| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

1.Accidental release prevention and emergency response policies. 
The Whitmore Lake Plant, 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 to help ensure the safety of our employees and the public 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 Manager, 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. 
The primary purpose of the Whitmore Lake Plant is to produce polyurethane foam seat cushions for the automotive industry. The foam is made by high pressure mixing of chemicals immediately prior to pouring the mixture into a mold  
that is attached by carrier to a continuously moving line. The mold moves through a curing oven. Upon exiting the oven, the foam pads are removed from the mold, crushed, trimmed and prepared for shipment to customers. 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 3 tanks located in the contained bulk storage tank room inside our plant. The TDI is then transferred to the process utilizing a computer-controlled system.  
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 337,000 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 sum 
maries of these scenarios. 
The methodology used to determin the distance to the toxic endpoint as established by the RMP rule was the Area Locations of Hazardous Atmospherse (Aloha) version 5.2.1. for plume modeling.  Meteorological information was obtained from the National Weather Service and from the National Climatic Data Center. Meteorological conditions of 1.5 mph and 96 degrees F at 72 % relative humidity were used.  An urban environment was assumed due to the characteristics of the local terrain. 
Worst-case Release Scenario.  
Catastrophic failure of a railcar full of TDI at the railsiding, discharging its entire contents of 200,000 pounds as is stipulated in the RMP rule. It is assumed that the maximum temperature the TDI could reach during an unload is 140 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. The distance to the endpoint concentration of 0.007  
mg/l is 648 feet or  0.12 miles. A residential population of 1870      could possibly be affected by this worst-case scenario event.   
Alternative Release Scenario.  
The valve on a pressurized railcar leaks resulting in a loss of 80,000 pounds of TDI. It is assumed that the temperature of the TDI would be 110 degrees F.  The resulting liquid forms a pool with a depth of 1 cm that evaporates to form a cloud, which disperses downwind. It is assumed that this scenerio happens when no one is in attendance at the rail siding. The distance to the endpoint concentration of 0.007 mg/L is 354 feet or 0.067 miles. No residential population will be affected by this scenario. 
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  
ard reviews of our processes 
Operating procedures 
Equipment Maintenance Program 
RMP Compliance Audits 
Accident/Incident Investigation 
In addition, we have an established Isocyanate Control Program which outlines the hazards of handling toluene diisocyanate and the controls which are in place to reduce the hazards of isocyanate exposure to the employees, the community and the environment. 
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-year accident history report.   We have had four small releases of TDI in the past five years. Each release  
occurred inside the facility buildings and was contained and controlled as a result of our emergency planning and trained responders.  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 provided 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. A representative of the fire department routinely visits this plant to discuss how to respond to a release of TDI.  We have also given local hospitals information regarding medical treatment for exposure to TD 
7. Planned changes to improve safety. 
At this time we are continuing to maintain our current safety management systems.  We are investigating the possibilities for containment of our railsiding and tanker truck unloading areas. Due to the extensive funding and approval process this may take several years to implementation. We also anticipate improving our procedures and training programs in the area of specific maintenance tasks. In addition we need to obtain additional ifomration regarding equipment specifciations and integrity.  We have also developed or improved our process procedures for several tasks.
Click to return to beginning