Flexible Foam Products, Inc. - Executive Summary

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2626 Murphy Road 
Portage, WI  53901 
Flexible Foam Products, Inc. (FFP) owns and operates a polyurethane foam manufacturing facility in Portage, Wisconsin.  FFP receives raw materials at its facility, mixes the materials to produce a polyurethane foam bun on a foam production line.  The foam is then cured and stored on site prior to shipping to customers.  Some limited fabrication takes place at the facility.  The polyurethane foam produced by FFP is used in many common household products, including seat cushions, bedding and pillows, and many automotive products where soft foam cushions are required. 
One of the components used in the production of polyurethane foam is toluene diisocyanate (TDI).  This compound is subject to EPA's Risk Management Rule. 
Toluene diisocyanate is delivered to the Murphy Road facility in tank trucks.  The trucks are off-loaded to a storage tank located inside the building.  Because the storage of TDI takes  
place inside the building, the probability of release of toluene diisocyanate vapors into the atmosphere is reduced.  As a result, the impact of such a release on the surrounding community is minimized.  There are no receptors (buildings and people other than the FFP facility) that would be impacted by the release of stored TDI. 
Because there are no public receptors and there have been no significant accidents of release in the last five years, FFP's Murphy Road facility is classified as a "Program 1" facility. 
*    Instantaneous failure of the tank wall 
*    Worst-case weather conditions (stable, low wind speed) 
*    Instantaneous release of entire contents of tank ( 125,000 lbs. ) 
Distance:    13 yards (39 feet) 
This release scenario has a toxic level of concern end point that is on FFP's property.  Based on computer modeling (using an EPA-approved model) of a catastrophic release of TDI as described above,  
it would not impact any person standing or driving outside the boundary of the FFP's property.  Any person visiting or working at FFP would be advised of the proper response action through the company's emergency response procedures. 
Section 2.6 release rate: 
FFP modeled with Aloha 5.2,  the release rate calculated was 0.00147 pounds per minute.  Due to EPA's RMP Submit program not accepting more than 1 significant figure a factor of 0.2 was entered.  Based on the modeled release rate FFP is a Program 1 facility, independent of the value entered into RMP Submit. 
FFP takes safety very seriously.  We use safety equipment and strict procedures to prevent releases and to reduce the impact of any release that might occur.  Some examples are: 
   -Safety controls such as warning alarms, and automatic shutdowns {to be added shortly}. 
   -Regular equipment inspections and maintenance to ensure proper operation. 
of all incidents to improve our procedures. 
   -Secondary containment to ensure that the contents of hazardous material remain on site. 
   -Hazardous Waste and Hazardous Materials, Emergency Contingency Planning. 
   -Hazardous Materials Awareness Training 
   -Hazardous Materials Response Training 
FFP's personnel are regularly trained and drilled on safety and accident prevention.   
The following programs are in place to respond to a release of hazardous material. 
   - Columbia County Hazmat Response Team 
   - WDNR Emergency Response Team 
No significant accidents or releases in past five years.
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