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CTA Report, Draft 1, ISP Review - US Chemical Safety and Hazard ...

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• Manually striking baghouse bags with sticks, removing the waste from the baghouse, <strong>and</strong><br />

dropping it via the pipe chute into the blend room.<br />

These line-cleaning activities suspended the combustible dust <strong>and</strong> allowed it to settle on flat surfaces.<br />

The oven was not normally shut down during line cleaning because it took a long time to reheat. Material<br />

cleaned out of the processing line was typically dumped onto the plant floor <strong>and</strong> then swept up with<br />

brooms <strong>and</strong> deposited in a dumpster. Wall-mounted <strong>and</strong> portable pedestal fans were used to blow dust<br />

away from the operators as they cleaned around the lines. The fans increased the dispersion of<br />

combustible dust in the production area, which resulted in dust settling on overhead flat surfaces.<br />

4.3 Periodic Line Maintenance<br />

Line 405—including the oven—was shut down for maintenance periodically. According to maintenance<br />

logs, in 2002, periodic maintenance on line 405 was performed at intervals ranging from 6 to 9 weeks. In<br />

2003, line 405 was first scheduled for periodic maintenance on February 13 (8 weeks from the last<br />

maintenance), but the maintenance was postponed twice, <strong>and</strong> eventually rescheduled for February 21 (9<br />

weeks from the last maintenance).<br />

During normal maintenance, accumulations of phenolic resin powder <strong>and</strong> fiberglass that collected inside<br />

the oven were s<strong>and</strong>blasted off walls <strong>and</strong> the oven flights. Material in the bottom of the oven was scraped<br />

out, the bags inside the baghouse were replaced, <strong>and</strong> the rotary airlock was cleaned out. The material<br />

removed from the airlock was typically dumped on the roof of the blend room. Over time, a pile of<br />

combustible dust—about the size of a 5-gallon bucket—built up on the blend room roof.<br />

4.4 Plant Shutdowns<br />

Twice a year—typically in July <strong>and</strong> December—the entire <strong>CTA</strong> facility was shut down for cleaning<br />

<strong>and</strong>/or maintenance. During the cleaning, all plant equipment was shut down except for exhaust fans <strong>and</strong><br />

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