Flex Foam - Executive Summary |
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Flex Foam, a division of Western Bonded Products, Inc., is committed to providing a safe working place and protecting the environment. We consider this a high priority and we continue to endeavor to reduce the risks associated with working with hazardous substances wherever feasible. Management supports the development and implementation of this Risk Management Plan (RMP) and is committed to maintaining safe practices to preserve a safe environment for our employees and our community. In accordance with the RMP and Off Site Consequence Analysis (OCA) and the accident history at this site, Flex Foam is elligible for the RMP Program Level 1. Safety is primarily promoted by improving and continuing education for employees, by minimizing handling of hazardous substances, by restricting employee (and certainly public) access to areas where hazardous substances are used and stored, by enhancing process, building, and grounds monitoring, and by pollution prevention efforts wherever feasib le. PROCESS DESCRIPTION Flex Foam manufactures polyurethane slabstock foam (slab) and rebonded foam products. Both foam products are used for carpet pad, and slab foam is also used in the upholstery, furniture, and bedding industries for cushions and padding. Pads and cushions are cut to order on site as specified by the customer. Polyurethane foams (slab) are synthetic foams derived from the chemical reaction of a diisocyanate and alcohol in water, aided by catalysts and a blowing agent. Colors and/or fire retardants are added as required by the customer. Flex Foam uses Toluene diisocyanate (TDI) in this process. This is the only hazardous substance on site subject to RMP requirements. Chemicals are pumped and metered from the main storage tanks to a mixhead where the reaction takes place. All chemicals are liquid and this part of the process is automated and totally enclosed. The reaction is practically instantaneous, within in seconds the product begins to "set up". T he resulting foam bun is conveyed through a tunnel and away from the mixhead. Almost all the TDI is consumed within the product, very lilttle is emitted from this process. Rebonded foam products are recycled slab foam which is ground into small chunks and mixed with binder. The binder is a blend of TDI or MDI, polyol, and oil and is like glue in consistency. The resulting mass is pressed into a round mold and steam cured. Flex Foam recycles 30,000 to 40,000 lbs of scrap foam in a single shift operation. Scrap foam is received from new construction trim and old foam from demolition or remodeling project, all of which mayhave been sent to a land fill. Scrap foam from on site activities are also recycled back to the rebonded foam process. The final foam products are cut to size on site in accordance with the customer's orders. Volatility of TDI is very low. In addition, when it is combined with the polyol product, it is even more "bound up" and less volatile. Therefore the eva poration rate is low and fugitive air emissions from these operations or in the event of a spill, are minimal. WORST CASE RELEASE SCENARIO Early in 1997, Flex Foam, along with other foam manufacturers, contracted through the Polyurethane Foam Manufacturing Association (PFA) , the Roy F. Weston, Inc. to work with EPA to develop the appropriate modeling approach and identify parameters specific for our industry that would meet the RMP requirements under Section 112(r) of the Clean Air Act . The results of this cooperative effort recommended using the ALOHA Version 5.2.1 model, and identified the worst case release scenario as an instanteous release of the largest storage vessel on site. Upon review of the recommendations and considering Flex Foam's site specifics, our worst case release scenario was determined to be an instantaneous release of the contents of the main TDI tank. Flex Foam has one 9705 gallon TDI Storage Tank on site. The tank is located in a confined tank room tha t is located in the manufacturing building. The tank is also within a retention wall within the room. These passive mitigation measures were taken into consideration while conducting the analyses. The surface area of the pool would not exceed 745 FT2. The recommended procedures from the PFA contractor and EPA were followed. Sensitivity analyses for several parameters, including temperatures, were also run to verify the worst case release scenario. For tanks located within a building, the model is first run in the outdoor Puddle mode. This mode determines a maximum emission rate for input conditions to the second phase of the model. Ten percent of this emission rate is used as the emission rate in the Direct mode of the model and run again to determine the endpoint. NOTE: IN SECTION 2.6 OF THIS REPORT, THE "RELEASE RATE" IS REPORTED AS 0.2 LBS/MIN AND IN SECTION 2.11 "DISTANCE TO ENPOINT" IS REPORTED AS 0.2 MILES, AS DIRECTED BY EPA (EPA RMP HELPLINE). ACTUAL RELEASE RATE IS 0.0007 LBS/MIN AND ACTUAL DISTANCE TO ENDPOINT IS 0.OO74 MILES. THE RMP*SUBMIT PROGRAM DOES NOT ALLOW ENTRIES IN THESE FIELDS BELOW 0.2. The analyses showed that NO OFF-SITE RECEPTORS WERE IMPACTED. FIVE YEAR ACCIDEDNT HISTORY Flex Foam has not had any incidents within the last five years that has resulted in an accident in accordance with 40 CFR 68. PREVENTION PROGRAM AND STEPS In addition to the passive mitigation measures mentioned above, Flex Foam has taken several measures to reduce, not only employees exposure to hazardous substances, but also to reduce the likelyhood of accidental spills or releases. Both the rebonded and slab foam chemical processes have been automated and enclosed. The systems are monitored closely during operation at the control board and flowmeters. The systems are also walked down before, during, and after operations. The equipment and tank levels are inspected daily. Chemical deliveries are closely monitored by delivery personnel and a Flex Foam Operator and the delivery supply hook up is adjacent to the tank. Safety issues are reinforced throughout the week during the daily crew meetings. Safety meetings are held weekly. Safety is further enhanced by restricting access to the chemicals and the chemical use areas to a small number of employees and plant management. These individuals receive additional training. System preventive maintenance and daily system inspections help minimize accidental occurrences by looking for potential failures. The grounds and buildings are also monitored by a 24 hour Security System which includes video monitoring, intrusion and fire alarms with security notificaition and automatic dispatch capabilities. EMERGENCY RESPONSE PROGRAM An Emergency Response Plan (ERP), in accordance with Arizona Revised Statutes 26-347(ARS), is maintained with the Arizona State and Maricopa County LEPC, and the Phoenix Fire Department. Since handling and processing of TDI is contained within our b uildings, a release would not present an immediate threat to the environment or any off-site receptors. Therefore, the ERP provides for trained personnel to indentify an incident, notify the Facility Emergency Coordinator (FEC) and evacuate along with the remaining employees. Employees in chemical use and storage areas each have a two radio with them at all times. The FEC notifies the proper authorities. Absorptant material and PPE are kept in close proximity of activities involving the use or storage of TDI. However, in the event of a release, clean up would be done by an outside contractor. Alarms are used to notify personnel to evacuate. The ERP is reviewed annually. Training and drills are conducted several times a year. Notification procedures are in accordance with the EPA and ARS requirements. Flex Foam Management has directed Plant Management to continue to review our processes and activities and provide safety improvements wherever feasible. |