Woodbridge Corporation - Executive Summary

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1. Accidental release prevention and emergency response policies. 
   The Woodbridge Corporation in Fremont, Ohio, 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 and environmental improvements. 
   Our complete Health Safety and 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 em 
ployees 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 Woodbridge Corporation in Fremont, Ohio is to produce polyurethane foam seat cushions for the automotive industry.  The foam is m 
ade 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 tanker truck.  It is stored in Tank #1 and Tank #2 located in the contained bulk storage room.  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 the facility is 125,000 pounds. 
3. Off site consequence analysis scenarios 
   EPA's RMP rule requires the we provide information about the worst case release sce 
nario for our facility.  The following is a brief summary of this scenario, including 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 computer program called Areal Locations of Hazardous Atmospheres (ALOHA().  Based on the scenario requirements of the RMP rule data was input into the ALOHA( Model to estimate the pool evaporation rate.  Meteorological conditions of 1.5 mph and 98(F at 51% relative humidity were used.  An urban environment was assumed due to the characteristics of the local terrain. 
   Worst-case Release Scenario.  Catastrophic failure of storage tank "Tank #1" full of TDI, discharging its entire contents of 81,000 pounds in 10 minutes, as is stipulated in the RMP rule.  It is assumed that the maximum temperature the TDI could reach during storage is 98(F.  There is a containment dyke for t 
he bulk storage tanks, it is calculated that a pool with a depth of 2-1/2 feet is formed and evaporates to form a cloud that disperses downwind.  The distance to the endpoint concentration of 0.007 mg/l is 42 feet.  No residential population, public receptor or environmental receptors would to be affected by this worst-case scenario event. 
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 system for our TDI process addresses each of the key features of successful prevention programs including an Emergency Response Plan and Accident/Incident Investigation Program. 
   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 including:  monitors, int 
erlocks and controlled limits. 
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 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 was 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 TDI. 
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 as outlined in our Hazard Review.
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