Woodbridge Foam Fabricating, Inc. - Executive Summary

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EPA's RISK MANAGEMENT PLAN 
EXECUTIVE SUMMARY 
FOR 
Woodbridge Foam Fabricating, Inc. 
 
 
 
1.      Accidental release prevention and emergency response policies. 
 
Woodbridge Foam Fabricating, Inc. as part of the Woodbridge Group of companies, believes the health and safety of its employees and the protection of the natural environment, should be of the utmost concern in the operation of its business.  We are committed to operating and maintaining all of our processes in a safe and responsible manner. 
 
It is our policy to: 
 
* Comply with all applicable laws, regulations, and standards. 
* Review and assess our operations for the purpose of making health, safety & environmental improvements. 
 
Our complete Heath Safety & Environmental policy statement, signed by our plant manager, is posted in the lobby of our facility.  
 
We use a combination of prevention programs and emergency response planning, which are described later in this document, to help ensure the safety of our employees and the pu 
blic as well as protection of the environment. Our Plant Manager has the overall responsibility for ensuring that our facility operates in a safe and reliable manner.  This responsibility includes overseeing the implementation of the elements of our risk management program.  To ensure that our risk management program is appropriately developed and implemented, our Plant Manager has assigned the role of RMP coordinator to a staff member with the background, training, and experience necessary to manage the program. The RMP Coordinator, acting with the authority delegated directly from the Plant Manger, is responsible for coordinating the development, implementation and integration of the RMP elements as is required under Section 68.15 of the RMP rule.  
 
2.      The stationary source and regulated substances handled. 
 
This facilities primary purpose is to produce polyurethane foam for the diaper, automotive, and many other specialty foam markets. Polyurethane foam is manufactured by combi 
ning specific ratios of chemical streams in a mixing chamber where the reacting ingredients are dispensed onto a moving conveyor system.  The reacting mixture cures into the form of a slabstock bun.  The foam buns are fabricated into spools, rolls, and other specialty parts.  Toluene Diisocyanate (TDI), which is regulated by EPA's risk management program rule, is one of the reactants required to manufacture polyurethane foam. TDI is received at the plant by railcar and tanker truck; it is stored in four tanks located in the contained bulk storage tank room.   
 
Access to the site is restricted to authorized facility employees, management personnel, and contractors. The maximum amount of TDI that can be stored at this facility is 420,000 pounds. 
 
 
 
 
3. Off-site consequence analysis scenarios  
 
EPA's RMP rule requires that we provide information about the worst-case release and alternative release scenario's for our facility.  The following are brief summaries of these scenarios, includin 
g information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario.   
 
The methodology used to determine the distance to the toxic endpoint as established by the RMP rule was a technique described in EPA's OCA Guidelines.  In particular, equation D-1 of that guidance document was used to estimate pool evaporation rates based upon information published by the National Institute of Standards. A table using this technique was developed and the specific distances extrapolated from that table. 
 
Worst-case Release Scenario.  
 
Catastrophic failure of a railcar full of TDI at the railsiding, discharging its entire contents of 185,000 pounds as is stipulated in the RMP rule. It is assumed that the maximum temperature the TDI could reach during an unload is 110 degrees F. As there is no containment at the railsiding, it is assumed that a pool with a depth of 1 cm is formed and evaporates to form a cloud that disperses downwind. Meteorolo 
gical conditions of 1.5 m/s and 77 degrees F at 50% relative humidity were used.  An urban environment was assumed due to the characteristics of the local terrain. The distance to the endpoint concentration of 0.007 mg/l is 0.30 miles. A residential population of 470 could possibly be affected by this worst-case scenario event.  There are no environmental receptors impacted by this release.   
 
Alternative Release Scenario.  
 
The alternative release scenario selected consists of a two inch transfer hose rupturing during unloading of a TDI railcar.  The material is released for 5 minutes onto the ground at the railcar unload station until appropriate action is taken to stop the unload process. It was assumed that the temperature of the TDI was 85 degrees F.  Meteorological conditions of 3 m/s and 77 degrees F at 50% relative humidity were used with a class F stability.  An urban environment was assumed due to the characteristics of the local terrain. The following parameters were used in 
performing the projected release. 
 
The temperature chosen for this analysis exceeds both the yearly average ambient temperature and processing temperature.  TDI is top unloaded from a railcar using regulated dry air pressure at 30 psi. Using Bernoulli's equation, the maximum amount of TDI that would be released in a period of 5 minutes from a 2 in hose connected to a railcar is 21,500 pounds. The distance to the endpoint concentration of 0.007 mg/l would be 100 feet. This distance does not reach offsite.  
 
 
4.      The general accidental release prevention program and the specific prevention steps.  
 
We take a systematic, proactive approach to preventing accidental releases of chemicals. Our management systems for our TDI process address each of the key features of successful prevention programs including:   
 
Safety information  
Hazard reviews of our processes 
Operating procedures 
Training 
Equipment Maintenance Program 
RMP Compliance Audits 
Accident/Incident Investigation 
Contractor T 
raining 
Hot Work Permit 
Process Equipment Change 
Emergency Response Program 
 
In addition, we have an established Isocyanate Control Program that outlines the hazards of handling toluene diisocyanate and the controls that are in place to reduce the hazards of isocyanate exposure to the employees, the community and the environment.  Process controls also exist to minimize potential releases (e.g. tank level gauges, high level alarms, high-pressure switches, bursting disk, and system interlocks).   
 
These listed individual elements of our prevention program work together to prevent accidental chemical releases.  Our company and our employees are committed to the standard that these management systems set for the way we conduct business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. 
 
5.      Five-year accident history.  
 
We have not had any TDI releases that qualify for listing in the EPA's required five-ye 
ar accident history report. We have had eight small releases of TDI in the past five years. Each release occurred inside the facility buildings with no resulting injuries, property damage, or environmental impact.  A thorough and complete investigation of each of these releases was conducted in accordance with our accident/incident investigation program, root cause was determined, and appropriate corrective action taken. 
 
6. The emergency response program. 
 
We maintain an integrated contingency plan, which consolidates the various federal, state and local regulatory requirements for emergency response planning.  Our program provides essential planning and training for effectively protecting workers, the public and the environment during emergency situations. We have coordinated our program with the local emergency planning committee and the fire department.  The LEPC, SERC, and local fire department all have copies of an MSDS for TDI and have copies of facility maps which identifies TD 
I unloading, storage, and handling areas. A representative of the fire department routinely visits our plant to discuss emergency response procedures. 
 
The core elements of the emergency response plan identify detailed procedures and protocols to be initiated in the event of a release.  The following responses are addressed in our plan: 
* Proper notifications in the event of a release (internal and external) 
* Systematic shutdown of operations 
* Evacuation of personnel 
* First aid procedures 
* Emergency response team actions 
* Decontamination of personnel and equipment 
* Management of waste material 
* Start up of operations 
* Accident/Incident Investigation 
 
7.  Planned changes to improve safety. 
 
At this time we are continuing to maintain our current safety management systems.  In addition, we are continuing to improve the computerized process control system at the pouring line.  We will evaluate installing additional flow detection devices on critical streams that could result in an  
isocyanate release.  We also anticipate performing additional preventative maintenance inspections on the TDI process.  Additional unload safety controls will also be implemented as outlined in the hazard review along with procedural inspections.
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