Failures/Faults ...... 44 5.4.5 Fire Events ...... 45 5.4.6 Vandalism and Deliberate Damage ...... 47 5.4.7 Natural Hazards Risk ...... 47 5.5 Credible Major Accident Events ...... 48 5.6 Level of Risk ...... 48 5.7 Conclusion of Qualitative Risk Assessment ...... 52 6. Mitigation and Monitoring ...... 53 6.1 Emergency Plan and Procedures ...... 53 6.2 Process Safeguards Provided ...... 53 6.3 Fire Protection Systems...... 54 6.4 Containment of Fire Water and Runoff ...... 54 7. Conclusions and Recommendations ...... 55 7.1 Conclusions ...... 55 7.2 Recommendations ...... 56
Appendix A. Hazardous Substances Store Schematic and Site Layout Appendix B. Sprinkler/Fire Run-off Catchment Plan Appendix C. Emergency Plan and SOPs for Managing Spillages Appendix D. SOP for Dealing with a Hot Block Appendix E. SOP for ISO Bulk Tanker Transfer Appendix F. Qualitative Risk Analysis Descriptors F.1 Consequence Descriptors F.2 Likelihood Descriptors F.3 Risk Ranking Matrix
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Executive Summary
The purpose of this report is to provide a qualitative risk assessment of the hazards/credible accident scenarios which could result in offsite impacts on neighbouring properties from the operations of the proposed Ambury Properties Ltd foam manufacturing plant being located at 88 Lumsden Road, Ohinewai. Ambury Properties Ltd will own the site and the buildings and the plant will be operated by The Comfort Group (TCG). With respect to hazardous substances storage, the proposed facility requires consent under the Waikato District Plan for the following reasons:
• The quantity of TDI/MDI to be stored at the proposed facility requires consent as a “discretionary activity”; and
• The quantity of carbon dioxide to be stored at the proposed facility requires consent as a “discretionary activity”.
The Qualitative Risk Assessment (QRA) has been prepared to support an application for resource consent under the Resource Management Act for the proposed light industrial development. The QRA has been prepared following the guidance contained in AS/NZS ISO 31000:2009 Risk management: Principles and guidelines and the NSW Department of Planning Assessment Guideline Multi-level Risk Assessment, January 2011 which provide for an integrated assessment process for safety assurance of development proposals which are potentially hazardous.
The proposed site was previously used for dairy farming purposes. The land use around 88 Lumsden Road, consists of agricultural farming and grazing land to the south-east, south and south-west of the site. Sensitive activities to hazardous facilities are typically identified as schools, hospitals or residential areas (particularly high- density residential areas). The closest existing residential properties are to the south-west of the site on Lumsden Road.
During the construction of the project a range of hazardous substances will be used on site including:
◼ Diesel and oil for vehicles and construction of the plant, stored in portable containers;
◼ Paints and solvents, stored in tins or small drums; and
◼ Compressed gases such as oxygen and acetylene cylinders.
There will be no deliberate discharges of these substances to the natural environment as part of the construction activities. Accidental discharges will be minimised to the extent possible as part of the housekeeping procedures of the contractors. All empty containers and other refuse will be either returned to the supplier or placed in a skip, which will be emptied regularly at an approved municipal landfill.
A list as per the expected types, volumes and classifications of hazardous substances to be used at the site once the facility is operational is presented in Table 2. A range of hazardous substances will be used in the manufacture of foam with the main hazardous substance used at the site being isocyanates (MDI/TDI) which are used in the production of foam and underlay. Most of the hazardous substances will be stored in a designated Hazardous Substances Store which has been specifically designed for the storage, transfer and handling of the hazardous substances that will be used in the manufacture of foam. Within the Hazardous Substances Store there will be a separate sealed room used for the bulk and drum storage of TDI and MDI.
TCG’s design for the proposed facility incorporates a number of features to prevent the release of hazardous substances to the environment. They include:
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◼ A dedicated Hazardous Substances Store where the majority of hazardous substances (including TDI/MDI) are stored, which is bunded and separated from the rest of the factory;
◼ Bulk TDI/MDI stored in tanks within the Hazardous Substances Store, located in a separate room which is sealed, and the vapour discharges are ventilated via the carbon filter in the event of a spill or tank failure;
◼ Five independent fire sprinklers zones which cover the whole facility, apart from the TDI/MDI Store; and
3 ◼ A fire water storage pond (2,300 m ) at the eastern end of the site to contain firewater and to prevent accidental discharge into the adjacent drain.
In addition to the above engineering controls TCG have developed a series of Standard Operating Procedures for the handling of hazardous substances, tanker transfers and emergency shutdowns of the foam blowing plant, and for dealing with spillages.
A QRA has been conducted for the proposed bed and foam manufacturing plant at Ohinewai using the following steps: 1) Hazard Identification 2) Fault/Failure mode analysis 3) Likelihood analysis of the fault/failure mode/release 4) Off-site consequence analysis of the accident event 5) Qualitative determination of risk.
A hazard identification process was conducted for the site facilities and operations. For each hazard a number of fault/failure modes were identified. Where an incident was identified that could have a potential offsite effect, it was included in the QRA. The QRA lists the hazard, incident type, causes, likelihood and consequences and safeguards (mitigation measures). Each postulated hazardous incident where a potential offsite effect was identified, was assessed as to its potential level of effect using quantitative empirical modelling (consequence analysis). From the outputs of the modelling, an assessment, in light of proposed safeguards (technical and management controls), was undertaken using the likelihood and consequence descriptors and the risk matrix, to determine the level of risk.
The QRA conducted combines both a qualitative analysis (Level 1) and partial quantification (Level 2) where all hazards in terms of their consequences (effects) to people beyond the site boundary are assessed. Partial quantification was applied to development for the hazards identified in order to determine whether they are Credible Major Accident Events (MAEs) with potential consequences beyond the site boundaries but with a low frequency of occurrence.
A total of five credible MAEs that could result in offsite effects should they occur at the site were identified by the QRA process. For the majority of incident/accident events analysed, the consequences of the event are able to be contained on site and as such the process was stopped at that point for these hazards. The credible MAEs identified that could result in offsite effects are:
◼ Overfilling of TDI/MDI bulk tanks;
◼ Failure of the extract fan during foam blowing resulting in vapour releases;
◼ Hot block (excessive heat generated as a result of the foam blowing reaction);
◼ Extensive fire at plant; and
◼ Fire water including contaminants being released offsite.
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These MAEs were run through the risk analysis matrix where the qualitative descriptors were used to determine the likelihood of an event occurring and consequence of that event in terms of offsite effects. All MAEs which could result in offsite effects have been evaluated as having a low level of risk to human health and environment provided the mitigation measures detailed in this report are followed. In conclusion, the level of risk posed to the environment and human health resulting from the storage and use of hazardous substances at the facility on average is low. The mitigation, standard operating procedures, emergency response procedures and safety design measures that will be in place will limit the risk resulting from the storage and use of hazardous substances to as low as is reasonably practical.
The following recommendations based on the QRA are made for implementation by TCG.
1) The Standard Operating Procedures for managing chemical spills including TDI are implemented at the site and are regularly tested to ensure staff are aware of the contents of the procedure and to check that they are still current. If the SOP tested is found to be deficient it should be amended.
2) The Standard Operating Procedure for managing a hot block incident should be implemented at the site and the SOP tested once every six months so that staff are familiar with the requirements of the SOP and how to manage a hot block situation, given that a hot block event occurs on an infrequent basis.
3) That removal efficiency of the carbon filter is tested on regular basis in order to ensure that the filter is operating as per its specifications.
IZ052900-NEM-RT-002 vii Important note about your report
Qualitative Risk Assessment to support a resource consent application by Ambury Properties Ltd (the Client) and as such can be used for this purpose. The report has been prepared in accordance with the scope of services set out in the contract between Jacobs and the Client. That scope of services, as described in this report, was developed with the Client.
In preparing this report, Jacobs has relied upon, and presumed accurate, any information (or confirmation of the absence thereof) provided by the Client and/or from other sources. Except as otherwise stated in the report, Jacobs has not attempted to verify the accuracy or completeness of any such information. If the information is subsequently determined to be false, inaccurate or incomplete then it is possible that our observations and conclusions as expressed in this report may change.
Jacobs derived the data in this report from information sourced from the Client and/or available in the public domain at the time or times outlined in this report. The passage of time, manifestation of latent conditions or impacts of future events may require further examination of the project and subsequent data analysis, and re-evaluation of the data, findings, observations and conclusions expressed in this report. Jacobs has prepared this report in accordance with the usual care and thoroughness of the consulting profession, for the sole purpose described above and by reference to applicable standards, guidelines, procedures and practices at the date of issue of this report. For the reasons outlined above, however, no other warranty or guarantee, whether expressed or implied, is made as to the data, observations and findings expressed in this report, to the extent permitted by law.
This report should be read in full and no excerpts are to be taken as representative of the findings. No responsibility is accepted by Jacobs for use of any part of this report in any other context.
This report has been prepared on behalf of, and for the exclusive use of, Jacobs’s Client, and is subject to, and issued in accordance with, the provisions of the contract between Jacobs and the Client. Jacobs accepts no liability or responsibility whatsoever for, or in respect of, any use of, or reliance upon, this report by any third party.
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Ohinewai Foam Factory Hazardous Substances Assessment
1. Introduction
1.1 Purpose of the report
The purpose of this report is to provide a Qualitative Risk Assessment (QRA) of the hazards/credible accident scenarios which could result in offsite impacts on neighbouring properties from the operations of the proposed Ambury Properties Limited (APL) foam manufacturing plant to be located at 88 Lumsden Road, Ohinewai. APL will own the site and the buildings, and the plant will be operated by The Comfort Group (TCG).
With respect to hazardous substances storage, the proposed facility requires consent under the Waikato District Plan (WDP) for the following reasons:
• The quantity of toluene diisocyanate (TDI)/ diphenyl diisocyanate (MDI) to be stored at the proposed facility requires consent as a “discretionary activity”; and
• The quantity of carbon dioxide (non- hazardous compressed gas) to be stored at the proposed facility require consent as a “discretionary activity”.
The QRA has been prepared to support an application for resource consent under the Resource Management Act 1991 (RMA) for the proposed factory. The QRA has been prepared following the guidance contained in AS/NZS ISO 31000:2009 Risk management: Principles and guidelines and the NSW Department of Planning Assessment Guideline Multi-level Risk Assessment, January 2011 which provide for an integrated assessment process for safety assurance of development proposals which are potentially hazardous.
This report has been prepared in partial fulfilment of the requirements of Section 88 and Schedule 4 of the Resource RMA.
1.2 RMA requirements
1.2.1 Waikato District Plan
The proposed storage and use of hazardous substances at the site is a discretionary activity under Rule 25.31.2 (a) of the Waikato District Plan (WDP), as they exceed the permitted hazardous substances quantities for the Rural Zone specified in Appendix H of the WDP as assessed in Section 1.3 below.
1.3 Hazardous substances The provisions for storage and use of hazardous substances are set out in Appendix H of the WDP.
Appendix H contains table HT1 which sets the permitted quantities of hazardous substances by class for the different zones identified in the WDP. Table 1 below compares the proposed volumes of hazardous substances at the site with the thresholds for the Rural zone. Where the anticipated storage exceeds the permitted quantity, consent as a discretionary activity is required.
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Ohinewai Foam Factory Hazardous Substances Assessment
Table 1 : Comparison against relevant permitted quantities in the WDP for the Rural Zone
Rural Zone Permitted HSNO Subclass Quantity Anticipated storage Consent status
2,000 kg Non-hazardous compressed gas 6000 kg Discretionary or 4,000 m3
LPG 1500 kg 500 kg Permitted
LPG (within 50m of m.s.z.) 500 kg 500 L Permitted
3.1D 20,000 kg 2,900 L Permitted
6.1A 200 kg 49,000 L Discretionary
6.1A (within 50m of m.s.z.) 100 kg 49,000 L Discretionary
6.1B, 6.3-6.9 2,000 kg 78,700 L Discretionary
6.1B, 6.3-6.9 (within 50m of m.s.z.) 1,000 kg 78,700 L Discretionary
6.1C 6,000 kg 1,200 L Permitted
6.1C (within 50m of m.s.z.) 2,000 kg 1,200 L Permitted
8.1, 8.2A, 8.3 2,000 kg 3,500 L Discretionary
8.2B, 8.2C 10,000 kg 1,500 L Permitted
9.1A, 9.2A, 9.3A, 9.4A 500 kg 300 L Permitted
9.1B, 9.2B, 9.3B, 9.4B 10,000 kg 2,300 L Permitted
9.1C, 9.2C, 9.3C, 9.4C 30,000 kg 26,400 L Permitted
High BOD5 40,000 kg - Permitted
(>10,000 mg/l)(within 30m of water body 20,000 kg - Permitted or coastal water)
The proposed quantities of non-hazardous compressed gas (carbon dioxide), toxic substances Class 6.1A, Class 6.1B, Class 6.3-6.9, Class 6.1C, and corrosive substances Class 8.2A and 8.3 in the Rural Zone trigger the requirement for discretionary activity consent.
If assessed as if the land were rezoned to Industrial1, the threshold for consent are still exceeded for all subclasses except for Class 8.3. The quantities of all other substances are below the permitted activity thresholds.
Overall, the proposed storage and use of hazardous substances requires resource consent as a discretionary activity.
1 We are aware of the proposed rezoning application to the Waikato District Council and the implications of that rezoning if successful is covered in Section 2.2 below.
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Ohinewai Foam Factory Hazardous Substances Assessment
2. Environmental Setting
2.1 Land Zoning and Adjacent Land Uses
The site subject to this resource consent application is located at 88 Lumsden Road, Ohinewai with a legal description of Allotment 405, Whangamarino Parish and is 36.96 ha in size. The site is part of a wider farming operation that also includes 231 Tahuna Road, however the subject site is a discrete part of the farm as outlined in Figure 1 below.
The site is located approximately one kilometre north-east of the State Highway 1 Ohinewai Interchange and can be accessed via Lumsden Road and Balemi Road. Lumsden Road is a no exit road, with a number of commercial and industrial premises located approximately 2 kilometres to the north.
Immediately to the west is the North Island Main Trunk Railway (NIMT) and State Highway 1. A small number of residential properties are located across from the site on Lumsden Road, directly adjacent to the NIMT. Three residential properties are also located to the south of the site, with the wider farm operation beyond that. Beyond the site boundaries and approximately one kilometre to the east sits reserve land and Lake Rotokawau. To the west of SH1 is the Ohinewai Village which includes residential, community and commercial land uses.
The Waikato River is located beyond Ohinewai Village approximately one kilometre to the west.
The site is a largely undeveloped lot apart from an an array of storage containers located to the north-west of the site. The site is currently in pasture earthworks have recently commenced on site as part of the preparatory works for the site development. The site location is provided in as Figure 1.
2.2 Proposed Land Zoning and Future Adjacent Land Uses
The site is currently zoned Rural, however a proposal to zone the site Industrial is currently being progressed as part of the Proposed Waikato District Plan process being put forward by APL. The rezoning process also seeks surrounding land (owned by APL) be rezoned to a mix of Industrial, Business and Residential land.
Therefore, if the rezoning process is successful, the proposed factory will sit within and land zoned Industrial and with Industrial zoned land located on its southern boundary. Land zoned residential will be located to the south-east, with the existing Village zone to the west of the factory remaining. Land to the north and east of the factory will remain Rural.
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Ohinewai Foam Factory Hazardous Substances Assessment
Figure 1 : Site location
2.3 Wind Directions
The nearest meteorological station to the site is the Huntly Meteorological Station. Wind data collected for the period 2002 is presented as Figure 2.
Winds from the westerly quarter direction are predominant (38% of all winds). The next most frequent wind direction is from a south-easterly direction (20% of all winds). Calm and light wind speed events are rare occurring around 8.3% of the time.
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Ohinewai Foam Factory Hazardous Substances Assessment
Figure 2 : Wind Rose for Huntly 2002
WIND ROSE PLOT WINDROSE - HUNTLY OBSERVED DATA 2002
NORTH
20%
16%
12%
8%
4%
WEST EAST
SOUTH
MODELER DATE COMPANY NAME Wind Speed (m/s) Mira Chakraborty 9/09/2003 Sinclair Knight Merz Ltd
> 11.06 DISPLAY UNIT COMMENTS
8.49 - 11.06 Wind Speed m/s
5.40 - 8.49 AVG. WIND SPEED CALM WINDS
3.34 - 5.40 2.43 m/s 8.33%
1.80 - 3.34 ORIENTATION PLOT YEAR-DATE-TIME Direction 2002 0.51 - 1.80 (blowing from) Jan 1 - Dec 31 Midnight - 11 PM
WRPLOT View 3.5 by Lakes Environmental Software - www.lakes-environmental.com
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Ohinewai Foam Factory Hazardous Substances Assessment
3. Process Description
The proposed main activities to be undertaken at the site once the plant is constructed are described in the following sections. The construction of the overall TCG factory, including bed manufacturing is being staged and therefore not all processes will be undertaken in the initial stages of the development. Stage 1 and 2 of the factory will include the foam manufacturing and underlay processes. Bed manufacturing will occur in later stages of the factory development and those operations will be subject to separate approvals and assessments.
A rail siding from the Main Trunk Railway will be installed by APL to the north of the foam manufacturing plant which will take goods to and from the site. The rail siding will be withing APL’s site boundary. There will be two train movements per day (one train in, one train out). All hazardous substances associated with the foam manufacturing will transported by road to the site.
3.1 Base, Joinery and Assembly Shop
The base, joinery and assembly shop manufactures wooden bedding components starting with lengths of timber arriving on site to the completed bed base unit. The only process chemicals used in this area is a water-based adhesive. Dust discharges from the joinery shop are collected via a pulse jet bag house filter dust collection unit designed to achieve an emission level <15 mg/m3 and with a collection efficiency of 99.9%. The unit will be fitted with pressure gauges to measure any change of pressure across the bag house unit which is an indication of a bag failure. The pressure gauges will be alarmed.
3.2 Foam underlay
The base raw material for this process includes foam off-cuts that are collected from various processes throughout the bed manufacturing operation with the majority being purchased offshore and delivered on site in bale form in 40’ containers. The foam off-cuts are fed into a bale breaker and then chipped and sorted. The chipped and sorted foam are metered and fed into a ribbon blender. A polyurethane premix containing TDI, manufactured on site, is metered into the hopper and the mixture rotated to ensure the ingredients are thoroughly blended. This blend is metered into a cylindrical mould, compressed and steam cured. The formed cylindrical foam block is then peeled, and a polyethylene film thermally laminated to the foam sheet. This laminated sheet is cut to length, rolled and packed as foam carpet underlay ready for dispatch.
Steam is produced by a 700 kW gas fired boiler. The manufacture of foam underlay uses approximately 14 kg/hr of TDI for 10 hours of operation per day. . At most, the maximum use of TDI will be16.5kg/hr.
The raw materials for the underlay plant are stored in the Hazardous Substances Store. The Binder (premix of polyol and TDI) will be mixed in the Hazardous Substances Store and transported daily by forklift in special containers, or as required, to fill the Binder process vessel which is a 1680 kg bulk tank. In addition to the Binder process vessel, processing oil will be stored in a 600 kg bulk tank in a bunded area at the Foam Underlay Plant. This tank will be refilled using drummed stock which is stored in the Hazardous Substances Store and is transported by forklift from the store to the Foam Underlay Plant.
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Ohinewai Foam Factory Hazardous Substances Assessment
The process flow diagram is presented in Figure 3.
Figure 3 : Underlay Process Schematic
3.3 Spring manufacture
Wire for the manufacture of bedsprings (mattresses and bases) is received in coil form. The wire is fed through five spring machines, which form the wire into the various shapes and lengths required. The forming process requires several stages of heating in both electric and gas fired ovens. No process chemicals are used in this area.
There are three types of spring assemblies manufactured on site: ▪ Sensorzone – this is a solid foam mattress core with holes drilled at specified positions, individual coil springs are manufactured and manually inserted in the holes drilled in the foam base. ▪ Pocket springs – A one operation machine manufactures the steel spring from wire, forms a pocket of non-woven fabric around the metal spring and then glues the rows of pocket springs together to form a spring assembly. This unit is then put into a foam box to form the building base for an inner sprung mattress. ▪ Torquezone – This is a process where each row of springs is manufactured from one single strand of wire and each of these rows is held together with a helical spring coil. The spring units are then passed through a tempering oven. These spring units are then placed into a foam box to form the building base for an inner sprung mattress.
No process chemicals are used or stored in these areas.
3.4 Foam manufacture process
The manufacture of polyurethane foam involves mixing together an isocyanate with a polyol, a catalyst and a blowing agent to expand the foam. Other chemicals are also added to provide colour, fire resistant properties and anti-microbial properties.
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Ohinewai Foam Factory Hazardous Substances Assessment
Flexible polyurethane foam is manufactured on a Hennecke Multiflex foam plant fitted with a Nova Flex liquid carbon dioxide dispensing system. The foam manufacturing plant will be housed in a separate specially designed building at the proposed Ohinewai site. This means that the building is isolated from the rest of the manufacturing facility and any TDI/MDI vapours released by the foam manufacturing plant will not be able to travel through the whole of the manufacturing facility, which is one of the hazards with the current Otahuhu manufacturing site.
The major ingredients for the manufacture of flexible polyurethane foam are: ▪ Polyol (polyether type polyol); ▪ Toluene diisocyanate (TDI) or methylene diphenyl diisocyanate (MDI); ▪ Water; ▪ Silicones; ▪ Amine catalysts; ▪ Tin catalysts; ▪ Processing aids; and ▪ Liquid Carbon Dioxide (Ancillary Blowing Agent). There are two major reactions: ▪ Polyol and TDI/MDI polymerize to form polyurethane; and ▪ TDI/MDI and Water react to produce carbon dioxide gas and begin the initial formation of the cell structure of the final product. The main use of hazardous substances at the site occurs at the polyurethane foam plant.
All ingredients are metered into a mixing head at a ratio determined by a calculated formulation. The ingredients are mixed together at high speed and then deposited, via a specially designed dispensing unit, onto a paper covered conveyor system. The metering and mixing process is computer controlled, so if ingredient flows vary outside of the calculated flow rate, alarms will activate and if no action is taken the foaming process will automatically shut down.
As the foaming liquid is conveyed down the tunnel the foaming liquid increases in volume and decreases in density and this volume increases in size to the point where the blow and polymerization reactions are complete, and the foam block begins to cure. By the time the continuous foam block exits the tunnel it has cured to a point where it can be cut into blocks and conveyed into the curing room. At this stage 85 to 90% of the gases have been exhausted from the curing foam. The stored foam blocks are allowed to cure for a further 24 hours as a minimum before being cut up into smaller blocks for further conversion operations.
The foam plant conveyor system, where the main foam forming reactions occur, is enclosed in a tunnel fitted with extraction ducts to remove any gas produced from the various reactions. The air extraction volume is 75,000 m3/hr. This extracted air is passed through an activated carbon filter where a minimum of 99.5% of the free isocyanate monomer (TDI/MDI) vapour is removed from the exhaust air before being released into the atmosphere.
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Ohinewai Foam Factory Hazardous Substances Assessment
The foam plant is illustrated in Figure 4 and the process in Figure 5.
Figure 4 : Schematic of Hennecke Multiflex Foam Machine
Figure 5 : Foam Plant Process flow
Polyol is delivered to the site in 20,000 litre containers and pumped into polyol holding tanks. These tanks are located inside the bunded Hazardous Substances Store.
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Ohinewai Foam Factory Hazardous Substances Assessment
TDI/MDI is delivered in 200 litre drums and/or in 20,000 litre ISO containers and is pumped under vacuum into storage tanks located inside the TDI/MDI Store, which is a separate sealed storage area in the Hazardous Substances Store.
Up to 90 tonnes in total of TDI (50,000 kg in bulk tanks and 40,000 kg in drums) and 46 tonnes in total of MDI (30,000 kg in bulk tanks and 16,000 in drums) will be stored on site. For stage 1 of the development TDI will be stored in one bulk tank (25,000 kg) and 40,000 kg in drums. The stationary container system will be certified by a WorkSafe approved test certifier. The TDI and MDI storage tanks within the TDI/MDI Store will be equipped with two high level alarms in series (a high alarm and a ‘high-high’ alarm). The air moving in or out of the tank is dried via a desiccant drier and expelled air passes through a filter to remove TDI/MDI vapour.
All other minor liquids (e.g. silicon, amine catalyst, tin catalyst) are delivered in various drum sizes and stored in bunded areas in the factory or the Hazardous Substances Store. See Appendix A for the layout of the bulk tanks in the Hazardous Substances Store. The drums are delivered to the process areas by forklift utilising a drum holder which reduces the potential for damage to the drum by the forklift during transportation.
All liquids are metered via high pressure pumps to the mixing head. Delivered volumes are computer controlled and any flow outside the metering volumes will bring up an alarm and if necessary, automatically shut down the manufacturing process. All the components required for the foam manufacture are metered into a high speed mixing chamber where the two main reactions begin. The reaction between the water and TDI/MDI generates heat which starts the process of polymerisation between the polyol and TDI/MDI to form polyurethane. At the mixing stage liquid carbon dioxide is added to cause the polymerizing liquid to foam. As the foam bun moves down the forming tunnel the foam begins to cure. At the end of the forming tunnel the foam is cured enough to cut and transport to a curing warehouse. Any vapours produced during the foam manufacturing process are passed through a filter that removes toxic vapour from the exhaust stream prior to releasing into the atmosphere.
The foam forming reactions are mildly exothermic and the newly formed blocks of foam are moved to the block store via the foam block conveyor system to cure and cool. The temperature and the rate of cooling of the blocks is constantly monitored during the cooling /curing period by inserting a wire thermocouple probe in the block after it has been cut by the flying saw. The temperature monitoring is able to detect any blocks where the temperatures may approach around 180-190°C which is when auto ignition of the block may occur resulting in the block catching fire. Such a block with elevated temperatures is referred to as a ‘hot block’. A computer automatically graphs the data sent from the probes at one-minute intervals and raises alarms if temperatures exceed 170°C.
The cooling rack system is able to accommodate 40 m long blocks (2x 20 m) and is 7 racks wide by 6 racks high. The foam blocks are delivered to and removed from the racks by an enclosed automated traveling conveyor (travellator). If the temperature probes or the operators detect a ‘hot block’, the travellator will remove the block and deliver it to an external ground level roller conveyor located on the south western corner of the building over which there is a piped cage arrangement which is fitted with water sprays. The block can then be cooled by operating these water sprays and pushing water lances into the block.
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Ohinewai Foam Factory Hazardous Substances Assessment
Once needed for production in the manufacturing process, the selected cured foam block is extracted from its rack and moved onto the travellator to be fed into the manufacturing area. 3.2.1 Activated Carbon Filter
The Camfil Farr activated carbon filter currently installed at the Otahuhu site and will be either re- located to the new site or a new activated carbon filter installed at the new site is guaranteed by the manufacturer (Camfil) to remove as a minimum 99.5% of TDI/MDI vapours from the exhaust stream prior to discharge. The activated Camfil Farr carbon filter has ~7.5 tonnes of activated carbon which is expected to last for approximately 15 years with a guarantee at the proposed maximum level of operation (i.e., 3 hours per day, up to 6 days per week). The activated carbon in the filter will be replaced prior to installation in the Lumsden Road site. A fan draws air from the foam blowing plant through the filter, which is then discharged to air via a chimney at a rate of 75,000 m3/hour.
A separate fan with extraction rate of 19,000 m3/hour will be installed that extracts air from the TDI/MDI bulk and drummed storage sealed room in the event of a spill to the filter to be treated before being discharged to air.
“The activated carbon filter system currently in place at the Otahuhu facility is constructed of two separate parts. On the inlet side there is a bank of ‘standard’ air type filters whose primary job is to catch any large airborne particles and debris that may come through the system. It is this section of the filter that includes two manometers (Manometer is an instrument that uses a column of liquid to measure pressure, although the term is used nowadays to mean any pressure measuring instrument). Marks on the gauges represent the level at which the filters are blocked. Every week the position of the indicators on the gauges are assessed and when they get close to the limit level, replacements are ordered, which take approximately one week to arrive. The system is then monitored daily to ensure sufficient air flow. It is anticipated that the new facility will include similar procedures and instruments. After the ‘in-feed’ filters, TDI/MDI fumes then pass into the activated carbon section of the system, where the approximately 10 tons of activated carbon reside. The ongoing functionality of the filter can be readily monitored by detecting any change in pressure across the filter. This is not expected to happen at the Ohinewai facility as the Carbon filter will be oversized for the facility’s purpose. The large size of the carbon bed generally ensures that a low pressure difference is maintained. As well as the above checks in place, continued in-stack monitoring and boundary monitoring of TDI will be undertaken2”.
For more details on this monitoring please refer to the Air Quality Assessment Proposed Bed Manufacturing Factory, Ohinewai, Waikato report prepared by Atmospheric Science Global Ltd;
“Significant advantages of The Comfort Group’s activated carbon system are that:
(i) the operating range of the filter has no limits within the life of the media;
(ii) (ii) it can handle large fluctuations in load without any loss of efficiency; and,
2 Air Quality Assessment Proposed Bed Manufacturing Factory, Ohinewai, Waikato prepared by Atmospheric Science Global Ltd, April 2020.
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Ohinewai Foam Factory Hazardous Substances Assessment
(iii) (iii) they are known to remove in excess of 99.9% of contaminants.”2
3.5 Foam Conversion
In this area the blocks of cured foam are sheeted or cut by specialised cutting equipment into designed shapes or flat sheets to be used in the manufacture of beds or sold to outside customers. Apart from silicone spray lubricants no other chemicals are used in this area.
3.6 Quilting and sewing
Quilting machines that produce the comfort layers and fabric covering components for bed manufacture will utilised on site. Raw materials used in this area or rolls of polyester fibre, rolls of peeled foam, polyester bulk fibre and rolls of ticking material. No chemicals are used in this area.
3.7 Bed manufacture
Bed manufacturing will be conducted using various components manufactured on site or purchased and brought to the site. Processing systems used in the bed manufacture are automatic gluing systems using water based and hot melt adhesive systems. The process starts with a spring unit, a foam box and travels down the manufacturing line where comfort layers are added, the various layers are sewn together, the completed mattress is then passed through an automated packing unit and then delivered to the dispatch store.
3.8 Expanded polystyrene beads
This process involves the expanding of polystyrene beds using live steam heated expansion equipment. The beads go through several passes and the expanded beads are stored in large bag hoppers. These expanded beads are used for fill in cushions and bean bags. No chemicals are used in this area.
3.9 Polyester fibre filled pillows
Fibre polyester is opened via a fibre opening system and blown into premade pillow cases. These filled pillows are packed in PE bags and compression packed for delivery to customers. No chemicals are used in this area.
3.10 Raw material delivery
A rail siding will be installed by APL to the north of the foam manufacturing plant, which will take goods to and from the site. The rail siding will be withing APL’s site boundary. The rail siding will be located around 50 m to the north of the factory within the property. There will be two train movements per day (one train in, one train out) which will bring raw materials, apart from hazardous substances to the site and to take finished products. The location of the rail siding is shown on the site layout drawing provided in Appendix A.
All hazardous substances associated with the factory will transported by road to the site. All deliveries are expected to the Hazardous Substance Store will be via the driveway from Lumsden
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Ohinewai Foam Factory Hazardous Substances Assessment
Road which connects with State Highway 1 via Tahuna Road. All hazardous substances will be transported to the site in accordance with the Land Transport Act 1998 and associated regulations. It is envisaged for Stage 1 there will be one delivery per week.
All process chemicals will be delivered to the hazardous substances receipt area at the rear of the site. Polyol is delivered to the site in 20,000 litre ISO containers and pumped into bulk polyol holding tanks located inside the Hazardous Substances Store. The majority of the TDI/MDI will be delivered in either 250 kg (200 litres) drums or 20,000 litre bulk ISO containers and will be pumped into certified above ground storage tanks. The TDI/MDI drums and bulk tanks will be located in a separate sealed room (TDI/MDI Store) in the Hazardous Substances Store (see Appendix A). There will be a maximum of two above ground tanks each of 25,000 kg capacity containing TDI and two above ground tanks of each 15,000 kg capacity containing MDI in a separate bunded area in the TDI/MDI Storage Room. For Stage 1 of the factory development only one bulk TDI and one bulk MDI tank will be utilised with the remaining stock held in drums
All TDI/MDI bulk storage tanks are equipped with two high level alarms and the air moving in or out of the tank is dried via a desiccant drier. Discharges from the room in the event of a spillage will be ventilated via the carbon filter in the event of a spill or tank failure. This extraction system will be activated by either a float switch located in a sump in the TDI/MDI bulk tank bund or another float switch located in a sump in the drum storage area of the TDI/MDI Store.
The majority of the TDI/MDI will be delivered to the site in drums. TDI/MDI will be pumped from drums stored in the TDI/MDI Store into the bulk tanks.
Alternatively, the liquid isocyanate will be pumped under vacuum from the tanker to the bulk tanks located in the sealed storage room. The pump used to move the TDI/MDI from the ISO tanker to the bulk tanks is a vacuum pump which is located inside a bund enclosure in the same room as the bulk tanks. The tanks will be filled from the top. A vapour return line from the tank to the tanker will be in place during the transfer. This line will collect the vapour displaced from the tank being filled and return it to the tanker. See Figure 6, which shows the proposed tanker transfer arrangement. The full drawing is provided in Appendix A.
Figure 6 : TDI Bulk Tank Arrangement and Transfer Arrangement
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Ohinewai Foam Factory Hazardous Substances Assessment
All other minor liquids (e.g. silicon, amine catalyst, tin catalyst) are delivered in various drum sizes and stored in the Hazardous Substances Store. Apart from the delivery of chemicals and storage of liquid carbon dioxide, all activities are internal.
3.11 Dispatch
Dispatch is located at the front of the site (northern end) and all finished products will be dispatched from there.
3.12 Spill Protection
All hazardous substances at the site will be stored in the buildings in appropriately designed storage areas which will provide spill containment. As discussed in the Section 3.10 there will be a specially designed Hazardous Substances Store which will be used to store the bulk of the hazardous substances used at the site, including a separate room for TDI/MDI storage. The Hazardous Substances Store will be externally bunded and will include the use of an internal flexi-bund arrangement (see Figure 6 and Appendix A).
3.13 Fire Protection
The proposed bed and foam manufacturing facility will be constructed of non-combustible materials. The combustible material in the building will largely comprise of manufacturing materials with the most significant material being the manufactured polyurethane foam held as foam blocks or in manufactured mattresses and beds. The only area not covered by the fire sprinkler system is the TDI bulk storage room within the Hazardous Substances Store which is sealed and discharge from which will be vented to the filter in the event of a spill. The reason for this is the potential for reaction of water with TDI should a spill or tank failure occurs in this area at the same time as a sprinkler release which APL/TCG wants to avoid.
The proposed plant will be fitted with an automated fire sprinkler system which will be designed, installed and maintained in accordance with the New Zealand standard for sprinkler systems NZ 4541:2013. It is understood that the fire sprinkler system is designed to operate on a zonal basis across the factory. If a fire is detected in a particular zone the fire sprinkler system in that zone will be activated and if the fire spreads to the neighbouring zones their sprinkler systems in turn will be automatically activated.
A 150 mm diameter water supply ring main runs around the whole of the proposed facility. This ring main will be fitted with in-ground fire hydrants which can be utilised in the event of a fire. In addition to the ring main a 2,100,000 litre storage tank will be constructed on site to provide enough water storage onsite to enable the automated fire sprinklers to activate and provide 120 minutes of firefighting. The storage tank will feed a 300 mm diameter main running from the tank to the sprinklers. Use of the sprinkler system via the on-site storage tank will be powered by three diesel fired fire pumps (two operational and one on standby) which are located along with the diesel supply tank in a concrete block room with a fire rating of 240/240/240. The diesel fire pumps will draw water from the on-site storage tank and supply 17,000 litres per minute of water at a delivery pressure of 1200 kPA to the fire sprinkler system.
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Ohinewai Foam Factory Hazardous Substances Assessment
In the event the sprinkler system is triggered to extinguish the fire, the fire water will be directed to a catchment pond formed at the eastern side of the site. This system for capturing the firewater and containing it on site is designed to prevent the fire water getting into the site’s stormwater drainage system. The catchment area has a capacity of 2,300 m3 for retaining fire water on-site. The area is shown on the Sprinkler/Fire Run-off Catchment Plan presented in Appendix B.
The bunded areas for containing firewater has been calculated on a realistic fire event which assumes that not all of the sprinkler zones (5) will be activated and that the sprinkler system will quickly put out the fire. The fire sprinkler flow is approximately 280 litres per second and the bunded area will provide sufficient storage for 2.3 hours of total sprinkler activity at the site (assumes all zones are operating). Please refer to the Sprinkler/Fire Run-off Catchment Plan in Appendix B.
3.14 Stormwater Drainage System For the Hazardous Substances Delivery Area when there are no delivery vehicles or containers unloading/transferring hazardous substances in the bunded vehicle delivery area to the Hazardous Substance Store, the dual sump valve bypass will be set to discharge to the site’s stormwater drainage system. When vehicles/containers are unloading hazardous substances, the valve will be switched so that if a spill occurs in the bunded delivery area it will flow into the TDI/MDI bulk storage tank bund (refer to Figure 6 and Appendix A) and not into the site’s stormwater system.
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Ohinewai Foam Factory Hazardous Substances Assessment
4. Hazardous Substances
4.1 Hazardous Substances during Construction
During the construction of the project a range of hazardous substances will be used on site including:
◼ Diesel and oil for vehicles and construction of the plant, stored in portable containers;
◼ Paints and solvents, stored in tins or small drums; and
◼ Compressed gases such as oxygen and acetylene cylinders.
There will be no deliberate discharges of these substances to the natural environment as part of the construction activities. Accidental discharges will be kept to an absolute minimum as part of the housekeeping procedures of the contractors. All empty containers and other refuse will be either returned to the supplier or placed in a skip, which will be emptied regularly at an approved municipal landfill.
The conditions of contract for all construction contractors will emphasise the need to put in place appropriate safeguards to prevent accidental spillages of hazardous substances. One of the criteria that will be included in the assessment of tenders will be the experience and environmental record of the contractor.
4.2 Hazardous Substances during Operation The Comfort Group has supplied Jacobs with the maximum quantities and types of hazardous substances that are intended to be stored at the proposed site, and the exact quantities will be confirmed once a more detailed design of the sites is available. The hazardous substances maximum volumes and classifications under the HSNO Act are provided Table 2 below and are based on the maximum volumes that could be stored when the staged development is completed. The actual volumes and locations where the materials will be stored will be confirmed as part of the facilities detail design.
Table 2 : Summary of substances, volumes and hazard classifications3
Substances HSNO Classifications Maximum anticipated volumes stored
Adhesives 8.3A Corrosive to ocular tissue 2,000 L
Amine Catalysts 3.1D, 6.1C (inhalation, oral, Flammable liquid - low hazard, acutely toxic 1,200 L dermal), 6.3A, 6.4A, 6.5B, via inhalation, oral and dermal exposure, skin 6.9A, 8.2B, 8.3A, 9.1C, 9.3B and eye irritant, contact sensitisers, toxic to human target organs or systems, harmful in the aquatic environment, ecotoxic to terrestrial vertebrates.
3 Hazardous Substances and Industrial and Trade Activity Assessment for proposed foam and bed manufacturing plant, Tonkin and Taylor, June 2016
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Ohinewai Foam Factory Hazardous Substances Assessment
Substances HSNO Classifications Maximum anticipated volumes stored
Anti-microbial 6.1B (inhalation, oral), 6.4A, Acutely toxic via inhalation - oral, eye irritant, 300 L agents 6.5B, 6.9B, 8.2C, 8.3A, 9.1A, contact sensitisers, toxic to human target 9.2B, 9.3C organs or systems, very ecotoxic in the aquatic environment, ecotoxic in the soil environment, ecotoxic to terrestrial vertebrates
Colours 6.4A, 9.1C, 9.1D Eye irritant, harmful in the aquatic 500 L environment, slightly harmful to the aquatic environment or are otherwise designed for biocidal action.
Diesel 3.1D, 6.1D, 6.4A, 6.5B, 9.1C Flammable liquid - low hazard, acutely toxic – 1,500 L harmful, eye irritant, contact sensitiser, harmful in the aquatic environment.
Fire retardants 6.8B, 6.9A, 9.1B Suspected human reproductive or 800 L developmental toxin, toxic to human target Firemaster 550 organ or systems, ecotoxic in the aquatic (Flame Retardant) environment.
Fryol PCF (Flame 6.1D (oral) Acutely toxic - Harmful Retardant)
Methyl Diphenyl 6.1B (inhalation), 6.3B, 6.5A, Acutely toxic via inhalation, mildly irritating to 46,000 kg (30,000 Diisocyanate (MDI) 6.5B, 6.9A (inhalation) the skin, respiratory sensitiser, contact kg in bulk tanks sensitiser, toxic to human target organs or and 16,000 in systems via inhalation. drums)
Toluene 6.1A (inhalation), 6.3A, 6.4A, Acutely toxic via inhalation, irritating to skin 90,000 kg (50,000 diisocyanate (TDI) 6.5A, 6.5B, 6.7B, 9.1C, 9.3B and eyes, respiratory sensitiser, contact kg in bulk tanks sensitiser, suspected human carcinogens, and 40,000 kg in harmful in the aquatic environment, ecotoxic drums) to terrestrial vertebrates.
LG DOP 6.8A, 6.9B (oral), 9.1C, 9.1D Known or presumed human reproductive or 200 L development toxicants; Harmful to human target organs or systems via oral exposure; harmful in the aquatic environment, slightly harmful to the aquatic environment or are otherwise designed for biocidal action.
Methylene chloride 6.1D, 6.3A, 6.4A, 6.7B, 6.9B, Inhalation: Methylene chloride depresses the 500 L 9.3C central nervous system. Skin: prolonged or repeated contact may cause irritation, defatting of skin & dermatitis. Eyes: vapours may irritate eyes. Methylene chloride is listed on the IARC & NTP carcinogen list but not by OSHA
N Methyl 3.1D, 6.1E (oral), 6.3A, 6.4A Flammable, acutely toxic –may be harmful, 200 L Pyrrolidone 6.8A aspiration hazard, skin and eye irritant, known
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Ohinewai Foam Factory Hazardous Substances Assessment
Substances HSNO Classifications Maximum anticipated volumes stored or presumed human reproductive or development toxicants.
Carbon dioxide Non-hazardous None 6,000 kg
LPG 2.1.1A Flammable gas – high hazard 500 kg
Polyols Generally non-hazardous Acutely toxic –may be harmful, Aspiration 405,000 L but may be 6.1E (oral) hazard
The volumes of hazardous substances provided in the Table 2 are the maximum quantities that the plant may store once the development of the bed manufacturing plant is completed. The land use consents sought for the factory envisage the development being completed in stages and for Stage 1, the quantities of hazardous substances stored at the site will be less than the Upper Tier Major Hazard Facility (MHF) threshold for toxic substances and as such will comply with the Lower Tier requirements of the Health and Safety At Work (Major Hazard Facilities) Regulations 2016.
Stage 1 of the factory development will have a reduced volume of MDI and TDI, as each will have only one bulk tank, instead of two. The operation is proposed to scale up over a ten year period. The factory will operate under the Lower Tier requirements in the early stages of development (Stage 1) and then move to an Upper Tier classification and the relevant MHF management and certification requirements will apply.
4.3 Hazardous Substances Site Controls
All parts of the site, including unloading and loading areas, where hazardous substances are stored and handled will be designed, constructed and operated in a manner that prevents discharge to stormwater.
All pooling substances will be either stored internally, appropriately contained within the building (e.g. bunds installed for individual tanks within the building), or within the bunded Hazardous Substances Store on the northern side of the building towards the rear of the site. The bund capacities includes three main bund storage zones (1, 2 and 3) which are broken in to sub zones. as set out in drawings provided in Appendix A. The bund volumes presented on the drawings in Appendix A are based maximum estimates and differ from those presented in Table 3 and 4 which are based on the current design, which may be subject to change as the design progresses.
A summary of the largest tank sizes and bund volumes based on the current design are summarized in Table 3.
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Ohinewai Foam Factory Hazardous Substances Assessment
Table 3: Summary of Largest Tank Sizes and Bund Volumes
Bund Zone Largest tank Bund volume
Zone 1 35,000 L 79,400 litres
Zone 2A + 2B 25,000L + 38,000L drum storage 64,400 Litres
Zone 3 Unloading area 22,000 Litres
The bund volume based on the current design is summarised in Table 4 for the Zone 2B TDI/MDI bund for an assumed bund wall height of 650 mm in order to demonstrate that the design is in conformance with the bunding requirements set out in the Health at Safety Work (Hazardous Substances) Regulations 2017 (HSW-HS).
Table 4: Calculation Zone 2B Bund Volumes
TDI/ MDI Volumes Relevant HSW-HS Requirement Min bund volume Storage in Zones Clause required 2A and 2B
Largest tank 21,825 L 17.100 (1) 110% of largest tank 24,007.5 L (25,000 kg)
Drum storage 39,863 L 13.33 (1A)(b) Greater of 5% of total 5,000 L (50,000 kg) pooling potential or 5,000 L
Provided bund volume Zone 2B (based on 650 mm deep bund wall) 48,750 L
HSW-HS bund requirements satisfied Yes
In the case of the TDI and MDI storage, these will be stored within above ground bulk tanks and drums in a separate sealed room (TDI/MDI Store) as part of the Hazardous Substances Store. The total volume of TDI stored in bulk tanks and drums in the sealed room will not exceed 90,000 kilograms and for MDI it will be 46,000 kilograms. The room will be warmed to around 20oC to keep the stored TDI/MDI in a flowable state so that it can be pumped to the foam blowing plant. The room will be operated in a sealed state so that in the event of a major spill or tank failure all vapours released as a result of the spill will be extracted from the room to the carbon filter for treatment before being discharged to air. Following a major spill, water or other suitable chemicals can be introduced into the room to react with the free TDI to cure the resin. The cured inert material can then be safely removed for disposal.
TDI and MDI unloading from ISO tankers will also be undertaken in a designated delivery area where the ISO tanker will be located in a bunded area (see Figure 6). The delivery areas will be covered by a canopy which will be fitted with plastic side curtains which can be lowered during the transfer of TDI/MDI to protect the area from rain. This designated delivery area will also be used for the unloading of drum stock of TDI/MDI that have been transported by truck to the site. There is a stormwater shut-off valve located in the delivery area. The stormwater shut-off valve will be shut when unloading bulk quantities of hazardous substances. In the event of a spill while unloading, the released material will be contained in the bunded area and will flow to a drain located at the rear of the transfer area. From there it will flow into the base of the bulk tank bund and be removed by a
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Ohinewai Foam Factory Hazardous Substances Assessment
liquid disposal company before the valve is reopened. All stormwater grates will be clearly marked across the site
The flexible ISO Tanker TDI/MDI transfer and vapour lines will be short in length (around two to three metres) which connects the tanker to the vacuum transfer pump lines to the bulk tanks and to the tank vapour return line coupling point. These lines will hang vertically as the couplings on the tanker are at the top of the unit. The couplings are dry couplings and if the couplings should come adrift during transfer they will automatically self-seal. The transfer lines and the vapour return lines are welded steel running in the ceiling of the access way between the delivery areas and the bulk tanks.
Should a release occur, implementation of the Emergency Plan (refer to Appendix C) will ensure appropriate spill response actions are taken. The site has specific spill response procedures for the use and storage of di-isocyanates. Spill kits will also be located at the Hazardous Substances Store and any other areas of the site which will hold or store hazardous substances.
The Emergency Plan for Ohinewai is currently at a draft phase and will be updated as detailed design of the factory progresses. The Emergency Plan addresses the requirements under the Health and Safety at Work (Hazardous Substances) Regulations 2017 for an Emergency Management Plan, which is required for the types and volumes of hazardous substances stored at the site.
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Ohinewai Foam Factory Hazardous Substances Assessment
5. Qualitative Risk Assessment
5.1 General Approach
The NSW Department of Planning (NSW DoPI) Multi-Level Risk Assessment4 approach was used for this study. There is currently no equivalent guidance provided in New Zealand for conducting a Qualitative Risk Assessment (QRA) and the Multi-Level Risk Assessment approach has been used and accepted as an appropriate approach by planning authorities in New Zealand (Ngawha Geothermal Development, Wiri Mens Correctional Facility) for conducting a QRA for land use planning purposes. The approach considered the development in context of its location and its technical and safety management control. The Multi-Level Risk Assessment Guidelines are intended to assist industry, consultants and the consent authorities to carry out and evaluate risk assessments at an appropriate level for the facility being studied.
The Multi-Level Risk Assessment approach is summarised in Figure 7. There are three levels of assessment, depending on the outcome of preliminary screening. These are:
• Level 1 – Qualitative Analysis, primarily based on the hazard identification techniques and qualitative risk assessment of consequences, frequency and risk;
• Level 2 – Partially Quantitative Analysis, using hazard identification and the focused quantification of key potential offsite risks; and
• Level 3 – Quantitative Risk Analysis (QRA) based on the full detailed quantification of risks, consistent with Hazardous Industry Planning Advisory paper No.6 – Guidelines for Hazard Analysis.
4 Assessment Guideline Multi-Level Risk Assessment, New South Wales Department of Planning – 2011
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Ohinewai Foam Factory Hazardous Substances Assessment
Preliminary Screening (Qualitative Assessment)
Risk Classification and Prioritisation
Not potentially Hazardous – No
Further Analysis Qualitative Analysis Partial Quantitative Quantitative Risk (Level 1) Analysis (Level 2) Analysis (Level 3)
Figure 7 : Multi-Level Risk Assessment Steps
The QRA conducted following the guidance provided in Applying SEPP 335 is often referred to as a Preliminary Hazard Assessment and is based on the separation from sensitive receptors, the proposed controls and design of the plant and the potential for domino incidents with adjacent industrial sites, each of which were considered. The QRA conducted combines both a qualitative analysis (Level 1) and partial quantification (Level 2) where all hazards in terms of their consequences (effects) to people beyond the site boundary are assessed. Partial quantification was applied to development for the hazards identified in order to determine whether they are Credible Major Accident Events (MAEs) with potential consequences beyond the site boundaries but with a low frequency of occurrence. Consequences for a number of failure /fault modes were assessed using empirical calculations and dispersion modelling (CALPUFF, ALOHA and SCREEN 3) as required for a Level 2 assessment. The results of these consequence analysis are provided in Section 5.4. It should be noted that this risk assessment is limited to analysis of hazards at the facility such that should credible accident events occur, will result in offsite effects. In going through the process, a number of potential hazards were assessed, as outlined below.
5.2 Detailed Approach
A qualitative risk assessment was conducted for the proposed bed and foam manufacturing plant at Lumsden Road using the following steps: 1) Hazard Identification; 2) Fault/Failure mode analysis; 3) Likelihood analysis of the fault/failure mode/release; 4) Off-site consequence analysis of the accident event; and 5) Qualitative determination of risk.
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Ohinewai Foam Factory Hazardous Substances Assessment
A hazard identification process was conducted for the site facilities and operations as described in Section 3 of this report. For each hazard a number of fault/failure modes were identified. Incidents that could have a potential off-site effect were identified. Each postulated hazardous incident where a potential offsite effect was identified was assessed semi-quantitatively to determine the level of site effect. Where the qualitative and semi-quantification analysis determined that the safeguard proposed (engineering controls and SOPs) were adequate to control/mitigate the hazard, or that the consequence would obviously have no offsite effect, no further analysis was performed. All MAEs identified from the hazard identification and analysis process were then subjected to qualitative analysis based on the descriptors and risk matrix used is presented in Appendix F.
Recommendations were also made regarding risk reduction measures to reduce risk to a level “as low as reasonably practicable (ALARP), regardless of the risk levels achieved.
5.3 Hazards
Hazards have been identified relating to the transfer, storage and use of the hazardous substances at the site. Each hazard could result in an accidental release to the environment, or accidental human exposure, if a failure or incident event occurs. The likelihood of the incident occurring, and the consequences of the event is covered in the latter sections.
A hazard is defined as a source of potential harm, or situation with the potential to cause loss or adverse impacts5. Hazards for the Lumsden Road site include: 1) Incompatibility of hazardous substances stored on site; 2) Toxic/corrosive properties; 3) Ecotoxic properties; 4) Process; 5) Fire (including fire water) and explosion; 6) Vandalism and deliberate damage; and 7) Natural Hazards (earthquake and flooding).
5.3.1 Incompatibility Hazard
The chemical makeups of some substances make them unstable or reactive when combined with other incompatible substances. This incompatibility may present an intrinsic hazard for many chemicals transferred, stored, and used at industrial sites both during construction and operation.
Based on the inventory of hazardous substances in Table 1, there do not appear to be any incompatibilities between substances used for the production phases of the Project, apart from TDI/MDI which can have an exothermic reaction with water, water being the key catalyst used in the urethane foam blowing process. Application of water to TDI/MDI is undertaken under controlled conditions as part of the foam blowing process.
5 Environmental risk management – Principles and process (HB203:2000)
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Ohinewai Foam Factory Hazardous Substances Assessment
5.3.2 Toxic/Corrosive (Human Health) Hazard
Toxicity and corrosiveness are intrinsic hazards for many chemicals transferred, stored and used at industrial sites both during construction and operation. The toxicity hazards of the substances relate to the potential adverse effects on workers at the site and the surrounding community via ingestion/inhalation or dermal/ocular exposure. The level of toxicity is variable and relates to the intrinsic properties of the substance and their concentrations. The HSNO classifications for toxic substances are based on the toxicity of the substances. For example, a substance classified as acutely toxic (6.1A) is significantly more toxic than a substance classified as 6.1E. Many of the substances to be transferred, stored and used at the site have a toxic/corrosive hazard (Class 6 and 8) as listed in Table 2. However, the volumes of the materials to be stored at the site in most instances are small, apart from TDI and MDI. As such the relative risk posed to people in neighbouring properties in the event of an incident at the site from these materials apart from TDI and MDI, for example a spillage, is negligible.
TDI and MDI pose the main toxic hazard to neighbouring properties in the event of an incident at the site due to the volumes of materials held on site. Di-isocyanates are used as chemical intermediates in the production of polyurethane products such as foams, coatings and elastomers. Isocyanates are not known to occur naturally in the environment and the most likely means of entering the ambient air environment is the release as emissions from industrial and commercial plants using isocyanate compounds.
The following section provides background information on their toxic properties.
5.3.2.1 MDI
Commercial MDI exists as a mixture of 4,4-MDI (which is a monomer) and certain oligomers of MDI. The content of monomeric MDI in commercial products is generally between 45 to 65% by weight, depending on the manufacturer. The mixture of monomeric MDI and oligomers is called polymeric MDI (pMDI).
Polymeric MDI, which is a semi-solid liquid (gel), has a very low vapour pressure at ambient temperatures. Monomeric MDI is more volatile than pMDI but still has relatively low volatility compared to other isocyanates such as hexamethylene diisocyanate (HDI) or toluene diisocyanate (TDI). Because of its low volatility, the rate of release from storage and handling facilities at ambient temperatures is also very low. The presence in air of pMDI will only be potentially significant as a vapour at elevated temperatures, or if present as fine droplets, or when adsorbed onto particulate.
Polymeric MDI reacts with water to generate amines, polyureas, and carbon dioxide. pMDI, being insoluble in water, only reacts slowly but the reaction is faster when pMDI is present as fine droplets (due to increased surface area) and accelerates as temperature increases. pMDI reacts in air with hydroxyl radicals and has a reported half-life of around 1 day. Since it polymerizes in the presence of water (albeit slowly), its ecological risks are regarded as low.
The half-life of MDI is on the order of one day. Accordingly, there is no long-term cumulative build- up of these compounds in the environment.
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Polymeric MDI, because of its very low vapour pressure is occupationally the least significant of the industrial di-isocyanates but it is still an allergen and sensitiser and good occupational hygiene practices must be adopted to protect employees. Ambient air standards and guideline values are low in keeping with these properties.
The WorkSafe has established an 8-hour Time Weighted Average (TWA) for isocyanates of 0.02 mg/m3 and a 15-minute Short Term Exposure Limit (STEL) of 0.07 mg/m3 for isocyanates (as –NCO), which is intended to protect against possible sensitisation in workers and reduce the potential opportunity for accidental isocyanate exposure6.
The main exposure pathway for humans to MDI outside of manufacturing facilities is via inhalation. Acute exposure to MDI has been associated with asthma, dyspnea and other respiratory impairments in workers.
Respiratory sensitisation, also known as “isocyanate asthma”, has been shown to occur following long-term exposure. The asthma reaction may occur immediately after exposure to isocyanates or be delayed for several hours. The threshold for sensitisation to MDI has not been established.
The International Agency for Research on Cancer (IARC) has classified MDI as a Group 3 carcinogen “not classifiable as to human carcinogenicity”, based on insufficient evidence of carcinogenicity in experimental animals and humans. Limited experimental animal studies have reported increased pulmonary adenomas in one strain of rats. However, no conclusive evidence of MDI increasing incidence of cancer in humans has been documented.
5.3.2.2 TDI
Toluene diisocyanate is used as a chemical intermediate in the production of polyurethane products such as foams, coatings and elastomers. TDI is not known to occur naturally in the environment and the most likely means of entering the ambient air environment is its release as emissions from industrial and commercial plants using TDI. TDI is removed from the atmosphere by reaction with hydroxyl radicals and through dry deposition. The estimated half-life of TDI ranges between 3.37 hours to 1.48 to 2.79 days. Atmospheric degradation may also occur through contact with water in clouds, fog or rain.
The main exposure pathway for humans to TDI outside of manufacturing facilities is via inhalation. Acute exposure to TDI has been associated with severe immunological asthma-like reactions, and it affects the respiratory, gastrointestinal and central nervous system. Chronic exposures have resulted in significant decreases in lung function of workers; it causes an asthma-like reaction (wheezing, dyspnoea and bronchial constriction); and it has effects on the liver, blood and kidneys. Most TDI is metabolised and eliminated in the urine as the metabolite toluene diamine within 72 hours following exposure.
6 http://www.osh.dol.govt.nz/order/catalogue/pdf/isocyanates.pdf 7 Canadian Centre for Occupation Health and Safety, Hazardous Substances Data Bank, 2,4- Toluene Diisocyanate, 14/01/2002 (www.ccohs.ca/products/databases/samples/hsdb.html). 8 Ontario Ministry of the Environment, Ontario Air Standards for Toluene Diisocyanate (TDI), June 2004. 9 Bidelman TF; Environ Sci Technol 22: 361-367, 1988. (http://toxnet.nlm.nih.gov).
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Respiratory sensitisation, also known as “isocyanate asthma”, has been shown to occur following TDI exposure. The asthma reaction may occur immediately or be delayed for several hours. The threshold for sensitisation has not been established. In one study, respiratory tract sensitisation response producing bronchial asthma in up to 10% of previously exposed individuals may occur at a TDI concentration in air of 0.036 mg/m3. Another study indicated that exposure to levels as low as 0.014 mg/m3 (0.002 ppm) can result in chronic loss of pulmonary function.
The American Conference of Governmental Industrial Hygienist (ACGIH 1999) have established an 8- hour Threshold Limit Value (TLV) of 0.005 ppm for TDI (0.036 mg/m3) which is intended to protect against possible sensitisation in workers and reduce the potential opportunity for accidental TDI exposure.
The USEPA has developed an Inhalation Reference Concentration (RfC) for TDI of 0.07 µg/m3 as an estimate of daily exposure, below which there is expected to be no appreciable risk of deleterious effects during a human lifetime10. The inhalation RfC was derived from the information used to develop the ACGIH TLV 8-hour time weighted average.
The No Observable Adverse Effects Level for Human Equivalent Concentrations (NOAEL(HEC)) for TDI which is calculated from an 8-hour TWA occupational limit to provide a continuous exposure is 0.002 mg/m3. A Workplace Exposure Standard _Time Weighted Average is the concentration in air that a worker can be safely exposed to a contaminant in air for an eight-hour period without suffering any adverse effects on their health. The NOAEL(HEC) is the concentration that a person can be continuously exposed to (24 hours a day, seven days a week) resulting no observable adverse effects on their health.
Emergency Response Planning Guideline 2 (ERPG-2)11, developed by the American Industrial Hygiene Association is defined as the maximum airborne concentration below which it is believed nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms that could impair an individual's ability to take protective action. The ERPG-2 for TDI is 0.083ppm.
The International Agency for Research on Cancer (IARC) has classified TDI as “possibly carcinogenic to humans” (Carcinogenicity Group 2B), based on sufficient carcinogenicity evidence in experimental animals, but there is inadequate evidence in humans. Experimental animal studies have reported significantly increased incidences of tumours of the pancreas, liver and mammary glands from oral exposure to TDI, but not via inhalation. Other studies where rats and mice were exposed to a TDI mixture via inhalation resulted in no carcinogenic effects being observed.
Based on these studies the Californian Air Resources Board (CARB) has developed an oral cancer slope factor for TDI of 3.9x10-2 (mg/kg/day)-1 and an inhalation unit risk factor for TDI of 1.1x10-5 µg/m3 for cancer.
As with MDI, the relevant NZ Workplace Exposure Standards relevant to TDI are for the general class of isocyanates (as –NCO). These include the 8-hour Time Weighted Average (TWA) of 0.02 mg/m3 and a 15-minute Short Term Exposure Limit (STEL) of 0.07 mg/m3.
10 http://www.epa.gov/iris/subst/0503.htm 11 https://www.epa.gov/sites/production/files/2013-11/documents/oca-apds.pdf
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5.3.3 Ecotoxicity Hazard
Ecotoxicity is an intrinsic hazard of many substances transferred, stored and used at industrial sites both during construction and operation. The ecotoxicity hazards of the substances relate to the potential adverse impacts to ecosystems and natural resources. Substances to be transferred, stored and used at the facility set out Table 2 which are ecotoxic hazards include:
◼ Catalysts;
◼ Antimicrobial agents;
◼ Colours;
◼ Fire retardants
◼ LG DOP;
◼ TDI;
◼ Methylene chloride; and
◼ Diesel oil.
The key ecotoxic hazard which could result in off-site effects relates to aquatic ecotoxicity.
5.3.4 Process Control Failure Hazards
Process hazards relate to discharges of contaminants to the environment from process activities under normal operations and in the event of failures of engineered controls used to reduce the discharges to acceptable levels. The foam manufacturing process discharges contaminants to air that can be classified as toxic to human health. These TDI and MDI discharges from the foam blowing plant are controlled at the site by a Dunlop Foam filter which cleans the extracted air from the foam blowing plant by removing the TDI and MDI vapour prior to the extracted air being discharged to atmosphere. The environmental effects on the surrounding environment under normal operations are assessed in the Air Resource Consent for Proposed Bed Manufacture Factory, Warehouse and Office Facility, Ohinewai, Waikato February 2020 prepared by Jennifer Barclay, Atmospheric Science Global Ltd, in which the effects are found to be acceptable.
This report will assess the hazards posed by the faults/failures of key equipment required to mitigate TDI and MDI discharges and abnormal process conditions. These hazards include: ▪ Electrical supply failure; ▪ Foam blowing plant extract fan failure; ▪ Failure/breakthrough of the carbon filter; and, ▪ Hot block (excessive heat generated as result of the foam blowing reaction).
5.3.5 Fire and Explosion Hazards
Fire and explosion are intrinsic hazards for many hazardous substances transferred, stored and used at industrial sites both during construction and operation. A fire at the facility could also result in
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Ohinewai Foam Factory Hazardous Substances Assessment
toxic by-products (from the combustion of chemicals) being discharged to air. Substances to be transferred, stored and used at the facility which have a fire/explosion hazard include: ▪ Catalysts; ▪ N Methyl pyrrolidine; ▪ Diesel fuel; and ▪ LPG bottles for forklifts.
It has been assumed in this assessment that the TCG bed and foaming manufacturing plant combustion appliances will be fired on natural gas from a reticulated gas main.
Apart from LPG all the substances listed above are classified as Class 3.1D flammable substances and are at the lower end of the flammability intrinsic hazard scale as they do not create hazardous atmosphere zones and as such would require a flame or simple ignition source to be in contact with them to be ignited.
The quantities held on site of these substances are small and as such these substances will not by themselves be a risk to people working or living in neighbouring properties. This hazard has not been taken further in the QRA as the hazards will not result in credible major accident scenarios which will have effects beyond the boundary of the site.
LPG the cylinders for the forklifts will involve a simple swap out process with a used cylinder being replaced on the forklift by a full cylinder, and therefore the likelihood to create a vapour cloud from a release of LPG from one of these cylinders is very unlikely.
A fire during which the fire sprinkler systems in the plant fail to deploy could result in a release of toxic by-products to air and water is a potential credible accident scenario which could have off-site impacts and will need to be analysed in the QRA.
5.3.6 Vandalism Hazard
Deliberate damage by vandalism to the equipment or storage tanks on site could result in fire or release of hazardous materials to the environment in addition to damage to property or person.
5.3.7 Natural Hazards
Natural hazards associated with the operation of the site include possible earthquake and flooding. The area could experience strong ground shaking during a large earthquake or volcanic eruption, and larger earthquakes on distant faults could give rise to similar levels of ground shaking as would occur during a localised fault rupture.
A flood model was completed to quantify the risk of a stop bank breach of the Waikato River in 3 separate locations. The assessment was carried out by Woods report dated 18/11/2019 and updated in May 2020. The modelling outlines that during a stop bank breach, flooding would not affect the factory and bypass the site to the north.
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5.4 Fault Failure Events and Consequence Analysis of Potential Offsite Exposure
5.4.1 Incompatibility Events
Potential fault/failure events that could result in an incompatibility reaction between TDI/MDI and water at the plant have in the main been carefully engineered out at the plant to minimise the level of risk posed by this hazard and are further minimised by strict handling procedures.
TDI/MDI is stored at the site in drums and in bulk storage tanks in a separate sealed room which is fitted with extraction to the filter in the Hazardous Substances Store. The room is separately bunded and its walls, floor and ceiling will be constructed of materials which have a 120/120/120 minute fire rating. The TDI/MDI Store will not be fitted with fire sprinklers due to the potential reaction of any spilled TDI/MDI with water.
3 The TDI/MDI bulk tanks are situated in a bunded area which has a total spill capacity of 45 m . The TDI/MDI bulk tank bund provides the first line of spill protection ,with a further 164 m3 of spill containment provided by the remainder of the TDI/MDI Store area used to store drums should the TDI/MDI bulk tank bund be over topped.
Exposure to water is eliminated apart from a little bit of moisture in the bulk tanks which will accumulate as a result of atmospheric conditions over time. This moisture is present in very small quantities and as such is not enough to trigger a reaction. This small quantity of moisture reacts overtime with the TDI/MDI to form urea. The TDI/MDI from the bulk tanks is passed through dehumidifiers when the material is being pumped to the foam blowing plant to remove any moisture.
TDI/MDI is transferred from the ISO tankers to the bulk tanks located in the separate bunded MDI/TDI Store, with the transfer occurring in a covered transfer area fitted with plastic side curtains which can be lowered during transfer of product to protect the area from rain. The transfer of TDI/MDI from ISO tanker to the bulk tanks is covered by a TCG SOP (see Appendix E). Again, the likelihood of the TDI coming into contact with water, should the line transferring the material to the bulk tanks from the tanker fail, is highly unlikely given that the measures proposed to protect the transfer area from rain and as such we believe is not a credible accident scenario that will have offsite effects. The tanker transfer area is designed that should a transfer hose fail, the released material will be contained in the bunded area and will flow to a drain located at the rear of the transfer area. From the drain sump it will flow via drain into the base of the bulk tank bund in the TDI/MDI Store, thereby significantly reducing the potential for any spilled material to come in to contact with stormwater.
TDI/MDI can be pumped from drums stored in the TDI/MDI Store into the bulk tanks. The transfer occurs in the sealed TDI/MDI Store and any spill during this transfer process will be contained in the store and will not come into contact with water.
Drums of TDI/MDI are transferred from the TDI/MDI Store to the Underlay Foam Blowing Plant by forklift. The forklifts use a drum grip which prevents drums being pierced by the forks. The likelihood of the drums being damaged, leaking and reacting with stormwater should the spill occur during a rain episode is very low. Should a drum be damaged, the TCG spill procedure for TDI/MDI, which all staff are trained in, is followed and by following this procedure will reduce the likelihood for an incompatibility reaction between TDI/MDI with water. The amount of material typically spilt from a
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Ohinewai Foam Factory Hazardous Substances Assessment
drum is not large (less than 20 litres) and as a result should the spilt material come into contact with water the reaction will be limited. Also, drums have been found to self-seal quickly with the exposed TDI/MDI material reacting with moisture to form a urea plug which plugs the hole in the drum, reducing the amount of material that leaks or is spilt.
The exposure potential to persons in neighbouring properties from an incompatibility event at the APL/TCG site will be very unlikely given the proposed controls which effectively eliminate and isolate the hazard. As a result, the risk posed to residential properties to the south of the site on Lumsden Road is low.
5.4.2 Toxic/Corrosive (Human Health) Events
Access to hazardous substances at the Lumsden Road facility will be restricted to site personnel who are trained for handling the products. The substances will also be labelled as to make it clear to workers the toxic or corrosive hazards along with access to the substance safety data sheet. The foam manufacturing plant in which the toxic TDI/MDI materials are handled and used in the process is housed in a separate building to the rest of the facility and is effectively ‘isolated’ from the rest of the facility. All the bulk and drummed hazardous substances apart from TDI/MDI are stored in a designated Hazardous Substances Store which is appropriately designed. Bulk and drummed TDI/MDI are stored in the sealed TDI/MDI Store which is located in the Hazardous Substances Store which is appropriately designed and has extraction to the carbon filter in the event of a spill.
The other materials with toxic/corrosive properties that will be required in smaller amounts, including paints and degreasing agents, will be stored in designated storage cabinets when not in use. Therefore, it is considered unlikely that workers will be exposed to the hazardous substances in significant quantities and the subsequent level of risk is low.
Fault/failure events which could result in toxic substances, in particular vapour being released from the site and affecting neighbouring properties, include: ▪ Spillage of TDI/MDI; ▪ Failure of TDI/MDI transfer line during bulk transfer of TDI/MDI ▪ Failure of vapour transfer line during bulk transfer of TDI/MDI; ▪ Failure of TDI/MDI transfer from drums to bulk tanks; and, ▪ Failure of the carbon filter allowing breakthrough of vapours to occur. As discussed previously, the offsite toxic effects of TDI/MDI from the foam blowing plant and the foam underlay plant under normal operations on the surrounding environment are assessed in the Air Quality Assessment Proposed Bed Manufacturing Factory, Ohinewai, Waikato April 2020 prepared by Jennifer Barclay, Atmospheric Science Global Ltd, as acceptable in that they meet all the health based ambient air standards assessed in the report. This QRA therefore does not assess the effects of emissions from the plant operating under normal conditions. Spillages of TDI/MDI at the site have the potential to release TDI/MDI vapours from the pooled material into air. TCG’s design of the facility in regard to the storage of hazardous substances and its operating and emergency management spill procedures will minimize the risk of hazardous substances being released to the environment. Storage of hazardous substances, in particular
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Ohinewai Foam Factory Hazardous Substances Assessment
TDI/MDI will be indoors in covered drums, enclosed containers, bunded bulk tanks, and associated pipeline distribution systems.
The site’s TDI, MDI, polyol and CO2 bulk tanks will be filled by road tanker as required. There is a dedicated transfer area for TDI, MDI and polyol. Overfilling of bulk tanks will be prevented by the installation of high-level alarms and automatic trips. In a worst-case incident where the bulk tanks level alarms fail, the material will flow into the bulk tank bunded areas and will be contained there. For TDI/MDI the bulk tanks are in a separately bunded area in the sealed TDI/MDI Store which provides further spill containment. Any vapour released from the spilled material (drums or bulk tanks) in the TDI/MDI Store will be removed from the store and directed to the carbon filter for treatment before being discharged to air. The likelihood of such a spillage occurring with the TDI/MDI bulk tank bund being filled is extremely unlikely and this would only occur following a catastrophic failure of APL/TCG engineered controls (failure of high level alarms, all tanks are filled so the material overflows into the TDI/MDI bulk tank bund and that volume is enough to fill the total volume of the TDI/MDI tank and drum bund of 47m3). During Stage 1 of the development the TDI and MDI bulk tanks will be filled from drum stock that is brought to the site. This transfer will occur within the confines of the MDI/TDI Store.
In the event of a spill TDI will release vapour to air at a relatively slow rate as the material has a low vapour pressure at room temperature. Tonkin and Taylor12 have estimated that the vapour release rate of TDI from a worst-case spill of the material which fills the TDI/MDI bulk tank bund is 0.4 kg/hour. It should be noted that the transfer of TDI/MDI from ISO tankers to the bulk storage tanks will occur when the foam plant is not running. The release of TDI to air from the carbon filter is based on the removal efficiency of the filter (99.5%) and based on the air dispersion modelling conducted by Jennifer Barclay, would result in a predicted highest ground level ground concentration 0.036 µg/m3 as a one hour average (based on highest one-hour 99.9 percentile predicted ground level concentration of 0.014 µg/m3 as a one hour average under normal operations for the 2016 meteorological data, as set out in Table 6.1 of the dispersion modelling report13), which is well below the No Adverse Effects Level for Human Equivalent Concentrations (NOAEL(HEC)) for TDI14 calculated from an 8-hour TWA occupational limit for a continuous exposure being 0.002 mg/m3. As such, should this incident occur, the offsite effects will be acceptable and will not result in adverse health effects to people working or living in the surrounding area, including those working on the nearby rail siding which is located 50 m from the Hazardous Substances Storage and transfer area.
A spill resulting from failure of the transfer line from a drum to the bulk tanks will result in a maximum spillage of 205 litres which is significantly less than the TDI/MDI bulk tank and drum bund volume of 47 m3 and as such the vapour release will be much smaller. The vapour will be extracted to the carbon filter for treatment and once treated will have negligible offsite effects if any. The tanker trucks used for filling the storage tanks on site will be restricted to road tanker transfer areas (one for TDI, MDI and polyol and the other for CO2), with spill containment lips and dedicated drains and sumps (containing isolation valves). The tanker transfer area is designed so that should a transfer hose fail the released material will be contained in the bunded area from the drain sump it can flow into the base of the TDI/MDI bulk tank bund. The vapour from the material that flows into
12 Tonkin and Taylor, Calculation of Toluene diisocyanate vapour emission in the event of a spill. Letter, 1 June 2017 13 Air Quality Assessment Proposed Bed Manufacture Factory, Ohinewai, Waikato April 2020 prepared by Jennifer Barclay, Atmospheric Science Global Ltd 14 Toxnet, Toxicology Data Network, Toluene Diisocyanates (http://toxnet.nlm.nih.gov),
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Ohinewai Foam Factory Hazardous Substances Assessment
the base of the bulk tank bund in the TDI/MDI Store will be extracted to the filter for treatment prior to discharge to air. The transfer of TDI from the ISO tanker to the bulk tanks is at a rate of around 330 kg/minute. We have assumed that should a transfer line fail, as a worst case it would take two minutes for the transfer pump to be shut down, resulting in a spill of around 660 kilograms which would cover an area of around 18 m2 in the bunded delivery area. This accident scenario was modelled using ALOHA17 to determine the downwind concentrations of TDI if the material was to remain in the delivery area bund. The modelled simulation shows that at a distance of 11 metres from the spill the TDI concentration is predicted to be below the ERPG-2 of 0.083 ppm. As result there would be no adverse effects from such an incident at or beyond the boundary of the Lumsden Road site, given that at its closest point, the dedicated tanker and drum transfer area is 50 m from the rail siding, 150 m to the property boundary and 250 m from the closest sensitive (residential) receivers. In the event that drums are damaged in the transfer from a truck in the unloading area to TDI/MDI Store, the resulting scenario would be similar to that of a transfer line failure, with around 500 kgs of TDI being spilt in the bunded transfer area. This is based on the assumptions that the 200 litre drums of TDI are carried four to a pallet and if a pallet is accidentally dropped then not all the contents of the pallet would be spilt. The resulting downwind concentration would be below the ERPG-2 of 0.083 ppm at around 10 metres or less and such an incident would not result in offsite effects. Failure of the vapour line between the ISO tanker and the bulk tanks will result in a small vapour release of TDI/MDI into the tanker transfer area and this material will be released to atmosphere. With the tanker operator standing by the pump during the transfer operation, the length of time of the release in the unlikely event of a line failure would be minimised as the tanker operator would quickly shutdown the transfer pump. Also, the amount of vapour generated in the tank by TDI is low given that it will be held between 20 and 25oC, which is significantly below the boiling point of 252oC and at which temperature TDI has a low vapour pressure (0.015 hPa at 20oC15). We note that TDI does have relatively high volatility at higher temperatures such as those during the foam manufacture, which is controlled via the extraction system but the volatility at ambient temperature is low. The potential vapour release during a spill was calculated based on an ambient temperature of 25oC which is at the upper end of normal ambient temperatures at the proposed location.
The maximum average temperature of 25oC used in the assessment’s consequence analysis is based on information sourced from NIWA16, which provides an average temperature for the Waikato region of 18oC
It should be noted the transfer of drummed and bulk stock is undertaken under cover and this material is quickly moved inside the building to the TDI/MDI store, minimizing exposure of the material to higher ambient air temperatures.
However, given the above, we have assessed the potential off-site concentrations of TDI from the failure of a vapour transfer line based on the following assumptions:
15 BASF, Safety data Sheet for Lupranate T-80, 02.04.2014
16 https://niwa.co.nz/our-science/climate/publications/regional-climatologies/waikato
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▪ Failure of vapour transfer line results in discharges of displaced vapours from the TDI storage tanks for a period of two minutes whilst the transfer pump is shut down. ▪ Volumetric flow rate from the transfer line was calculated assuming a TDI transfer rate of 330 kg/min (275 litres/min). ▪ Displaced air discharged from the transfer line was assumed to be saturated with TDI. The concentration was determined using Raoult’s law, assuming partial pressure of 0.01 mmHg at 25C (1.33 Pa17) for TDI in an overall atmosphere of 1014 hPa. The resulting concentration of TDI is 13.1 ppm (93.5 mg/m3) in the discharged vapour. ▪ The mass emission rate of TDI was calculated from the concentration and flow rate as being 0.43 mg/s over the two-minute period of discharge.
The SCREEN318 dispersion model developed by the US Environmental Protection Agency was used to estimate worst-case ground level concentrations from a vapour transfer line failure based on the above assumptions. The result of the modelling predicts a maximum ground level concentration of TDI from the vapour transfer line discharge of 0.27 µg/m3 as a 1-hour average at a distance of 36 metres from the point of discharge. At a distance of 150 metres from the point of discharge, the concentration is predicted to be 0.14 µg/m3 as a one-hour average and is well below the NOAEL(HEC) for TDI of 2 µg/m3. As such, should this incident occur, the offsite effects will be acceptable and will not result in adverse health effects to people working or living in the surrounding area, including those on the rail siding. If a drum or container containing TDI or MDI does leak while outside of the storage area the size of the spill will not be large and due to its low vapour pressure, the vapour release will be low. For a TDI drum spill (250kg)) the vapour release is small and based on ALOHA19 simulations the distance to the ERPG-2 (safe concentration)) is around 10 metres or less and as such as drum spill will not have offsite effects.
Individual and societal risk has not been calculated as the consequence analysis shows there is no off- site consequences beyond the boundary of the site. For a range of accident /fault/failure events associated with the proposed foam blowing activities and the storage and handling of TDI, the level of effect (consequence) predicted at or beyond the boundary of the site was well below the No Observable Adverse Effects Level for Human Equivalent Concentrations (NOAEL(HEC)) for TDI of 0.002 mg/m3. The modelling predicts at 150 m from the point of discharge, a concentration 0.14 µg/m3 as a one-hour average for the failure of a transfer line. For a spill in the drummed and bulk tank TDI/MDI storage bund with extraction to the carbon filter and based on the air dispersion modelling conducted by Jennifer Barclay, this would result in a predicted highest ground level ground concentration 0.036 µg/m3 as a one-hour average at the boundary of the site. Based on a Lethal Concentration of 50% (LC50) for TDI of 610 mg/m3 the consequence levels in respect to a fatality are respectively 2.2 x 10-7 and 5.9 x10-8 which are well below the risk criteria levels as set out
17 https://www.cdc.gov/niosh/npg/npgd0621.html 18 The SCREEN3 model is a PC-compatible companion to the revised screening procedures document, "Screening Procedures for Estimating the Air Quality Impact of Stationary Sources, Revised," EPA-450/R-92-019, US EPA 19 ALOHA (Areal Locations of Hazardous Atmospheres) Model was developed jointly by the National Oceanic and Atmospheric Administration (NOAA) and the U.S. Environmental Protection Agency (EPA), is a computer program designed to model potential chemical releases, as well as thermal radiation and overpressure related to toxic chemical releases resulting from fires and/or explosions (EPA and NOAA 2007).
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Ohinewai Foam Factory Hazardous Substances Assessment
in the NSW Land-use Planning Criteria20 for residential of 1 x 10-6 and for protection of workers of 50 x 10-6 .
The injury risk criteria for toxic gas release is “Toxic concentrations in residential and sensitive use areas should not exceed a level which would be seriously injurious to sensitive members of the community following a relatively short period of exposure at a maximum frequency of 10 in a million per year.” The modeling shows that this criterion will be easily met as the consequence levels in respect to a fatality are respectively 2.2 x 10-7 and 5.9 x10-8 . In the unlikely event that a drum(s) containing TDI or MDI is damaged while being transported to the site or there is a vehicular accident resulting in damage to drums that occurs near residential properties, than evacuation of people residing within 40 -50 m downwind of the accident site should be undertaken by the emergency services attending the accident. This distance is based on four drums being damaged and 2,000 kgs of TDI being released, which is the full content of each damaged drum.
Breakthrough of TDI/MDI vapours through the carbon filter could occur in the event the activated carbon media in the filter becomes overloaded and does not have sufficient capacity to remove the TDI/MDI monomer vapours from the air extracted from the foam blowing plant. When breakthrough occurs the discharge of TDI/MDI will be more elevated than the normal emission and if it goes undetected could result in increased level TDI/MDI concentrations. The carbon filter suppliers have indicated to TCG that based on the current rate of production the carbon filter currently installed at the Otahuhu Plant and which will be shifted to this site has a life expectancy of 15 years before the media will need to be replaced. The media will be replaced as part of the relocation process prior to installing the filter at the Lumsden Road site.
The Carbon Filter media will be included in the programme maintenance schedule. Carbon filter removal efficiency testing will be carried out on a regular basis (annually) to check that the filter’s removal efficiency is being achieved and to check for any increased levels of discharges after the filter which could be an indication of breakthrough of occurring. If the discharge levels of the TDI/MDI measured after the filter show a 25% increase, then the testing will be repeated and if found to be still elevated, actions will be taken to replace the media. Otherwise the media will be replaced every 10 years. An increase of discharges of TDI in the order of 25% to that modelled will not result in ground level concentrations in the surrounding area which could result in measurable health affects, as the highest predicted maximum ground level concentration will be well under the NOEAL (HEC) of 0.002 mg/m3.
5.4.3 Ecotoxicity Events
TCG’s design of the facility for the storage of hazardous substances, as well as its operating and emergency management spill procedures, will minimize the risk of hazardous substances being released to the environment via the stormwater drainage system. Storage of hazardous substances will be indoors in covered drums, enclosed containers, bunded bulk tanks, and associated pipeline distribution systems. It is not expected that any hazardous substance would come into direct contact with the site’s stormwater from these storage arrangements. All drums, containers and bulk tanks will be fitted with secondary containment (bunds, spill containment lips, or dedicated interceptors) which
20 Hazardous industry Planning Advisory Paper No 4, Risk Criteria for Land Use Safety Planning, NSW Department of Planning, 2011
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Ohinewai Foam Factory Hazardous Substances Assessment
is in conformance with the Health and Safety at Work (Hazardous Substances) Regulations 2017. The size of the secondary containment areas in the Hazardous Substances Store is shown in a drawing provided in Appendix A.
If a drum or container does leak while outside of the storage area the potential for it to flow far from the point of leakage is very low based on small volumes (less than 200 L) and the proposed TCG spill procedures which will be in place at the site. A copy of the current spill procedures utilised at the TCG’s Otahuhu site is provided as Appendix C. The main hazardous substance that will be transferred external to the site buildings will be drummed TDI and MDI, moved by forklift and this scenario has been addressed in section 5.4.2 above.
In addition to the emergency procedures and engineered spill containment in the design, the facility has a third level of protection for preventing any spilled materials entering the site’s stormwater drainage system. This protection is that the stormwater drainage outlets (four in total) are fitted with shut-off valves which can be manually activated in the event of a spill, effectively closing off and isolating the areas where the spill occurred from the stormwater drainage system. It is understood that the shut-off valves will be electronic and solenoid actuated (slam shuts), with activation switches located throughout the facility. These shut-off valves would all be activated in the event of fire sprinkler activation.
The site’s TDI, MDI, polyol and CO2 bulk tanks will be filled by road tanker as required. There is a dedicated covered transfer area for TDI, MDI and polyol. Overfilling of bulk tanks will be prevented by the installation of high-level alarms and automatic trips. In addition, there are overflow lines between each of the TDI and MDI tanks located in the TDI/MDI tank bund, with a final overflow into the bulk tank TDI/MDI bulk tank bund located in the sealed TDI/MDI Store. In a worst-case incident where the bulk tanks’ level alarms fail, the material will flow into the TDI/MDI bulk tank bund in the sealed TDI/MDI Store and will be contained there.
The tanker trucks used for filling the storage tanks on site will be restricted to road tanker transfer areas (one for TDI, MDI and polyol and the other for CO2) with spill containment lips and dedicated drains and sumps (containing isolation valves). The tanker transfer area is designed so that should a transfer hose fail, the released material will be contained in the bunded area and will flow to a drain located at the rear of the transfer area. From the drain sump it will flow into the base of the bulk tank bund, thereby significantly reducing the potential for any spilled material to come in to contact with stormwater.
The Emergency Plan (see Appendix E) provides guidelines for management and remediation of spills, including the provision and use of spill kits, and will be updated as needed to reflect current good practice and to comply with the emergency management requirements of the Health and Safety at Work (Major Hazards Facilities) Regulations 2016 and Health and Safety at Work (Hazardous Substances) Regulations 2017.
Based on the mitigation discussed in this section the subsequent risk to the environment from hazardous materials is therefore considered in the main to be low. The likelihood of both a bulk tank and its containment bund suffering from a catastrophic failure simultaneously is extremely rare.
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5.4.4 Process Control Failures/Faults
Process control failures and process events at the foam blowing plant may result in the release of TDI/MDI and other contaminants to the environment. We have identified the following main fault failures which may occur with the foam manufacturing plant: ▪ Incorrect mixing of ingredients; ▪ Electrical supply failure; ▪ Foam blowing plant extract fan failure; and ▪ Hot block (excessive heat generated as result of the foam blowing reaction).
Incorrect mixing of ingredients All ingredients required for the foam blowing are metered into a mixing head at a ratio determined by a calculated formulation. The ingredients are mixed together at high speed and then deposited, via a specially designed dispensing unit, onto a paper covered conveyor system. The metering and mixing process is computer controlled so if ingredients flow vary outside of the calculated flow rate, alarms will activate and if no action is taken the foaming process will automatically shut down. The reaction time which TDI is released is around 1.5 minutes and it is estimated that the time for the plant to shutdown is around 5 minutes. During this time the foam plant extract system will be operating, and all TDI/MDI monomer vapour released as a result of the foam making reaction will be passed through the filter and discharged to air at the normal rates as covered in air quality assessment. The offsite effects as demonstrated by the air dispersion modelling undertaken will be negligible.
Electrical supply failure Electrical supply failure to the foam blowing plant will be mitigated at the Lumsden Road site by the installation of a stand-by diesel generator to automatically start if the site has a power failure. This will mean that if a power failure occurs during a foam blowing batch run the extract fan and the foam plant conveyor will continue to operate normally. The foam pouring will stop. Should the generator not fire then the foam blowing plant will shut down and there will be a release of TDI/MDI into the foam blowing plant. The levels of TDI/MDI will be monitored in the plant by fixed and portable monitors and if they approach workplace exposure standards the plant will be evacuated following the Foam Plant Evacuation Procedure.
Foam blowing plant extract fan failure Mechanical failure of the extract fan from the foam blowing plant is another potential fault failure mode. In order to prevent the fan failure, it is included as a high risk item in the TCG preventive maintenance program for this area as the fan extracts the vapour from the foam blowing process and pulls it through the filter before the treated air is discharged to atmosphere. This preventative maintenance program is utilised at the existing Otahuhu foam blowing plant and as far as TCG is aware there has not been to date any mechanical failure with the foam blowing plant’s extract fan. Should the extract fan fail the plant will be subject to an emergency shutdown. The emission of TDI/MDI from the reaction is over in approximately 1.5 minutes and the shutdown would probably take another two minutes. The majority of the TDI/MDI emission would therefore be completed in approximately 5 minutes. The TDI/MDI vapour from the extract fan failure would be contained in the foam manufacturing plant and the majority of that would slowly seep out of the foam plant enclosure. As with the electrical failure the levels of TDI/MDI will be monitored in the plant by fixed
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and portable monitors and if they approach workplace exposure standards the plant will be evacuated following the Foam Plant Evacuation Procedure. Monitoring of TDI/MDI using the mobile occupational health monitors would be instigated outside the foam blowing plant and at the boundary of the site to monitor levels in ambient air. If the monitoring indicates elevated exposure levels at the boundary above the NOEAL(HEC) of 0.002 mg/m3 evacuation of the surrounding should be considered.
Hot block A “hot block” of foam is an abnormal process event which needs to be managed and mitigated quickly. A “hot block” of foam is identified via the computer controlled system that monitors the block’s exothermic temperature via temperature probes whilst the block is in curing room. If the block temperature is found to be still rising after the block maximum temperature alarm has been activated (at 170oC) or the operators detect a ‘hot block’, the travellator will be utilised to remove the block and deliver it to an external ground level roller conveyor located on the south western corner of the building over which there is a piped cage arrangement with is fitted with water sprays. The block can then be cooled by operating these water sprays and by pushing water lances into the block by operators. TCG have developed a Standard Operating Procedure SH0040 (for removing “hot blocks” and quenching them (see Appendix D). All foam plant operators are trained in this procedure and APL/TCG will conduct regular hot block response drills to ensure that should a hot block situation eventuate they are trained and familiar with the steps they are required to take to remove a hot block from the foam block racking system. The Comfort Group Deer Park Site has operated for 10 years and has yet to have a production “hot block “ event. They produce three x 60 m long foam blocks per day, for around 40 weeks per year, which equates to around 6,000 blocks. The Technical Manger (former) with the Comfort Group advised that over 30 years of operating and being involved in foam blowing plants he only encountered one “hot block” incident. With the latest computer technology on modern foams plants the computer program will automatically shut the plant down if the flow rate moves to above or below set limits in regard to the reaction, thereby preventing a “hot block” incident. Based on the above information, the potential for a “hot block” is a rare event. Failure of the temperature monitoring probes and or operator checks to identify hot blocks would result in potential fire in the foam block racking room. If such an event occurred, it will be managed by the fire extinguishment systems installed at the site. The likelihood of a fire due to a “hot block” is extremely rare and this situation is prevented by the mitigation and monitoring measures implemented by the TCG at the Lumsden Road site to detect early the potential for a ‘hot block’ incident and to prevent the ‘hot block’ bursting into fire. Contaminated water run-off from the hot block treatment cage will be contained on site. The stormwater drains in the areas near the hot block treatment cage will be isolated by the activation of stormwater shut-off valves and the placement of portable spill protection socks etc.
5.4.5 Fire Events
Flammable liquids and combustible storage on site will be managed by compliance with TCG EMPs and associated procedures. Small quantities of paints, cleaning and degreasing agents (flammable substances) will be stored in dedicated hazardous substance stores or cabinets in accordance with standard AS 1940-2004 “The Storage and Handling of Flammable and Combustible Liquids”. The
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likelihood of fire from the hazardous substances is therefore classified as unlikely and the subsequent level of risk is low.
Diesel will be stored in a 1,500 litre tank in a 240/240/240 fire rated room along with the diesel fire pumps which are used to boost the water supply to the site’s fire sprinkler system.
In addition, the manufacturing facility will be in the main constructed of non-combustible material. The foam manufacturing building has been designed as a separate building from the rest of the facility with a fire rating of 120/120/120. Any fire in the foam manufacturing plant will be contained to just that building.
Damage to buildings, equipment or hazardous substance storage containers from fire could result in the release of toxic substances including partial pyrolysis from the combustion of polyurethane foam products to the environment, including potential releases to the atmosphere that could travel off- site. A comprehensive fire detection and suppression infrastructure as previously described in this report, will be provided at the facility to prevent damage from fires and for quick extinguishment. Other potential causes of fire, such as electrical, shall be minimised by proper design and construction of the facility.
In the actual event of a fire, fire detection and suppression measures will be in place to extinguish the fire before significant damage is done to the buildings, equipment, hazardous substances storage or personnel at the facility. The proposed fire protection and extinguishment system is described in Section 3.13.
In the event of electricity supply interruption to the site, the fire sprinkling system is powered by three diesel fire pumps with two operating and one on standby providing redundancy should one of the pumps fail. There is a bulk water supply tank on site holding 2.1 million litres which will supply water to quench the fire via the fire sprinkler system to enable the automated fire sprinklers to activate and provide 120 minutes of firefighting. This is in addition to the plants 150mm diameter water supply ring main which runs around the whole of the proposed facility. This ring main will be fitted with in- ground fire hydrants which can be utilised in the event of a fire.
The fire sprinkler system has five independent zones, and should a fire break out whilst one of the zones is offline for maintenance, the four remaining zones are available and will be activated to extinguish the fire. It should be noted that the sprinkler zones overlap, and any zone taken out for maintenance will be covered by the other remaining operational zones. As such, there will be no loss in sprinkler coverage.
The process fire extinguishment has a high degree of redundancy built into it. The design criteria that must be achieved, which in this case is for the received heat radiation at the neighbouring boundary 2 2 to be less than 30 kW/ m and not more than and 16 kW/m at 1m over the boundary. This heat must be evaluated using a 30 m length of the external wall of the building emitting at 144 kW/m2, which equates to a temperature of 992oC.”
The calculations show that the maximum heat at the boundary will be 14.06kW/m2 which is well below the less than 30 kW/m2 set by the Building Code, and obviously less than this at 1m further over the boundary.”
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Fire sprinkler systems have an extremely high reliability record in New Zealand.
Combustible material in the building will largely comprise of manufacturing materials with the most significant material being the manufactured polyurethane foam held as foam blocks or in manufactured mattresses and beds. Quick extinguishment of any fire at the facility will prevent the combustible material in the building from decomposing in the fire and releasing toxic fumes which would be contained in the smoke discharged with fire. In addition, the high intensity water sprays from the fire sprinklers will effectively scrub out any free isocyanate monomers released by the fire and decomposition compounds such free cyanide, thereby reducing/preventing the releases of these toxic properties from the site in a fire event.
It should be noted that the discharge rates of toxic products generated by a fire is difficult to quantify. Quick extinguishment will prevent these toxic products being discharged in any quantity that would have off-site consequence. If the fire is not extinguished quickly then TCG emergency response procedures for a factory fire should be activated and this would include advising the police/fire service to consider/implement the evacuation of people living in nearby houses and working in nearby factories downwind of the fire. The main cause of fire in industrial buildings is due to electrical faults. The likelihood of a fire in a modern well design facility with a fully functioning sprinkler and fire hydrant system that will require neighbouring properties to be excavated is an extremely rare event.
In the event of a fire and the activation of the sprinkler system the site has been so designed that all the fire water will drain to one catchment pond that can hold up to 2,300 m3 of fire water (see Appendix B). The catchment pond has been sized on the basis that the sprinklers will be deployed on a zonal basis and that full volume of water stored on the site for fire extinguishment will not be deployed as the fire is expected to be quickly extinguished. The four main stormwater outlets at the rear of the site are fitted with shut-off valves which in the event of the activation of the fire sprinkler system will be closed electronically to prevent fire water exiting the site. Fire at the Lumsden Road site which engulfs the whole building constructed from non-combustible materials is regarded as an unlikely event, and therefore the production of fire water from a fire which overwhelms the firewater containment system is expected to be a very rare event. 5.4.6 Vandalism and Deliberate Damage
This risk is mitigated by security measures normal for such a facility. The site will be surrounded by a security fence, and access controlled via a gatehouse and reception. During the day APL/TCG staff members work at the site and are able to provide an appropriate level of surveillance and security. At night the security fence will be locked, and parts of the site including offices and warehouse monitored by a security alarm system. The likelihood of deliberate damage to the site or vandalism is therefore regarded as being unlikely. 5.4.7 Natural Hazards Risk
Structures constructed at the proposed facility (tanks, secondary containment bunds, etc.) will be in accordance with the New Zealand Building Code and therefore resistant to damage from most seismic activity. The storage tanks and bunding around the storage tanks will be designed to be resistant to earthquake damage.
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A large earthquake could result in moderate consequences to the environment from release of stored hazardous substances. However, the probability of significant earthquake damage is considered very unlikely, and consequent risk is low given the earthquake zoning requirements for the Waikato region.
The revised modelling concluded that an unlikely breach of the stop bank at Ohinewai North Road under a Q100 year plus climate change event could occur. The modeling showed that the factory site will not be subject to any flooding under this event and therefore the level of risk posed in respect to flood waters mixing and reacting with TDI/MDI stored in bulk tanks and drums at the site is negligible.
5.5 Credible Major Accident Events
From the hazards identified in Section 5.3 pertaining to the bed and foam manufacturing process and an analysis of potential fault/failure events in Section 5.4, we have identified five credible MAEs that could result in offsite effects should they occur at the site. The MAEs were determined through the hazards identification and consequence analysis process conducted. For the majority of incident/accident events analysed the consequences of the event are able to be contained on site. The credible major accident events identified are: ▪ Overfilling of TDI/MDI bulk tanks; ▪ Failure of the extract fan during foam blowing resulting in vapour releases; ▪ Hot block; ▪ Extensive fire at plant; and ▪ Fire water including contaminants being released offsite.
5.6 Level of Risk
The following sections set out the environmental qualitative risk analysis conducted for the credible major accident events hazards identified in respect to the storage and use of hazardous substances during the operation of the Lumsden Road bed and foam manufacturing facility. The level of risk has been determined using the likelihood and consequence descriptors and the risk matrix set out in Appendix F. The assigned level of risk for the MAEs assessed which could result in offsite effects are presented in Table 5. The risk analysis has assessed the level of risk posed by the failure of the mitigation measures (plant design and procedures) applied by TCG in their operation of the plant that could result in a credible major accident event with offsite consequences.
48 Table 5 : Credible Major Accident Event Hazards Level of Risk
Risk Analysis MAE Hazard Event Cause Effect Mitigation Consequence Likelihood Risk
Failure of tank Installation of three levels of high level level alarms, and Release TDI/MDI alarms and automatic trips. Overflow tank to tank viscous liquid lines between each of the TDI and MDI overflow into the TDI/MDI tanks located in the bulk tank bund in Overfilling of bulk tank bund the TDI/MDI Store. TDI/MDI bulk tanks. in the sealed Tanks are situated in isolated TDI/MDI Failure of tank level 5 D Low TDI/MDI Store. Store which is sealed. alarms, and tank to Potential for All vapour released in TDI/MDI Store tank overflow released vapours can be extracted to the filter before impact to the being discharge to air. environment. SOP for transfer from road tanker to Toxic/Corrosive bulk tanks. properties Mechanical failure Mechanical Release of Preventative maintenance of fan. of fan and as a failure of fan and vapours into the Onsite emergency power generation. result vapours from as a result foam blowing Foam plant shutdown procedure foam plant are not vapours from plant area. including workplace and boundary drawn through foam plant are Fugitive release monitoring of TDI/MDI. filter not drawn of vapours from 4 E Low through filter the foam blowing plant to the atmosphere and potential effects offsite.
Fire at the site and Fire at the site Contaminated Site is contoured so all fire water will deployment of fire and deployment water as a result flow to rear of the site. sprinkler systems to of fire sprinkler of the fire is Ecotoxic Bunded area at the rear of the site with a 3 E Low extinguish the fire systems to released from capacity 2,300 m3 to contain firewater. resulting in extinguish the the site. . fire resulting in
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Risk Analysis MAE Hazard Event Cause Effect Mitigation Consequence Likelihood Risk contaminated fire contaminated Stormwater outlets are fitted with valves water fire water which can be closed off in the event of a fire. Valves are shut automatically in the event of a fire sprinkler activation. Other devices such as mats etc. are provided in spill kits to shut off other stormwater drainage outlets. Site emergency response procedures and regular training of staff in the procedures requirements.
Foam exothermic Foam If hot block Continuous temperature monitoring of reaction is beyond exothermic catches fire it blocks in curing area to detect any hot specification and reaction is could set off blocks early. results in a Hot beyond other blocks in Hot block procedure for managing a hot Block specification the curing barn block incident. and as a result Hot blocks removed from curing area decomposition and taken to external hot block vapours could treatment rack. be released to Process Water sprays fitted to hot block rack 4 D Low atmosphere. which are activated along with water lances to cool block. Deluge sprays will knock out any decomposition vapours as a result of the hot block. Fire detection system in curing barn. Curing barn sprinkler system will be activated.
Failure of fire Failure of fire Smoke, fire Fire detection systems Fire extinguishment extinguishment combustion 3 E Low systems to put products and
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Risk Analysis MAE Hazard Event Cause Effect Mitigation Consequence Likelihood Risk systems to put out out initial small decomposition Fire sprinkler systems installed to cover initial small fire fire products from five zones at the facility and provide 24- polyurethane hour protection. foams impacting Mandatory independent monthly testing on surrounding of sprinklers and two-yearly complete properties. re-survey. Diesel fire pumps and back-up fire pumps. Onsite water storage to supply sprinklers and hydrants (2.1 million litres). Buildings constructed of non- combustible material. Natural dispersion of the smoke plume. Fire and emergency procedures including evacuation.
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5.7 Conclusion of Qualitative Risk Assessment
The results of the QRA conducted demonstrates that the following conditions are met: ▪ screening and risk classification and prioritisation indicate there are no major off-site consequences and societal risk is negligible; and ▪ the necessary technical and management safeguards are well understood and readily implemented. As result of meeting these conditions, the determination of societal and individual risk is not required and the use of a qualitative risk assessment using qualitative descriptors is appropriate.
All MAEs as a result of the failure of the proposed mitigation controls which could result in offsite effects have been evaluated as having a low level of risk to human health and environment. The proposed mitigation measures detailed in the preceding sections are robust, of a good international industry practice standard and have a low likelihood of failure. In conclusion, the level of risk posed to the environment and human health resulting from the storage and use of hazardous substances at the facility on average is low. The mitigation, standard operating procedures, emergency response procedures and safety design measures that will be in place will limit the risk resulting from the storage and use of hazardous substances to as low as is reasonably practical.
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6. Mitigation and Monitoring
6.1 Emergency Plan and Procedures
An Emergency Plan will be prepared for the new facility in accordance with the requirements of Health and Safety at Work (Major Hazard Facilities) Regulations 2016. TCG has compiled a draft Emergency Plan (EP) based on the existing Otahuhu Plant operations, while accounting the specific requirements of the Ohinewai site. The preliminary EP will be updated as detailed design of the Ohinewai factory progresses. A copy of the EP is set out in Appendix C.
TCG will put in place a series of standard operating procedures (SOPs). A sample of those relating to spill incidents are listed in Table 6 and are presented in Appendix C.
Table 6 : Spillage SOPSs
SOP Title
SH 0001 TDI and other isocyanate spills SH 0002 Temporary repair of leaking drum
SH 0004 Containment of chemical spill
SH 0018 TDI/polyol spill register SH 0037 TDI Spill Crew drill The SOP SH 0004, Containment of Chemical Spill, provides instructions on the use of spill kits for spill containment and clean-up and the investigation of the spill incident and preventive action. 6.2 Process Safeguards Provided
A number of safety features will be installed at the site to minimise the potential for impact as a result of incidents or to manage or mitigate incident impacts that could result in offsite effects. These are summarised below. • Spillage Containment – all storage tanks and process areas will be constructed with spillage containment. Tank storages will comply with the spill containment requirements of the Health and Safety at Work (Hazardous Substances) Regulations 2017. Process areas will be designed, as a minimum, to contain spillage from the largest process vessel in the plant around which the bund is constructed. • Vapour Control and Treatment – The site has a filter that will receive extracted TDI/MDI vapours from the foam blowing plant, foam block curing area, and the bulk storage tank vault. The filter will remove 99.5% of the extracted TDI/MDI vapours before being discharged to air. In addition, the removal efficiency of the filter will be monitored on a regular basis. • Vapour Detection – Stationary TDI/MDI vapour detectors are located in the foam blowing building to monitor TDI/MDI levels in air. These units are supplemented by portable meters which can be taken to areas where there is a leak or a vapour release which may require monitoring. • Stormwater shut-off valves – the main stormwater outlets are fitted with automatically actuated shut-off valves which can be closed in the event of a fire or spillage to prevent contaminated material entering the stormwater drains. These values can also be operated manually if required. • Hot block sprinkler conveyor – A specially caged area where a block is conveyed to for rapid quenching using sprinkler heads fitted to the cage frame and manually inserted water lances in the block. The water run-off is contained from this area by the activation of the stormwater shut-off valves.
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6.3 Fire Protection Systems
• Fire Detection – the site will be provided with a fire detection system within the process plant areas and hazardous substances storage area. The fire detection system will be connected to a general alarm system as well as a dedicated area alarm that will notify plant operators of the incident location. • First Attack Fire Protection – fire extinguishers will be provided throughout the plant in accordance with the various Dangerous Goods storage standards and AS/NZS2444). Fire hose reels will be provided in accordance with the requirements of the various Australian Standards (e.g. AS/NZS1940) and AS/NZS2441. • Fire Main Sprinkler Systems – the site will be fitted with a fire main, installed in accordance with the requirements of AS/NZS 2419. The fire main will be fitted with hydrants, located throughout the site. In addition the plant will be fitted with a five zone automatic sprinkler system which is fitted with diesel fired boost pumps to increase delivery pressure • Fire Water Supply – fire water will be supplied from a fire water tank capable of supplying a minimum of two hours fire water by two fire pumps. A third pump is installed which will activate should one of the two main pumps fail.
6.4 Containment of Fire Water and Runoff
In the event that a fire does occur at the site, there will be a need to apply a fire extinguishing medium, such as water from fire hose reels or hoses, and those systems previously described to extinguish the fire.
Fire water will drain to a catchment pond with the capacity to hold 2,300 m3 of water. The fire water will be tested and removed for treatment.
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7. Conclusions and Recommendations
7.1 Conclusions
TCG’s design for the proposed facility incorporates a number of features to prevent the release of hazardous substances to the environment. They include:
◼ Dedicated storage areas for hazardous substances, which are bunded and separated from the rest of the factory
◼ TDI/MDI stored in bulk tanks and drums, located in a separate sealed room in the Hazardous Substances Store, which are ventilated to the filter system in the event of a spill or tank failure
◼ Five independent fire sprinklers zones which cover the whole facility, apart from the TDI/MDI Store .
3 ◼ A fire water storage pond (2300 m ) at the eastern end of the site to contain firewater and to prevent accidental discharge into the adjacent drain.
In addition to the above engineering controls APL/TCG have developed a series of Standard Operating Procedures for handling hazardous substances, tanker transfers, emergency shutdowns of the foam blowing plant and for dealing with spillages.
A Qualitative Risk Assessment was conducted for the proposed bed and foam manufacturing plant at Lumsden Road using the following steps: 1) Hazard Identification
2) Fault/Failure mode analysis
3) Likelihood analysis of the fault/failure mode/release
4) Off-site consequence analysis of the accident event
5) Qualitative determination of risk.
A hazard identification process was conducted for the site facilities and operations. For each hazard a number of fault/failure modes were identified. Incidents that could have a potential off-site effect were identified. Each postulated hazardous incident where a potential offsite effect was identified was assessed semi-quantitatively to determine the level of site effect. Where the qualitative and semi-quantification analysis determined that the safeguard proposed (engineering controls and SOPs) were adequate to control/mitigate the hazard, or that the consequence would obviously have no offsite effect, no further analysis was performed. All MAEs identified from the hazard identification and analysis process were then subjected to qualitative analysis based on the descriptors and risk matrix.
A total of five credible MAEs that could result in offsite effects should they occur at the site were identified by the QRA process. For the majority of incident/accident events analysed, the consequences of the event are able to be contained on site and as such the process was stopped at that point for these hazards. The credible MAEs identified are:
◼ Overfilling of TDI/MDI bulk tanks;
◼ Failure of the extract fan during foam blowing resulting in vapour releases;
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◼ Hot block;
◼ Extensive fire at plant; and
◼ Fire water including contaminants being released offsite.
These MAEs were run through the risk analysis matrix where the qualitative descriptors were used to determine the likelihood of an event occurring and consequence of that event in terms of off-site effects. All MAEs which could result in offsite effects have been evaluated as having a low level of risk to human health and environment, providing that the mitigation measures detailed in the preceding sections are followed. In conclusion, the level of risk posed to the environment and human health resulting from the storage and use of hazardous substances at the facility on average is low. The mitigation, standard operating procedures, emergency response procedures and safety design measures that will be in place will limit the risk resulting from the storage and use of hazardous substances to as low as is reasonably practical.
7.2 Recommendations
The following recommendations based on the QRA are made for implementation by TCG. 1) The Standard Operating Procedures for managing chemical spills including TDI are implemented at the site and are regularly tested to ensure staff are aware of the contents of the procedure and to check that they are still current. If the SOP tested is found to be deficient it should be amended. 2) The Standard Operating Procedure for managing a hot block incident should be implemented at the site and the SOP tested once every six months so that staff are familiar with the requirements of the SOP and how to manage a hot block situation, given that a hot block event occurs on an infrequent basis. 3) That removal efficiency of carbon filter is tested on regular basis in order to ensure that the carbon filter is operating as per its specifications.
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Appendix A. Hazardous Substances Store Schematic and Site Layout
IZ052900-NEM-RT-002 57 RESOURCE CONSENT A DISCUSSION NC 16 03 2020 B DISCUSSION NC 02 06 2020
C1 C2 Canopy over Stormwater strip drain ARC116 Stormwater drainage line Seperation 50mm Roll Stormwater drainage Stormwater strip ARC116 Canopy over Issue: Rev: Initial: Date: & sump refer civil refer civil engineers between bunded over mound line refer civil drain & sump refer engineers details details areas engineers details civil engineers details CANOPY OVER
Stormwater strip drain & sump. With shut off valve for chemical unloading refer civil engineers details
Shut off valve during chemical POLYOL AND unloading. To switch from OTHER stormwater line to spill line. ISOCYANATE Refer civil engineers details CHEMICAL UNLOAD BUND UNLOAD BUND TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum Spill drainage RAMP RAMP TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum line to bunded TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum area. Refer drainage TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum 35K L 35K L engineers 25K 25K 25K 3595 TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum V4001 HR TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum V4001 HR 3595 details 6000 mw (ISO tanker) (ISO tanker) (ISO tanker) (ISO tanker) TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum AC TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum 12K 35K L 35K L TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum 25K 25K 3595 LR 3150 ( visco) HL431 TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum
TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum Spill drainage (ISO tanker) BLEND SPARE Drum or IBC CO2 line to bunded TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum TDI drum area. Refer civil engineers SUMP FOR SPILL PUMP details AC DN 8K 25K 35K L 35K L 15K kgs 15K kgs VE 1100 25K Coploymer MDI MDI PIPI CP1421 3140 (visco) (LR00) (ISO Tanker) Non CO2 (Drums) ISO tankers (ISO Tanker) H frame crane
Slope floor to bunded AC area TDI 25K kgs TDI 25K kgs
Built up steel plate floor to Slope concrete help retain fumes from floor to sump from spill in bunded area.
1 TANK FARM PLAN - 1:125 @ A1
EXTERNAL BUND STORAGE EXTERNAL BUND STORAGE ZONE 3 ZONE 3 ZONE 3A ZONE 3A Area = 86 m² Area = 118 m² Bund Area = 86 m² Bund Area = 118 m² Height Bund = Say 10 m² / 86m² = 116 mm Bund Height = 150mm Height Bund = 22 m³ / 118m² = 186 mm Bund Height = 200 mm Note: bund is not required as spill area will be piped to internal bund BALEMI ROAD
C1 - ZONE 2A BUND STORAGE Area = 274 m² ZONE 2A & 2B ISOCYANATE ZONE 1 C2 Area = 594 m² - Largest bulk tank weight = 25 Tonne Volume = 20,492 Litres BUND STORAGE WT Plus 10% = 2,049 Litres 22,541 Litres ZONE 1 POLYOL 1 LUMSDEN ROAD Drum Stock Largest Tank Volume = 35,000 Litres TDI = 32,800 Litres plus 10% = 3,500 Litres MDI = 16,400 Litres 38,500 Litres 49,200 Litres x 50% = 24,600 Litres Drum Stock = 40,000 Litres x 50% = 20,000 Litres ZONE 2B Total Spill Litres = 47,141 Litres Area = 75 m² Total Spill Litres = 58,500 Litres Bund Area = 75m² Bund area = 594m² Height Bund = 47.141m³ / 75m² = 628.5 mm Bund Height = 650MM Height of Bund = 58.5m³ / 594m² = 98.5 mm Bund Height = 150 mm
2 STORAGE PLAN BUND ZONES 00 KEY PLAN - NTS @ A1 - NTS @ A1
These drawings and CAD files remain the Project: Drawing Title: Project No.: Scale (A1 Orginal): Sheet No: property of Gaze Commercial Limited and TANK FARM PLAN & BUNDING should not be copied in any form or passed SLEEPYHEAD FOAM & J19-0288 OR AS 1:125 @ A1 ARC 115 onto any third party with prior written consent. BEDDING FACTORY AREAS SHOWN 1:250 @ A3 88 LUMSDEN RD Do not scale dimensions from drawings. Check OHINEWAI Drawn: NC Approved by: all dimensions, clearances and access sizes on NEW ZEALAND Rev No: commercial site before commencing any construction. Date: 29.09.2019 Issued by: Sm art Proper ty So utions B
J:\J19-0288 Sleepyhead Ohinewai\Design\Drawings\5.4 RC design FINAL\J19-0288 ARC 115 -116 FOR JACOBS.dwg RESOURCE B B A CONSENT A DISCUSSION NC 16 03 2020 6000 B DISCUSSION NC 02 06 2020 4.0°
Issue: Rev: Initial: Date:
4.0°
EXTRACT TO CARBON FLITER
Future high level BUILT UP REMOVABLE SLOPE FLOOR unloading for ISO tanks STEEL PLATE FLOOR TO TOWARDS THE HELP RETAIN FUMES BUNDED AREA FOAM FROM FROM SPILL IN DRIVE OVER BUND HUMP 11100 PLANT BUNDED AREA. TDI & MDI TDI TANK TANK FARM 8550 25,000 Kg TDI DELIVERS 20,492 Litres -44 GALLON MDI TANK 6000 DRUMS ON 15,000 Kg PALLETS 5500 TDI DELIVERS 160 x MDI DELIVERS 80 x 205 Litre DRUMS ON 207 litre DRUMS ON PALLETS PALLETS 4250
9650 650
BUND STORAGE ZONE 2A & 2B ISOCYANATE Largest bulk tank weight = 25 Tonne Volume = 20,492 Litres SUMP FOR TDI SPILL PUMP 100 mm DIA BY PASS DRAIN TO STORMWATER STRIP DRAINAGE BUNDED STORMWATER EXTERNAL Plus 10% = 2,049 Litres DISCHARGE TO TDI BUNDED DRAIN, TWIN SUMPS AND AREA = 14.3M³ STRIP DRAIN & CONCRETE PAVING 22,541 Litres ENCLOSURE WHEN UNLOADING GATE VALVE. TO BE REFER CIVIL SUMP REFER REFER CIVIL Drum Stock TDI. TURNED TO BY PASS SW ENGINEERS CIVIL ENGINEERS ENGINEERS TDI = 32,800 Litres REFER CIVIL ENGINEERS DETAILS DRAIN TO DISCHARGE TO DETAILS DETAILS DETAILS MDI = 16,400 Litres BUNDED ENCLOSURE 49,200 Litres x 50% = 24,600 Litres WHEN UNLOADING TDI. Total Spill Litres = 47,141 Litres REFER CIVIL ENGINEERS C1 C1 TANK FARM CROSS SECTION Bund Area = 75m² DETAILS - ARC115 1:75 @ A1 Height Bund = 47.141m³ / 75m² = 628.5 mm Bund Height = 650MM B A B 6000 4.0°
4.0°
EXTRACT TO CARBON FLITER POLYOL TANK FARM
FOAM DRIVE OVER BUND HUMP 11100 PLANT POLYOL DELIVERS TANK TANK TANK -ISO TANKER AT LOW 35,000 LITRES 35,000 LITRES 35,000 LITRES LEVEL & DRUMS ON PALLETS
BALEMI ROAD 6000 5500
C1 -
C2 9650 - 9500 WT 1 LUMSDEN ROAD
BUND STORAGE ZONE 1 POLYOL Largest tank volume = 35,000 litres SUMP FOR SPILL PUMP 150 LOWER FLOOR CHEMICAL DELIVERS STORMWATER STRIP DRAINAGE BUNDED STORMWATER EXTERNAL plus 10% = 3,500 litres TO ACT AS BUND IN DRUMS ON DRAIN, TWIN SUMPS AND AREA = 14.3M³ STRIP DRAIN & CONCRETE PAVING 38,500 litres FOR SPILL PALLETS GATE VALVE. TO BE REFER CIVIL SUMP REFER REFER CIVIL Drum stock = 40,000 litres x 50% = 20,000 litres CATCHMENT TURNED TO BY PASS SW ENGINEERS CIVIL ENGINEERS ENGINEERS Total litres = 58,500 litres DRAIN TO DISCHARGE TO DETAILS DETAILS DETAILS Bund area = 594m² BUNDED ENCLOSURE Height of Bund: 58.5m³ / 594m² = 98.5 mm Bund Height = 150 mm 00 KEY PLAN WHEN UNLOADING TDI. - NTS @ A1 C2 C2 TANK FARM CROSS SECTION REFER CIVIL ENGINEERS - ARC115 1:75 @ A1 DETAILS These drawings and CAD files remain the Project: Drawing Title: Project No.: Scale (A1 Orginal): Sheet No: property of Gaze Commercial Limited and TANK FARM CROSS SECTIONS should not be copied in any form or passed SLEEPYHEAD FOAM & J19-0288 OR AS 1:75 @ A1 ARC 116 onto any third party with prior written consent. BEDDING FACTORY C1, C2 & BUNDING AREAS SHOWN 1:150 @ A3 88 LUMSDEN RD Do not scale dimensions from drawings. Check OHINEWAI Drawn: Approved by: LTS 3 all dimensions, clearances and access sizes on NEW ZEALAND Rev No: commercial site before commencing any construction. Date: Issued by: Sm art Proper ty So utions J19-0288 ARC 115 -116 FOR JACOBS B
J:\J19-0288 Sleepyhead Ohinewai\Design\Drawings\5.4 RC design FINAL\J19-0288 ARC 115 -116 FOR JACOBS.dwg BOUNDARY 730
628 107000 155000
future rail line 150m 14000 52882 34000 28 7300
AC
AC
AC FFL 9.650 FFL 9.650 FFL 9.850
FFL 9.750
FFL 9.750
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Ohinewai Foam Factory Hazardous Substances Assessment
Appendix B. Sprinkler/Fire Run-off Catchment Plan
IZ052900-NEM-RT-002 58 BALEMI RD BOUNDARY RESOURCE CONSENT
STORM - RC APPLICATION NC 20.05.20 WATER PONDS & WETLANDS Issue: Rev: Initial: Date:
Legend Sprinkler Outflow
Direction of sprinkler flow run off to exit @ all door threshold slot drains SPRINKLER WATER FLOW TO DOORWAYS AND CAPTURED AT Sprinkler drainage DOORWAY THRESHOLD STRIP DRAINS. PIPED TO HOLDING Sprinkler outflow retention STORAGE POND pond
NON SPRINKLED AREA EXTERNAL CHEMICAL UNLOADING. RECESSED BUNDED AREA WITH SHUT OFF VALVE TO STORMWATER WHEN UNLOADING TO ALLOW FOR SPILL REDIRECTION TO INTERNAL BUNDED AREA. REFER TO PROCEDURE MANUAL
28
REBOND AC LAB AC TANK FARM
AC LUMSDEN RD LUMSDEN FOAM STORE FOAM PLANT
BEAN PLANT
FOAM CONVERSION
CATCHMENT POND 2300m³
EXTERNAL SPRINKLER WATER OUTFLOW STORAGE. RECESSED BUNDED AREA WITH SHUT OFF VALVE TO STORMWATER WHEN SRRINKLERS TRIGGERED TO 24 ALLOW FOR WATER TO BE RETAINED & TREATED AS REQUIRED. REFER TO PROCEDURE MANUAL
SPRINKLER WATER POND 1 BALEMI ROAD STAGE 1 -
1 4 2 5 3 LUMSDEN ROAD
1 SITE PLAN SPRINKLER OUTFLOW 00 KEY PLAN - 1:750 @ A1 1:2500 @ A3 - NTS
These drawings and CAD files remain the Project: Drawing Title: Project No.: Scale (A1 Orginal): Sheet No: property of Gaze Commercial Limited and should not be copied in any form or passed SLEEPYHEAD FOAM & SITE PLAN J19-0288 1: 750 @ A1 ARC 113 onto any third party with prior written consent. BEDDING FACTORY SPINKLER OUTFLOW 1: 1500 @ A3 88 LUMSDEN RD Do not scale dimensions from drawings. Check OHINEWAI Drawn: Approved by: all dimensions, clearances and access sizes on NEW ZEALAND Rev No: commercial site before commencing any construction. Date: Issued by: Sm art Proper ty So utions A
J:\J19-0288 Sleepyhead Ohinewai\Design\Drawings\5.4 RC design FINAL\_J19-0288 ARC XREF-01 SITE PLAN 101-111.dwg
Ohinewai Foam Factory Hazardous Substances Assessment
Appendix C. Emergency Plan and SOPs for Managing Spillages
IZ052900-NEM-RT-002 59
Emergency Plan Doc SHO 001 June 2020
Draft # 6 - 10.06.20 THIS DOCUMENT IS IN THE PROCESS OF BEING PREPARED FOR STAGE 1 AND 2 OF THE OHINEWAI FOAM FACTORY. IT IS BASED ON THE EMP FOR THE OPERATIONAL OTAHUHU SITE AND PRESENTLY IS BEING TREATED AS A PRELIMINARY DRAFT AND LIVE DOCUMENT. IT WILL CONTINUE TO BE UPDATED AS DATA BECOMES AVAILABLE.
NZ Comfort Group Ltd
Ohinewai Site 88 Lumsden Road Ohinewai
Emergency Plan
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Emergency Plan Doc SHO 001 June 2020
TABLE OF CONTENTS OVERVIEW ...... 5 1. Emergency Plan Aim ...... 5 2. Emergency Plan Objectives...... 5 3. Introduction ...... 5 SITE INFORMATION ...... 6 4. Location...... 6 5. Personnel & Operating Hours ...... 6 6. Surrounding Area ...... 6 7. Activities of Adjacent Premises ...... 6 8. Site Hazards ...... 7 9. Manufacturing Processes ...... 9 10. Site Storage ...... 10 11. Chemical Bunding ...... 10 12. Utilities On Site ...... 10 EMERGENCY MANAGEMENT & RESPONSE ...... 11 13. Types of Emergency...... 11 14. Levels of Emergency ...... 11 15. Incident Control ...... 11 16. Internal Incident & Emergency Teams ...... 12 17. External Emergency Response Teams...... 14 EMERGENCY EVACUATIONS ...... 15 18. Evacuation Overview ...... 15 19. Assembly Points ...... 15 20. Emergency Monitoring & Alarm Systems...... 15 21. Evacuation Plan Procedure ...... 16 FIRE EMERGENCIES ...... 17 22. Equipment ...... 17 23. Suggested Response for Large Foam Fire ...... 18 24. Fire Prevention & Control Methods ...... 18 25. Fire Emergency Environment Impact ...... 18 CHEMICALS...... 19 26. Overview ...... 19 27. Chemical Properties ...... 19 28. Hazchem Codes & Safety Data Sheets ...... 20 29. Chemical Locations ...... 20 30. Hazardous Chemical Spills Scenarios ...... 20 31. Hazard Zones ...... 20 32. Exposure Standards ...... 20 NZ Comfort Group Ltd Ohinewai Site Page 2 of 40
Emergency Plan Doc SHO 001 June 2020
33. Chemical Emergency Environmental Impact ...... 21 Emergency Planning Assumptions ...... 22 34. Fire Emergency Assumptions ...... 22 Draft - to be updated when long block store designs are completed...... 22 35. Hazardous Substance Emergency Assumptions ...... 22 MINOR HAZARDOUS SUBSTANCE EMERGENCY...... 23 36. Minor Hazardous Substance Spill ...... 23 37. Minor Hazardous Substance Spill Plan ...... 23 MAJOR HAZARDOUS SUBSTANCE EMERGENCY ...... 24 38. Major Hazardous Chemical Spill ...... 24 39. Major Hazardous Substance Spill Plan ...... 24 LPG OR FLAMMABLE GAS EMERGENCY ...... 25 40. Gas Leak ...... 25 NATURAL DISASTER EMERGENCY ...... 26 41. Overview ...... 26 42. Earthquake ...... 26 43. Flooding ...... 27 TERROR THREAT EMERGENCY ...... 28 44. Bomb Threat ...... 28 45. Suspicious Item or Package ...... 28 EMERGENCY RESPONSE TRAINING ...... 29 46. Spill Response Team ...... 29 47. Medical Response Team ...... 29 48. Emergency Evacuation Team ...... 29 49. Fire Suppression Response ...... 29 MAINTENANCE & TESTING OF EMERGENCY PLAN & SYSTEMS ...... 30 50. Control Panel ...... 30 51. Alarm System ...... 30 52. Fire Extinguishers & Hoses ...... 30 53. Self-Contained Breathing Apparatus ...... 30 54. Sprinkler System ...... 30 55. Automatic Doors ...... 30 56. Drainage System ...... 30 APPENDIX 1...... 31 57. TDI Tank Safety System ...... 31 APPENDIX 2...... 32 58. Incident Control Team ...... 32 59. Spill Response Team ...... 32 APPENDIX 3...... 33 NZ Comfort Group Ltd Ohinewai Site Page 3 of 40
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60. External Emergency Response Contacts (some data yet to be confirmed) ...... 33 APPENDIX 4...... 34 61. Neighbouring Business Emergency Contacts (To be updated when info is available) ...... 34 APPENDIX 5...... 35 62. Hazardous Zone ...... 35 APPENDIX 6...... 36 63. Bulk Chemical and Foam Block Storage...... 36 APPENDIX 7...... 38 64. Ohinewai Site Layout...... 38 APPENDIX 8...... 39 65. Drainage Cess Pit Locations ...... 39 APPENDIX 9...... 40 66. Stop bank breach - flood extents ...... 40
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OVERVIEW
1. Emergency Plan Aim This Emergency Plan (EP) is a formal documented system for the management and response to emergencies which may arise due to events which occur either on-site or off-site that have the potential to impact the safe and normal operation of our business which is a lower tier registered Major Hazard Facility (MHF). 2. Emergency Plan Objectives The objectives of the EP are to: • Enable the business to develop, review and maintain a high level of preparedness; and • Support timely, efficient and appropriate responses to major incidents and minimise or limit the impacts of an emergency; and • Ensure effective management of an emergency until external emergency services response teams arrive and take control of the site; and • Provide relevant information, knowledge and skills for both internal and external (emergency services) response teams; and • Protect emergency response teams, workers and the community from harm. 3. Introduction This EP has been prepared to meet the requirements of; the Health and Safety at Work (Major Hazard Facilities) Regulations 2016 (the MHF Regulations) as well as the Health and Safety at Work (Hazardous Substances) Regulations 2017 which requires a completed hazardous substance EP. The EP has been prepared in general accordance with HSNO COP 36 and in consultation with the Risk Management Team and relevant internal stakeholders. The EP includes potential emergency scenarios and response procedures, information and controls on hazardous substances to be stored on site, a plan showing the layout of the site and hazardous substance storage locations and emergency response equipment, site emergency contacts and responsibilities, procedures for notification of potentially affected neighbours and for testing and review of the EP.
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SITE INFORMATION
4. Location 88 Lumsden Road, Ohinewai, Waikato
A site layout plan is included in Appendix 7 5. Personnel & Operating Hours The manufacturing plant typically operates Monday to Friday from 06:00 (6am) till 15:00 (3pm) with occasional overtime on week days and/or Saturday mornings. Typical numbers of staff on site during a working week day, would be 50 people (Foam Plant)– approximate split between factory and office workers. 6. Surrounding Area The site fronts onto both Balemi Road and Lumsden Road in Ohinewai and is located a Rural zone under the Waikato District Plan. The immediate surrounding land is a mix of Rural and Village zone. There are residential and rural-residential properties adjacent to the site with the nearest residential properties located over 100 metres to the West of the main hazardous chemical storage areas on the site. The Factory site is part of a wider mixed-use development planned by NZCG that includes additional Industrial land uses, business/commercial and residential. The mixed-use development is subject to a structure plan and rezoning process that is underway with the Waikato District Council. 7. Activities of Adjacent Premises
Geographic Location Descriptions
Northern Boundary (Balemi Road) Rural land
Eastern Boundary Existing rural land Proposed: Open space and Residential Existing: Rural residential “lifestyle blocks. Southern Boundary Proposed: Industrial businesses
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Western Boundary (Lumsden Road) Residential properties before Rail lines and State Highway 1 8. Site Hazards
HAZARD TYPE SPECIFIC HAZARD HAZARD QUANTITIES HAZARD PROPERTIES
Chemical Toluene Di-isocyanate STAGE 1 TDI is a Liquid which is clear / (TDI) colourless in appearance and has a Bulk Storage Tank = pungent odour. 25,000 Kilograms TDI volatilises when exposed to air, and can result in a hazardous vapour to form. As TDI has a freezing Drums Total = 40,000 temperature of 14°C and a melting Kilograms temperature of 22°C. the potential for Drums Each = 250 TDI vapours varies through the year, Kilograms depending on the ambient temperature. Average temperatures in Auckland exceed 22°C only during the Maximum storage for summer months of January to March, stage 1 with average temperatures over the remainder of the year 14°C to 20°C. 65,000 Kilograms Refer to Safety Data Sheets stored digitally within ChemAlert with hard copies in the foam plant office and available at the Fire Panel.
Chemical Methylene Chloride 500 Litres (2 drums) Methylene Chloride is a liquid which is (MeCl2) clear/colourless and has a sweet odour. Methylene chloride is highly volatile and has a boiling point of 39.6. Therefore, a spill of methylene chloride would result in vapours even during winter. Refer to Safety Data Sheets stored digitally within ChemAlert with hard copies in the foam plant office and available at the Fire Panel.
Chemical Methyl Diphenyl STAGE 1 MDI is a light-yellow coloured, Diisocyanate (MDI) odourless liquid. Bulk Storage Tanks = Flashpoint of 200oC. 15,000 Litres Refer to Safety Data Sheets stored Drums Total = 20,000 digitally within ChemAlert with hard Kilograms copies in the foam plant office and Drums Each = 250 available at the Fire Panel.
Maximum storage for stage 1 35,000 Kilograms
Chemical Polyols Various 385,000 Litres Polyol is a white, viscous liquid that is almost odourless. Polyol has a boiling point of 200-320oC and a flash point of 110-260oC. Refer to Safety Data Sheets stored digitally within ChemAlert with hard
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copies in the Foam Plant Office and available at the Fire Panel.
Chemical Amine Catalysts 1200 Litres (total) Flammable liquids Low hazard, Toxic via inhalation, oral (Multiple products) and dermal.
Flammable Liquids LPG Total Volume = 350 LPG is a colourless gas with an Kilograms unpleasant odour (strong odour like rotten eggs or cabbage). LPG is an extremely flammable gas. LPG has freezing temperature -81oC, Auto ignition at 468oC. LPG may cause frostbite, tissue damage and blistering to exposed skin.
Compressed Gas Carbon Dioxide (CO2) 6,000 Kilograms Carbon Dioxide is a colourless odourless gas. Exposure to gas under pressure may cause frostbite, tissue damage and cause breathing difficulties in confined spaces. No ecological damage caused by this product
Foam Polyurethane Foam Maximum within Foam Foam is extremely flammable. Block Store Toxic gases are given off when Polyurethane Foam burns. 120 x 40m Foam Blocks Specifically: • Carbon monoxide, a colourless odourless gas • Hydrogen Cyanide, a colourless gas that may give off a bitter almond odour
Mains Supply Gas (To Natural Gas Unlimited – mains Natural gas is colourless and tasteless be confirmed) supplied. and may have no odour. If a sulphur compound has been added its odour will be of garlic or rotten eggs. Flash Point of 187C Stable under normal temperatures and pressure. Toxic if inhaled causing a range of issues including; difficulty breathing and altered or loss of conscious.
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Emergency Plan Doc SHO 001 June 2020
9. Manufacturing Processes Plant Type and Function At this site we manufacture: • Flexible polyurethane foam • Carpet underlay • Components used in the manufacture of beds • Beds of various construction Foam Manufacturing The manufacture of the polyurethane foam involves mixing together an isocyanate with a polyol, a catalyst and a blowing agent to expand the foam. Other chemicals are also added to provide colour and fire-resistant properties. The volume and hazards associated with the other hazardous substances are much lower than TDI / MDI and methylene chloride. Chemicals are pumped from storage tanks to a Hennecke foam manufacturing plant. The foam is produced in a continuous length and is cut into 40 metre blocks and allowed to cure for around 20 hours After curing the blocks are moved to cold block storage. They may also be peeled or cut to required lengths and delivered to either outside customers or transferred to the bedding operation. Underlay Manufacturing Carpet underlay is manufactured by moulding chipped trim foam and prepolymer bonding agent into a cylinder block. These blocks are then peeled and a polyethylene film is bonded to one side. The finished product is rolled, packaged and stored ready to despatch. The underlay process involves mixing small pieces of foam off-cuts together with a small quantity of a solution made with polyol and TDI (approximately 20%TDI) and pressing the mixture into a mould. The mixture is then heated with steam which causes the TDI to react with the polyol and steam to set the material in to a bound form. The only hazardous substance used in the underlay manufacture is the solution of polyol and TDI. This is prepared on site in the hazardous goods storage area. Underlay manufacture is carried out in the factory, and does not involve any significant volumes of hazardous substances and therefore is not a source of potential environmentally hazardous substances that could result in discharge to land or water from this site. Bed Manufacturing All components are feed onto assembly lines and then various types of bed units are assembled. The completed bed units are packaged in plastic or cardboard and moved to the dispatch warehouse area. Bed Component Manufacturing Spring units are manufactured from coiled wire to produce either pocket spring or continuous coil spring inners. Timber frames are manufactured from timber stock, some of these bases include drawer units. Multiple grades of polyurethane and latex foams are processed into various shapes and sizes used for the box edging or main internal component for mattresses. Via cutting, quilting, sewing and laminating together of various fabrics, fibres and foams the comfort layers and outer covering for beds are manufactured.
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10. Site Storage The T.D.I. drum storage and decanting areas are bunded to ensure containment of uncontrolled releases of product (spills). Any chemical spill in the container devanning area is contained by the sloping concrete pad and isolation valves on all storm water outlets located on the concrete pad. The site is flat with very little slope apart from the bunded unload areas. Foam Block Storage Foam blocks are stored in a special self-containable building located in the west of the site (Building 2). A site plan is included in Appendix 7. The long block handling system will be confirmed at the design stage. Chemical Storage The storage for major chemicals for foam manufacturing is located in bunded areas in the tank farm within Building 1 as outlined in Appendix 6. The storage for major chemicals for underlay manufacturing is located in bunded areas in Building 4. This is still to be designed. Minor liquids are stored in their delivered containers (200 litres drum or small units) in specially design racking located in bunded areas. LPG Storage To be confirmed. 11. Chemical Bunding T.D.I. Bulk Store A bund wall 0.6 metres with volume 54,813 litres capable of containing the full capacity of the largest bulk storage tank plus 10% by volume, or in case where TDI is delivered in 20 tonnes Isotainers. Polyol Bulk Store There are thirteen (13) bulk polyol tanks with a total storage capacity of 385,000 litres. The containment bund volume for this area is 94,000 litres. The largest tank being 35,000 litres. Underlay Chemical Store Layout of this area is yet to be confirmed Chemical Site Delivery Area This area is where the site receives deliveries of Polyol ISO via Tankers and TDI via palletised drums. The area is sloping concreted pad with shutoff valves on all storm water outlets. Details of bund area is included in Appendix 6 12. Utilities On Site This site has the following utilities, these are clearly marked and identified on the site map. Refer Appendix 7
Gas Main Main Power Sprinkler Fire Water Stop Valve Hydrants Mains
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EMERGENCY MANAGEMENT & RESPONSE
13. Types of Emergency As an MHF we have identified there are several major hazards we have on-site that create the risk of a potentially significant incident which could result in an Emergency. We have grouped these into two main categories being Fire and Chemical. Comprehensive BowTie risk assessments have been conducted on these two categories and these RA’s form the basis of our emergency plan relating to “on site” emergencies. There are a number of other hazards that could create the risk of a potentially significant incident which could result in an Emergency, that are covered in our Emergency Plan; specifically, Natural Disaster Emergencies (e.g. flood or earthquake), LPG Leaks and Medical Emergencies (e.g. a serious harm safety incident).
14. Levels of Emergency
Level Description Emergency Response
Moderate: An uncontrolled release of hazardous Immediate area evacuation if substance no greater than 200 litres. required and follow plan set out in Minor Chemical Emergency Section 29.
High: An uncontrolled release of hazardous Full Emergency Evacuation, substance of 200 litres or more. contact Emergency Services and Major Chemical Emergency follow plan set out in Section 31.
Moderate to High: A spot fire able to be container by fire Immediate area evacuation if extinguisher or hose. required and follow instructions in General Fire Section 21.
High: A fire in the Foam Block store Full Emergency Evacuation, contact containing 14+ 35-metre-long blocks of Emergency Services and follow plan Foam Block Store Fire Foam. set out in Section 31.
15. Incident Control Control Centre The control centre is where the Chief Warden and the Incident Control Team (ICT) will assemble and remain during an emergency. Authority During an emergency, authority for controlling the incident will initially be the Incident Control Team until such time as external emergency services response teams arrive onsite and appoint an incident chief / commander. During an emergency the ICT has the power to override normal business management. Where a widespread state of emergency has been declared (such as a civil defence emergency) an Emergency Control Organisation (ECO) has the power to override all normal non-emergency management procedures. This however must still be conducted in the safest possible manner and only resets with the emergency Chief Warden, area warden or chemical response team leader. All other personnel will take instruction from these people. Access Internal roads on site must be kept clear of obstructions at all times, to allow access to emergency service vehicles.
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16. Internal Incident & Emergency Teams The site has key teams of staff who are trained to respond to a range of incident and emergency situations. Contact details for the Emergency Response Team members are displayed on posters around the factory. A list is also available at the control centre and also in Appendix 2 of this document. Incident Control Team The ICT will consist of any or all of the following people: Chief Warden, Spill Response Team Leader, Senior First Aider and the most senior manager onsite (it may also include the Site / National Operations Manager, National Safety Manager or People & Culture Manager). Duties • Control Evacuation • Contact and communicate with emergency services • Contact other external emergency services if require e.g. Power, Gas etc. • Contact neighbouring sites if necessary • Evaluate severity of incident • Communicate and provide incident updates with company superiors if required • Communicate with personnel • Direct clean-up operations Spill Response Team The site also has a chemical response team made up of staff trained to respond to a chemical spill. The spill response team members are displayed on Posters around the factory. A list is also available at the control centre and also in Appendix 2 of this document. During an emergency, these people are identifiable as they will be wearing self-contained breathing apparatus and special splash proof overalls. Duties • Identify substance and volume of spill • Contain spill • Assist emergency services if required • Clean up and dispose of material Medical Response Team – First Aiders In a medical emergency, trained and certified first aiders are the team who respond to the incident. A list of current First Aid Certificate holders is on display on the sites notice boards. During an emergency First Aiders are identifiable as they are wearing green hard hats with the words “First Aid” emblazoned in white across the front. Duties • Retrieve first aid kit (If safe to do so) • Attend to injured • Where possible evacuate the patient to a safe area. • Report to emergency Chief Warden • Arrange for emergency vehicles if required If you cannot assist the patient in their current condition / location leave them for emergency services. If this is the case have all relevant information prepared for the emergency services so they can make a fast assessment of the situation.
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Emergency Evacuation Team – Fire Wardens A list of current Emergency Wardens is on display on the sites notice boards. During an emergency or fire the Wardens are identifiable by wearing orange Hi-Viz vests with the words “Fire Warden” emblazoned on the back. During an emergency or fire the Chief Warden is identifiable by wearing a yellow Hi-Viz vest with the words “Chief Warden” emblazoned on the back and a white hard hat. Evacuation Roles & Responsibilities Wardens have been appointed to ensure that if any emergency occurs which requires the evacuation of the building, whether a result of a fire or otherwise, the building can be evacuated quickly and efficiently. The role of the warden is to make sure that all parts of the building are checked and the whereabouts of all occupants if the building are accounted for. A Chief fire warden has been appointed to coordinate the actions of the wardens and to liaise with the fire and emergency services. Fire & Emergency Wardens Wardens have been appointed to ensure that if any incident (fire, chemical spill or some other hazard) occurs which requires an emergency evacuation of the site, that the buildings can be evacuated quickly and efficiently in a managed way. The role of the warden is to make sure that all parts of the building are checked and the whereabouts of all occupants if the building are accounted for. A Chief Fire Warden has been appointed to coordinate the actions of the wardens and to liaise with external fire and/or emergency services response teams. In the event of a fire or other emergency requiring the evacuation of the building, wardens must wear their identifying clothing such as vests and hard hats. Duties • When the fire alarm sounds wardens are required to have full charge of the evacuation of all staff, customers and visitors in their assigned areas during the period of an evacuation. This includes a confirmation that their allocated area has been checked and is clear which is to be recorded by the Chief Warden. • Wardens should ensure that every person employed in their area is familiar with the emergency evacuation procedures. Procedures should be displayed clearly on factory notice boards, by firefighting equipment and emergency exit points. • Wardens are to ensure that their area is completely evacuated by systematically checking all parts of the area, including; storage areas, meeting rooms, toilets and locker rooms etc. to ensure they are cleared of all occupants. • Wardens are to direct all staff and visitors to leave the building by the nearest emergency exit and assemble at the designated assembly point. It is not necessary to do an actual head count, as making sure your designated area is clear of all personnel is sufficient. • Only if time permits, ensure all machines are turned off and smoke doors are closed. • Once your designated area is clear, report to the Chief Fire Warden who will be stationed at the assembly Area and inform him that your area has been cleared. Report to the Chief Warden if any person has not evacuated and the reason why e.g. firefighting, unable to evacuate due to mobility issues etc. • After reporting to the chief warden, all wardens are to assist in keeping people outside the building and ensuring all entrance ways are clear for emergency services until such time as an all clear has been given by emergency services and the Chief Warden authorises re-entry.
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Chief Warden The Chief Warden is responsible for coordinating the activities of wardens during an emergency evacuation. When the evacuation alarm sounds the Chief Warden must ensure the fire service is notified of the emergency by a nominated person dialling 111 and giving only give information that is known to be true. The chief warden will proceed to the fire alarm panel outside the front entrance where they will: • Ensure that area clearance or otherwise is recorded on the evacuation checklist. • Ensure that disabled persons are accounted for and that the location of any person who has not evacuated and the reason why they have not evacuated is recorded. • Act as liaison between Fire and Emergency and the wardens. The Chief Warden will authorise re-entry to the site only when Fire and Emergency have given permission. All Workers on Site Actions to take if you discover a fire: Operate the Fire Alarm by using any of the manual fire alarm call points located throughout the building. This will sound the alarms throughout the building Dial 111. Ask for Fire and Emergency. If calling from a desk phone inside the building you will need to dial 1 for an outside line before then dialling “111”. When connected, inform Fire and Emergency of a Fire at: NZ Comfort Group, 8 Lumsden Road, Ohinewai, Waikato. Give the precise location of the fire and any helpful information. If it is unsafe or you cannot contact Fire and Emergency from within the building, then ring once you have left the building (from a mobile phone or neighbouring building). Actions to take if the fire alarm sounds: When the fire alarm bell rings continuously the building must be evacuated and ALL personnel should assemble at the relevant assembly area: Exact area yet to be determined 17. External Emergency Response Teams Additional Emergency response contact details for Emergency services, key infrastructure providers and neighbouring properties are listed in the back of this document. (Appendices 3 & 4)
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EMERGENCY EVACUATIONS
18. Evacuation Overview If there is a continuous sounding of the fire alarms, or the instruction is given by a Warden to evacuate the building, all workers, customers and visitors must evacuate immediately. • Do not linger to finish a job or collect personal belongings. • Only if time permits, turn off and make safe equipment you are using. Remember when closing down any equipment, follow safe working procedures. • Do not lock doors. • Leave lights on. 19. Assembly Points Ohinewai site assembly points to be confirmed. Main Entrance Carpark The major assembly point for the site, is located in the main entrance (Great South Road) carpark which is situated between the Control Centre and Great South Road adjacent to the Gate 1 main entrance point. In an emergency all workers who can safely evacuate to this area should do so and gather by the assembly point signage, all staff should ensure the Warden for their area is aware of their presence at the assembly point. Saleyards Road In an emergency, workers located on the Western and Southern areas of the site will be required to evacuate themselves to the Saleyards Road gates – which are assembly points. They should remain at the Saleyards Road assembly point with the assigned wardens unless it becomes a safety concern or they otherwise directed to move by the controlling authorities. The wardens at the assembly point will contact the Chief Warden via mobile phone to inform him that their areas have been cleared. These Wardens will also ensure no unauthorised persons enter the site via these site entry points. 20. Emergency Monitoring & Alarm Systems Control Panel The main fire alarm and monitoring system panel is located at the gate house by entrance 1A to the site. Site Map included in Appendix 7
Alarm System (system not yet designed) 22 push button type alarm switches are located throughout the site. These switches activate an audible evacuation alarm which sounds throughout the site. This system also has a direct connection to the fire and emergency responder system and once activated will automatically trigger a site response from the fire service.
Fire Detectors & Suppression (parts of this system are yet to be designed but the principle is the same) Automatic sprinkler system runs throughout building except in TDI store where heat detection sensors are installed and is a self-contained 120/120 fire rated room. The automatic sprinkler system will automatically activate or in the case of the TDI area the heat sensors will automatically activate the evacuation alarm. A drop in water pressure in the sprinkler circuit activates the onsite alarm system
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21. Evacuation Plan Procedure
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FIRE EMERGENCIES
22. Equipment There are fire hose reels and fire extinguishers available throughout this building. All occupants must be familiar with the location and the use of the firefighting equipment in their area. A fire extinguisher is designed to put out small fires only. Before using an extinguisher or hose ensure that: • The fire alarm has been activated and people are evacuating the building. • A “111” call has been put through to the Fire and Emergency Services. • Wardens search their designated areas. Never delay calling “111” while trying to put a fire out. Equipment Classes There are four classes for the purpose of firefighting. Some extinguishers are more suited than others for putting out specific types of fire.
Class Type of Fire Extinguisher
Materials such as wood, paper and textiles. Fire hose reel water filled fire extinguisher or Class A multipurpose dry powder extinguishers
Flammable liquids such as petrol fats and Dry powder or multipurpose extinguishers, carbon Class B solvents. dioxide extinguishers, foam or water
Gasses such as acetylene, LPG, CNG, TURN OFF GAS FIRST Class C and natural gases. Use a dry powder extinguisher.
Metals such as sodium potassium and Special dry powder extinguisher Class D magnesium.
Never use a Fire Hose or Water filled fire extinguisher to put out an Electrical, Petrol or Liquid Chemical Fire
Using a Fire Extinguisher To determine if it is safe to use a fire extinguisher or fire hose. Is the fire small enough to be put out with a fire extinguisher? • Is the extinguisher or hose suitable for extinguishing the class of fire? • Will attempting to extinguish the fire endanger anyone’s life? • Is there an unrestricted access to the fire? The safety of the building occupants must always be the first consideration. • Make sure the extinguisher is the correct type • Break extinguisher seal/remove the safety pin. Keep yourself low so you are not overcome by the heat and smoke. • When you are safely in position, aim the extinguisher at the base of the flames • Discharge the extinguisher in a sweeping motion at the base of the flames until the fire is completely extinguished. • If the fire becomes uncontrollable, or there is too much heat or smoke to stay safe, leave immediately.
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23. Suggested Response for Large Foam Fire Many measures are in place to prevent ignition of foam stored onsite. The greatest risk is of a fire starting is in the Foam Block Store that is part of the factory building. The large volume of foam stored in the store, and the curing process, creates an elevated risk. This room is able to be sealed in the event of a fire to contain the fire and minimise the risk of the fire spreading. Should a fire occur in the Foam Block Store, the speed with which all foam in the area would ignite and the intensity in which the fire would burn is such that extinguishing a fire once established would be virtually impossible. In the case of this rare event occurring, it is suggested efforts are best spent in an attempt to minimise the spread of the fire beyond the Foam Block Store whilst reducing the potentially harmful effects of the fire on the immediate surroundings – including people and the environment. It is suggested response efforts should focus on the use of water to cool exterior metal walls in an attempt to prevent radiant heat affecting neighbouring structures. The fire would burn intensely, removing the skylights, and allowing venting before the steelwork in the roof twisted and collapsed. Time to burn-out of such a fire is estimated to be 30-40 minutes. A hot fire would generate large flames with a plume extending high up into the atmosphere which would enable toxic fumes to be dispersed at an elevation where the risk of harm to the immediate environment and population was greatly reduced. Any action which lowers the burning temperature of the fire is likely to increase the formation carbon monoxide along with other toxic chemicals and soot at a height which is far closer to ground level. This would also restrict the safe dispersion of toxic fumes by lowering the plume height. The advantage of allowing a fire, which cannot be extinguished quickly to burn unchecked is the lessening of damage to the environment, potential impact to human life and produces a much smaller amount of dirty water run-off which could be generated by firefighting activity. 24. Fire Prevention & Control Methods In order to manage and mitigate the risk of a fire, several control methods and measures are in place. These include: • A site wide ban on smoking other than in the designated smoking areas. • Enforcement of Hot Works Permit requirements is in place. No hot work is to take place without first completing a hot work permit and following the correct procedures for relevant risk assessments. Whilst hot work is undertaken (until such time as the elevated risk created by the hot work is no longer present) there is a requirement for a fire watch to be present, with suppression devices in the event of a fire breaking out. • Scheduled electrical inspections of all machinery and wiring throughout the site occur in line with the annual plan. This is conducted by authorised electricians with site experience. • The provision of portable firefighting equipment in line with NZS 4503:2005. Inspection of all these devices is carried out in accordance with the appropriate regulations. • Forklifts used inside the factory building are either electric or gas powered. Forklifts with internal combustion engines are fitted with a modified exhaust system to prevent the hot exhaust coming into contact with the foam. • A 2-hour firewall forms a protective barrier between all manufacturing areas and the hot block store including the foam plant. More information regarding the monitoring and maintenance of our Fire Prevention & Control Methods is available in the “Maintenance & Testing of Emergency Plan & Systems” section on page 30. 25. Fire Emergency Environment Impact When Polyurethane decomposes, smoulder or burns at low temperatures, substantial amounts of the monomers (Isocyanates and polyols) will be released. In addition, combustion will release aromatic mono and polycyclic compounds as sooty deposits and various gaseous products (CO, CO2, HCN etc.)
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CHEMICALS
26. Overview The following activities undertaken on site use and store Toluene Diisocyanate (TDI), Methylene Diphenyl Isocyanate (MDI), Methylene Chloride (MeCl2), and Polyols: • Polyurethane Foam Manufacture • Underlay Manufacture 27. Chemical Properties The following table provides detailed information about the hazardous chemicals we have onsite.
Chemical Site Max Volume Chemical Properties Toxicity & Effects
Toluene Di-isocyanate 65,000 kgs Max TDI is a Liquid which is clear / colourless Toluene Di-isocyanate has multiple (TDI) in appearance and has a pungent odour. human impacts. Volumes will change to comply with Major TDI volatilises when exposed to air, and It is acutely toxic to humans and is a Hazardous Facilities can result in a hazardous vapour to form. known primary irritant to: lower tier level. As TDI has a freezing temperature of • Skin, eyes, airways and mucosa 14°C and a melting temperature of 22°C. the potential for TDI vapours varies It is also: through the year, depending on the • a respiratory and dermal contact current ambient temperature. sensitizer; and Average temperatures in Auckland • a suspected carcinogen, and usually only exceed 22°C during the summer months of December through to • toxic to human target organs or March. systems via inhalation or oral pathways. Average temperatures of 14°C to 20°C are normal during all other seasons. It is also harmful to the eco toxic in the aquatic environment and is Refer to Safety Data Sheets stored toxic to terrestrial vertebrates. digitally within ChemAlert or hard copies located in the foam plant office and at the Fire Panel.
Methylene Chloride 500 kgs Methylene Chloride is a liquid which is Methylene Chloride has multiple clear/colourless and has a sweet odour human health impacts. Methylene chloride is highly volatile and It is acutely toxic to humans via oral has a boiling point of 39.6. Therefore, a pathways it is also: spill of methylene chloride would result in vapours even during winter. • irritating to the skin and eyes; and Refer to Safety Data Sheets stored • a suspected carcinogen; and digitally within ChemAlert with hard • harmful to human target organs copies in the foam plant office and or systems via inhalation. available at the Fire Panel It is also harmful to terrestrial vertebrates.
35,000 kgs Max Methyl Diphenyl Diisocyanate is a light Acutely toxic via inhalation, mildly yellow coloured, odourless liquid. irritating to the skin, respiratory Volumes will change Flashpoint of 200oC. sensitizer, toxic to human target to comply with Major organs or systems via inhalation. Hazardous Facilities Refer to Safety Data Sheets stored lower tier level. digitally within ChemAlert with hard copies in the foam plant office and available at the Fire Panel.
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28. Hazchem Codes & Safety Data Sheets Full set of Safety Data Sheets in foam plant laboratory and individual Safety Data Sheets where chemicals are used.
Chemical Inventory Our Chemical Inventory is recorded in an online system called ChemAlert, hard copies of the inventory maximum volumes and comprehensive list of all chemicals held on site is kept in the Foam Plant office and at the Fire Panel. 29. Chemical Locations Refer Ohinewai Site Map in Appendix 6 30. Hazardous Chemical Spills Scenarios Uncontrolled Release Maximum Possible Levels Drum Contained Chemicals Uncontrolled release from damaged drums. Although this event could release a maximum of 20,000 litres of product, the likelihood of every drum in container onsite rupturing simultaneously is highly unlikely. Bulk Storage Tank Chemicals The TDI tank is capable of holding 25,000 litres of product. The TDI bulk storage tank has 3 mechanisms to prevent uncontrolled releases during the tank filling process. Refer Appendix 1 for detailed explanation and diagram of the tank set up. In the event of an uncontrolled release of TDI from the bulk storage tank, a large percentage of the toxic vapour would be contained as the bulk tank is inside the building. Should this happen the doors to the TDI Store would be sealed and vapour from the spill could be exhausted through the carbon filter. TDI/MDI liquid would flow into a covered bund area under the tanks. Vapour would be contained in this sealed area. The spill would then be pumped into drums for reuse or disposal. 31. Hazard Zones Determining Hazard Zone (TDI Spill) The “Health and Safety Employment Act 1992 Approved Code of Practice for the Safe Use of Isocyanates”, (Electronic and hard copies held on site) sets specific exposure standards for Isocyanate exposure these form the basis of hazard zone calculations: TWA (Time Weighted Average) = 0.02 mg/m3 or 20 parts per billion (ppb) STEL (Short Time Exposure Limit) = 0.07 mg/m3 or 70 parts per billion (ppb) Monitoring equipment is used continuously onsite during foam manufacture and will trigger an audible alarm to indicate a potential spill or leakage has occurred. Working on these recommendations, in conjunction with the figures shown in Appendix 5 the following hazard zones have been calculated upwind of the spill. Total Exclusion Zone From the modelling Jacobs has undertaken and is set out in the QRA for a range of incidents that could occur at the sites, the general conclusion is that for all incidents involving TDI that the spill (drums etc) and resulting release of vapor will not have offsite effects and would have an safety exclusion a zone of 40-50 m ( this is for a burst transfer line on an ISO tanker) from the spill. For a drum the exclusion safety zone is out to 10 metres. If four drums a pallet load was all damaged then the exclusion s zone would be out to 40 to 50 m. * Refer Exclusion Zone Map in Appendix 5 32. Exposure Standards The exposure standards used for the above zone calculations do not represent 'No-Effect' levels, which guarantee protection to every person. Given the nature of biological variation and range of individual susceptibility and sensitivity, it is possible that a very small proportion of people who may be exposed to concentrations around or below the exposure NZ Comfort Group Ltd Ohinewai Site Page 20 of 40
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standards may suffer mild respiratory discomfort. Asthmatics and sensitised persons could fall into this category. 33. Chemical Emergency Environmental Impact There are a number of cess pit storm water drains as well as slit drains running down the centre off the property. Drainage Cess Pit/slit drain locations in Appendix 9 for the exact locations. There is a risk of environmental impact should any chemical or liquid run off flow into these cess pits and enter the underground storm water system.
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Emergency Planning Assumptions
34. Fire Emergency Assumptions Draft - to be updated when long block store designs are completed With a fire, the area likely to be affected would be less than that for a T.D.I. spillage, and this type of incident would be over so quickly that it is doubtful that much time would be available for the evacuation of a large populated area. The best you could possibly hope for is that the site and the immediate neighbours are informed and evacuated if necessary. The amount of foam in storage would determine the length of time the fire would burn and the amount of toxic fumes released. If completely full the foam storage area would have approximately 18 x 30 metre blocks of foam in it. The average amount of stock held is 14 to 15 blocks. The most probable outcome would be the fire lasting for 1 - 1.5 hours at the most, with complete loss of all stock and the building. The priority would probably be given to protecting adjacent buildings and to stop the fire spreading. Refer Section 21; Suggested Response for Large Foam Fire for more details.
35. Hazardous Substance Emergency Assumptions In any large spillage, most if not all (depending on the location of the spill), of the T.D.I. would be caught by the protective bunds that surround the bulk facility. The most likely incident, or the weakest part of the system, is when drums T.D.I. are being unloaded from containers and shifted to the drum storage areas. If there was an uncontrolled release incident during this process the maximum volume of TDI spilt would be 500kgs or 2 drums – this would trigger a Major Hazardous Substance Emergency. Refer Section 36 & 37 for more information on responding to this type of emergency. In this situation, the product would give off large concentrations of fumes, well in excess of TLV's. The area likely to be affected is incalculable, and initially the entire site would have to be evacuated as a precaution. It is likely that this would extend then to our immediate neighbours. The public would also have to be protected, and depending on the size of the spill and the area of the hazard zone, the area surrounding Sleepyhead would have to be isolated by the emergency services. The location of isolation barricades would depend on the size of the spill and the weather conditions at the time. The environment would not be damaged greatly if the majority of the spill was contained without running into the storm water drains, this again would depend on the weather conditions at the time. If rain was falling the problem would be compounded and difficult to control. Public Health would take the highest priority, and they would have to be protected from the inhalation of fumes, and of course from contact with the T.D.I. Stopping the T.D.I. from entering any drains would be given high priority, as T.D.I. when in contacted with water produces a urea, which would eventually block the drainage system. This reaction would also give off dangerous fumes. It is hard to predict how long the clean-up procedure would take as it would depend on the weather conditions prevailing at the time. It is predicted that, with the proper equipment and favourable weather conditions, clean up could be complete within 12 hours.
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MINOR HAZARDOUS SUBSTANCE EMERGENCY
36. Minor Hazardous Substance Spill A minor spill is considered to be any spill not exceeding 200 Litres of hazardous substance chemicals. Should a minor spill occur, depending on the toxicity and properties of the chemical involved an evacuation of the immediate area may be required. If this is the case, the need to evacuate should be communicated verbally to the relevant manager of the affected areas. 37. Minor Hazardous Substance Spill Plan
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MAJOR HAZARDOUS SUBSTANCE EMERGENCY
This may require updating for the Ohinewai site 38. Major Hazardous Chemical Spill A major spill is considered to be any spill which exceeds a 200 litres volume of hazardous substance chemicals. 39. Major Hazardous Substance Spill Plan
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LPG OR FLAMMABLE GAS EMERGENCY
40. Gas Leak This procedure applies to uncontrolled dispersion of LPG or other flammable gases such as natural gas. • First consider the safety of all people present • If you suspect a flammable gas leak, move away from the source of the leak before using a mobile or cordless phone. • Evacuate and if necessary, call Emergency Services (Dial 111) ask for FIRE • If safe to do so, isolate or turn off gas at the source Bulk Storage or Main Line Leak • Activate the alarm, Evacuate the area • Call Emergency Services (Dial 111) as for FIRE • Tell the operator you have an LPG leak from a Bulk Storage or Mains Pipeline Leak • Remove all ignition sources • If there is a Pipe Leak close the isolation valves if safe to do so • Notify Site Operations Manager and Health & Safety Manager LPG Cylinder / Bottle Leak • First, if there is a possibility of the cylinder being engulfed by fire, evacuate surrounding area • Call Emergency Services (Dial 111) ask for Fire and Emergency • Advise them of a suspected LPG Leak, the location of the cylinder and the size of the cylinder. • Remove all ignition sources • If safe to do so: - Remove the cylinder or appliance from any heat source - Stop the leak by shutting the cylinder valve - Remove the cylinder to a safe outdoor area, if the leak persists DO NOT ATTEMPT ANY OF THE ABOVE IF YOU ARE NOT SURE WHAT TO DO • If gas is leaking, vent the area thoroughly until air is clear • Do not use the cylinder until it has been inspected and certified as safe. • Notify both the Site and Health & Safety Manager’s
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NATURAL DISASTER EMERGENCY
41. Overview The two most likely natural disasters that could create an emergency for our site are Earthquake or Flood related. If a natural disaster strikes the following steps should be taken: • Turn on a radio for advice and information. • If they are within reach take phone, wallet, bag and any emergency supplies with you upon evacuation. • Know and listen for the Civil Defence warning signal. • Identify the location of your nearest Civil Defence post and/or Police station. • Do not go sightseeing or make unnecessary trips to affected areas. 42. Earthquake During the Earthquake In the unlikely event of an earthquake, the following steps should be taken: • Remain Calm. • Move away from windows or heavy objects which could fall. • Drop, Cover and Hold. • Get under something solid that covers you, like a strong table, desk or other sturdy structure such as a solid wooden door frame. Hold on to it if you can. • Do not move until shaking stops.
After the Earthquake After an earthquake has ended and the shaking has stopped, the following steps should be taken: • An emergency evacuation should be initiated – wardens will advise staff to take bags, phones, wallets and emergency supplies which are within reach. • Once the evacuation is complete, establish what (if anything) has happened to everyone. • Conserve your water. • Treat injuries. • Get in touch with neighbours – they may need help. • When help is needed go to your nearest civil defence post. • Advise Supervisor / Operations Manager / H&S Manager if any damage or injury is sustained.
If the building is damaged: • Turn off gas at the mains. • Before you turn off electricity and water, think about whether the gas detection, fire suppression and alarm systems need these services. • Identify any chemicals that may have been spilt or damage to containment systems. • Should there be a spill or leak of a chemical or flammable gas, evacuate the immediate area and isolate the hazard if possible.
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43. Flooding Storm events In the event of flooding, the following steps should be taken: • Listen to the radio for information and follow civil defence instructions. • Be prepared to get to high ground. • Turn off electricity and gas supplies. • Do not go into floodwaters alone or go “sightseeing”. • Do not drink flood water. • Avoid back flow from drains and toilets. If possible fit bungs (stoppers) or sandbags and weigh them down. Waikato River Stop Bank Breach A flood model was completed to quantify the risk of a stop bank breach of the Waikato River in 3 separate locations. The assessment was carried out by Woods report dated 18/11/2019 and updated in May 2020. The modelling outlines that during a stop bank breach, flooding would not affect the factory and bypass the site to the north. An extract of the modelled flood extents is included in Appendix 10. In addition to the steps set out above for flooding events, while unlikely, any stop bank breach could restrict access to and from the site from Balemi Road. Taking into account the analysis completed, emergency access and egress is provided to the Factory as follows: • Exit from the site can be made via the internal road on the north east side of building 1 and then via the road on the south side of building 1 exiting onto Lumsden Road. • The site layout does not include an exit onto Balemi Road (Stages 1 & 2). As the site is developed, improved flood emergency exit procedures will be developed as requried.
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TERROR THREAT EMERGENCY
44. Bomb Threat If a bomb threat is received, the Operations Manager or delegate will firstly notify Police and then take one three courses of action as advised by the Police: Search The two most convenient forms of search available are the supervisory search (a covert operation) and occupant search (an obvious operation). The most thorough of the two forms of searching methods is the occupant search, however utilising the occupant search involves notifying all occupants of the threat and it is possible that factors such as the age and maturity of the occupants could render this inadvisable. In deciding the priority of searching, it is advised that stated location, if any, be searched first, followed by areas which the public have easy access (including the exterior of buildings), followed by occupied areas, and finally storerooms and the like. Whichever search is carried out, no guarantee can be given that a bomb has not been planted, as it is virtually impossible, short of demolition, to fully search a building. Search & Evacuate If the decision is made to search and evacuate, all machinery, gas and electricity should be turned off and a thorough search of the evacuation areas, building entrances, emergency exits and garden areas should be conducted prior to an emergency evacuation being initiated. Evacuate Without Search The decision to evacuate without searching could be the result of a threat evaluation where a specific location and/or time have been stated for the bomb to function. 45. Suspicious Item or Package If a suspect item is located, it must under no circumstances be handled or approached by anyone whatsoever. The finder should report the item to the site Operations Manager or delegate including a description of the object and its precise location. The location of the item should be clearly and visibly marked and an isolation perimeter established. An emergency evacuation should be initiated. If the item is located inside a building, the windows and doors of that area should be opened to disperse blast pressure, in the event of the device activating.
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EMERGENCY RESPONSE TRAINING
46. Spill Response Team The site has a 6-member Spill Response Team (SRT) (with an additional 2 people who act as back-up responders) who receive specialised training to become qualified and proficient in a number of key areas required when responding to a hazardous substance spill emergency. Qualifications As a minimum requirement, the SRT members all receive training and retain current competence for the following qualifications and skills: • Certified Chemical Handler • Use of Self-Contained Breathing Apparatus • Use of spill response PPE and equipment e.g. splash suits and containment tools • Chemical safety and decontamination • Bi-monthly simulated spill drills. 47. Medical Response Team The Medical Response Team (MRT) is made up of staff who are trained and hold current competency certification in providing emergency first aid. 48. Emergency Evacuation Team The Emergency Evacuation Team (EMT) have all received training in Warden procedures and practice these skills twice per year during evacuation drills. 49. Fire Suppression Response Key workers who are based in departments with a high risk of fires occurring (such as the Underlay and Foam manufacturing areas) are trained in the proper use of fire suppression equipment such as fire extinguishers. This training is delivered by external professional trainers on a biennial basis.
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MAINTENANCE & TESTING OF EMERGENCY PLAN & SYSTEMS
50. Control Panel The Control Panel is tested on a monthly basis as part of the alarm system testing process. 51. Alarm System The alarm system is tested on a monthly basis by Argus 52. Fire Extinguishers & Hoses Fire extinguishers and fire hoses are independently inspected on a bi-monthly basis. 53. Self-Contained Breathing Apparatus As part of the bi-monthly spill drills, the breathing apparatus equipment is inspected and tested. 54. Sprinkler System The sprinkler system is tested by way of a 4 point and stress test process on an annual basis. 55. Automatic Doors The automatic fire door systems are independently tested on a quarterly (3 monthly) basis. 56. Drainage System The drainage systems are monitored and checked quarterly; these checks include testing of waste water to verify there is no chemical run off detected within the drainage systems.
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Emergency Plan Doc SHO 001 June 2020
APPENDIX 1
57. TDI Tank Safety System Filling the Tank When the TDI tank is filling the TDI liquid flows from the decanting pump into the top of the TDI tank. The expelled air passes into the over flow tank and expelled into the atmosphere via the carbon filter. A one-way flow valve ensures the expelled air passes through the carbon filter. The tank has an ultrasonic level indicator with a “full” level switch which automatically shuts the decanting pump off once this level is reached. Should this switch fail there is a separate “high” level indicator switch which will automatically shut the decanting pump off. In the unlikely event that both of the switches in the primary tank fail, the excess TDI will automatically decant into the overflow tank, where there is a further switch which will shut the decanting pump down. Emptying the Tank When TDI is taken from the tank the air entering the tank passes through a desiccant drier which ensure only dry air enters the tank. A one-way flow valve ensure air entering the tank pass through the desiccant drier. TDI Bulk Storage Tank Layout
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APPENDIX 2
58. Incident Control Team
Name: Role / Area: Contact Number:
Lawrence Holden Site Manager +64 275 451 404
Dave Hughes NZ Safety Manager +64 275 96 8450
Peter Rogers Facilities Engineering Manager +64 275 54 9029
Pita Eti Foam Plant Supervisor +64 278 076 743
Bruce Huddleston Electrician +64 272 232 265
Gate House Site Security includes monitoring 0508 744 7687 Security Platform 4 Group (P4G)
Chris Taylor General Manager +64 274 763 532
John Symon National Operations Manager +64 274 333 197
Craig Turner Director +64 219 205 82
Graeme Turner Director +64 274 922 193
59. Spill Response Team
Name: Role: Mobile:
Pita Eti Chemical Response Team Leader +64 278 076 743
Salesi Mafi Chemical Response Team
Elton Sua Chemical Response Team
Andries Boshoff Chemical Response Team +64 215 437 73
Tui Holtz Chemical Response Team
Kaui Pakuiri Chemical Response Team
Mahonilau Edui Chemical Response Team
Michael Siua Chemical Response Team
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Emergency Plan Doc SHO 001 June 2020
APPENDIX 3
60. External Emergency Response Contacts (some data yet to be confirmed) EMERGENCY PHONE NUMBERS FIRE & EMERGENCY EMERGENCY 111 Nearest Stations: HUNTLY Ph: (07) 828 8799 HAMILTON Ph: (07) 839 4996
AMBULANCE EMERGENCY 111 Huntly Ph: (07) 828 7161 Hamilton Ph: (07) 847 2849
HOSPITAL Waikato Hospital Ph: (07) 839 8899
DOCTOR (To be confirmed) Ph: In an Emergency 111
POLICE EMERGENCY 111 Huntly Station Ph: (07) 828 7560
MAINS ELECTRICAL WEL Energy Fault with main power supply Into site whether an Emergency or to report accident or loss of power (24 HOUR) Ph: 0800 101 810
ELECTRICAL (Internal) Bruce Huddleston Ph: 0272 2232 265
GAS (MAINS) E GAS (To be confirmed) Ph: (09) 368 5495 (BOTTLED) Rock Gas (To be confirmed) Ph: (09) 279 0500
WAIKATO COUNCIL Pollution Hotline Ph: 0800 884 883
NATIONAL POISONS CENTRE 0800 764766
WATER (To be confirmed) Ph:
MPI 0800 809966
Telephones (IT System) 6
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Emergency Plan Doc SHO 001 June 2020
APPENDIX 4
61. Neighbouring Business Emergency Contacts (To be updated when info is available)
CONTACT NAME / POSITION COMPANY CONTACT NUMBER
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Emergency Plan Doc SHO 001 June 2020
APPENDIX 5
62. Hazardous Zone
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APPENDIX 6
63. Bulk Chemical and Foam Block Storage
Diagram A. Chemical and Foam Block Storage
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Emergency Plan Doc SHO 001 June 2020
Diagram B. Chemical Foam Plant Only
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APPENDIX 7
64. Ohinewai Site Layout
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Emergency Plan Doc SHO 001 June 2020
APPENDIX 8
65. Drainage Cess Pit Locations
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Emergency Plan Doc SHO 001 June 2020
APPENDIX 9
66. Stop bank breach - flood extents Taken from Flood Assessment carried out by Woods - updated May 2020
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Ohinewai Foam Factory Hazardous Substances Assessment
Appendix D. SOP for Dealing with a Hot Block
IZ052900-NEM-RT-002 60 Title: Transfer hot long foam block from rack conveyor room to fire conveyor
Document No SH 0040 Date of Issue: 7.7.16 Issue No 1
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TRANSFER A HOT LONG BLOCK OF FOAM FROM RACK ROOM CONVEYOR TO FIRE CONVEYOR
A “hot” block of foam is identified by monitoring of the block exothermic temperature which has indicated that the block temperature is still rising after the block maximum temperature alarm has been activated Identify the rack number containing the hot block and feed this info into the hot block rack control screen Push fire conveyor tab and the block will be automatically transferred via the travelator to the fire conveyor.
Once hot block has be positioned on fire conveyor
While carrying out this operation ensure the priority is always safety of yourself and others Put on required PPE o full face covered respirator o overalls o gum boots o gloves Manually open valve to turn on manually operated fire sprinklers located over the top of the fire conveyor,. Water valve located at foam plant end of fire conveyor. Push water lances into foam block and open water valve to operate water lances. Water valve located on each fire hose Continue repositioning water lances to ensure total block is soaked internally with water Monitor block temperature with portable temperature probes If temperature of block does not decrease call fire brigade Once temperature of hot block indicates temperature decrease keep sprinkler system and water lances operator for at lease a further 1 hour. Once block temperature is under control cut the block up using wire saw into block lengths that can be shifted by fork hoist. Leave cut blocks on fire conveyor for a further 24 hours then decide on how to dispose of the wet short blocks. Fill out an incident report form and pass this completed form on to your supervisor
Written by: Dave Cox 1 Operations Manager - Foam
Approval:
Ohinewai Foam Factory Hazardous Substances Assessment
Appendix E. SOP for ISO Bulk Tanker Transfer
IZ052900-NEM-RT-002 61 Title: Transfer of TDI from ISO Tanker to Bulk Tank Document No SH 0026 Date of Issue: 13.11.10 Issue No 1
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TRANSFER OF TDI FROM ISO TANKER TO BULK TANK
ISO Tanker must be in within the yellow lined bunded area on the concrete pad at front of the tank farm
Before connecting iso tanker to delivery piping ensure valve in storm water drain from bunded area is closed. Refer procedure SH0011
Check level of bulk tank to calculate the amount of TDI that can be transferred from the iso tanker into the bulk tank.
Record calculated litres to be transferred.
Connect return vapour line to ISO tanker.
Empty white oil from delivery pipe coupling
Connect delivery pipe coupling to iso tanker outlet
Complete TDI transfer check list SH0028 and sign off
Open iso tanker outlet valve
Check for leaks
Start delivery pump. Follow procedure as per SOP for transferring polyol.
Monitor TDI level in bulk TDI tank.
When ISO tanker is empty shut ISO tanker outlet valve.
Open breather valve to allow pump to empty delivery pipe
Disconnect hose from iso tanker
Allow TDI in transfer pipe to empty through pump
Turn off pump.
Written by: Dave Cox 1 Operations Manager - Foam
Approval:
Title: Transfer of TDI from ISO Tanker to Bulk Tank Document No SH 0026 Date of Issue: 13.11.10 Issue No 1
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Fill delivery pipe connector with white oil.
Fit end plugs to both delivery and vapour line connector.
Hook both pipes onto rope and lift up into storage position.
Written by: Dave Cox 2 Operations Manager - Foam
Approval:
Ohinewai Foam Factory Hazardous Substances Assessment
Appendix F. Qualitative Risk Analysis Descriptors
F.1 Consequence Descriptors
Effects
Level Descriptor Societal (Health and Community Environmental Fiscal Safety)
5 Insignificant No injuries or health Workforce Incidental on-site effect. No Low financial effects concern ecological consequences. loss <$10,000. 4 Minor First aid treatment. Local Minor release immediately Medium Incidental injury or community contained. Reduction in financial loss. health effects to concern abundance / biomass of flora $10 -100 k. persons exposed. fauna in affected area. No changes to biodiversity. Minor environmental nuisance. 3 Moderate Injuries or health Regional Off-site release contained High financial effects to persons community with outside assistance. loss. $100k - requiring medical concern and Reduction in biomass in local 1million treatment. local area without significant loss reputational of pre-impact ecological risk functioning. Significant sustained environmental nuisance. 2 Major Extensive injuries or Widespread Off-site release with Major financial health effects to reputation significant impact to loss. $1-10 persons. Single risk to a biodiversity and ecological million. operator fatality single functioning with eventual business unit. recovery (maybe not to pre Widespread impact conditions). community outrage 1 Catastrophic Single public fatality; Widespread Toxic release with off-site Huge financial multiple operator reputation detrimental effect. loss. >$10 fatalities or severe risk to more Irreversible changes to million. permanent disabilities than a abundance of biomass in to more than one business unit. affected environment. Loss person. Extreme of ecological functioning with community little prospect of full outrage recovery.
These tables are based on ISO 31000:2009
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F.2 Likelihood Descriptors
Level Descriptor Environmental Incident Frequency Project Frequency Likelihood
A Almost Certain Common < 1/Month More than once during the project. occurrence, high volume/use. B Likely Common 1/Year Once during the project. occurrence, low volume/use. C Possible Occasional 1/10 years Could happen during the project life. occurrence, high volume/use. D Unlikely Occasional 1/100 years Unlikely to occur during project life. occurrence, low volume/use. E Rare Very unlikely to occur during the Rare occurrence. 1/1,000 years project life.
F.3 Risk Ranking Matrix
5 4 3 2 1 LIKELIHOOD (Insignificant) (Minor) Moderate) (Major) (Catastrophic)
A M H VH VH VH (Almost Certain) B M M H VH VH (Likely)
C L M M H VH (Possible) D L L M M H (Unlikely) E L L L M M (Rare)
This matrix is based on ISO 31000: 2009
Key: Low risk; managed by L LOW routine procedures. Moderate risk; requires M MODERATE above normal attention.
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High risk; ALARP must be H HIGH applied. Very High risk; not acceptable and must be VH VERY HIGH reduced.
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IZ052900-NEM-RT-002