Future Foam, Inc. - Executive Summary |
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It is the policy of Future Foam to comply with all applicable federal, state and local regulations. In the event of an emergency at the facility the local EMS system will be contacted for emergency response. Future Foam, Inc. manufactures flexible polyurethane foam bunstock at a facility located at 400 North 10th Street in Council Bluffs, Iowa. The facility is located in an area zoned for manufacturing and is bordered by other manufacturing and a railroad yard. The building is a preengineered steel structure with indoor and outdoor chemical storage. Toluene diisocyanate (TDI) is stored in two (2) tanks, the largest (bulk storage) having a capacity of 32,000 gallons and the other (run) 10,000 gallons. Both tanks are located in the same diked tank farm with a surface area of 1510 square feet and a capacity of approximately 60,000 gallons. The tank farm is located outdoors with the 10,000 gallon tank located inside a building inside the tank farm containment. Product is received b y rail car and unloaded on a siding located on the backside of the facility next to the railroad yard. The rail siding is bermed by the railbeds and the side of the building and has an effective surface area of 3000 square feet and a capacity to hold the entire contents of a railcar. During foam manufacturing, TDI is pumped from the run tank to the process mixer through a closed piping loop. The mixer is an enclosed unit into which TDI and other processing chemicals are mixed and the reaction mixture is then transferred to the foam conveyor line. All TDI pumps and tank valves are located inside the diked area. A review of the foam manufacturing process was conductred to determine applicability of Part 68 regulations to this facility. It was determined that the facility contains one process with more than the threshold quantity of the regulated substance toluene diisocyanate (TDI) according to 68.115. According to 68.10(b) the facility fulfills the requirements as a Program 1 fac ility since: - there have been no accidental releases of TDI in the past five years, - the worst-case release distance to the toxic endpoint does not impact a public or environmental receptor, - and emergency response has beeen coordinated with the Council Bluffs Fire Department and information about chemicals onsite has been reviewed with the local emergency management coordinator. The value reported in Section 2.6 is overstated since RMP*Submit will not accept the values modeled by ALOHA, a publically available and widely used by emergency response agencies modeling program. ALOHA modeled a release rate of 0.0499 pounds/minute which is lower than that reported in Section 2.6. The "Worst Case Scenario" for this facility, as defined in 68.3 as "the release of the largest quantity of a regulated substance from a vessel or ... that results in the greatest distance to an endpoint ..." would be the catas trophic failure of a 20,000 gallon (190,000 pound) railcar of TDI. Such a failure pre-defined by EPA would release the entire liquid contents into a 3000 square foot bermed puddle in 10 minutes. The release to the atmosphere was modeled using ALOHA and the following factors: - puddle size = 3000 square feet - liquid temperature = 100F - atmospheric temperature = 100F - wind speed = 1.5 M/s - relative humidity = 50% - cloud cover = 50% - stability class = F - urban topography - release duration = 60 minutes - toxic endpoint = 0.007 mg/L (Part 68 Appendix A) - evaporation from a 3000 square foot puddle The model calculated a release reate of 0.0499 pounds/minute over a period of 60 minutes which resulted in a total release of 2.58 pounds of TDI. The distance to the Level of Concern endpoint of 0.007 mg/L was calculated as 29 yards (0.016 miles ). This distance does extend offsite but does not impact any public or environmental receptors. The release rate for TDI is such that the release duration would exceed 60 minutes therefore ALOHA calculates the maximum release to be 60 minutes assording to Section 2.7 of the RMP*Submit User's Manual. In the event of a "Worst Case Release" Future Foam would notify the Council Bluffs Fire Department and the current TDI supplier to the facility. The fire department has inspected the facility and scenarios have been discussed with the HazMat team. Active mitigation of such a release could be accomplished by covering the puddle with plastic or water to minimize evaporation. Release prevention is accomplished through a series of active and passive methodologies. Passive mitigation is accomplished by the rail siding unloading area berming which limits the surface area of the pool to 3000 square feet and will contain the entire volume of a railcar. Additional work is being conducted to further limit the puddle surface area. Active mitigation controls include top-unloading of railcars, pipline valving, tank high level alarms and pump operational monitoring systems. Administrative controls include periodic tank level inventories prior to unloading railcars, railcar inspections, general inventory controls, physically monitoring tank valve operation and preventative maintainence. All personnel associated with the foam production operation have received training on the proper handling and use of TDI including unloading operations. |