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

1. Accidental release prevention and emergency response policies. 
   The Romulus 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 Health, Safety & Environmental policy statement, 
signed by our plant manager, is posted in the lobby of our 
   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 public as 
well as prot 
ection of the environment.  Our Plant Manager has 
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 
2. The stationary source and regulated substances handled. 
   The primary purpose of the Romulus 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 pou 
ring 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 2 tanks 
located in the contained bulk storage tank room.  The TDI is 
then transferred to the process utilizing a computer-controlled 
   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 200,000 
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, 
including information about the key administrative controls and 
mitigation measures to limit the exposure distances for each 
   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.  
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.  The Aloha 
disperson model was also used as a verification of the tabular 
Worst-case Release Scenario:   
   Catastrophic failure of a TDI storage tank full of TDI inside 
the building, discharging its entire contents of 
100,000 pounds 
in 10 minutes, as is stipulated in the RMP rule.  It is assumed 
that the maximum temperature the TDI could reach during an 
strorage is 120 degrees F.  There is containment in the tank 
farm which would form a pool of 2378 square feet with a max 
depth of 7 feet.  The distance to the endpoint concentration of 
0.007 mg/l is 102 feet.  This distance is less than the distance 
to the nearest public receptors. 
Alternative Release Scenario:  
   Although, the worst-case Scenario results, and the five year 
accident history, put this process as a program one, a second 
scenario involving a hose rupture during a tanker truck off-load 
was also completed.  Again, the distance was less than 102 feet 
(worst case) and therefore less than teh distance to the nearest 
public receptors. 
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 
our TDI process address each of the key features of successful 
prevention programs including:   
Contractor use 
Hot work permits 
Safety information 
Hazard reviews of our processes 
Operating procedures 
Equipment Maintenance Program  
Accident/Incident Investigation 
Inventory Control 
   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.   

6. The emergency response program. 
   We maintain an integrated contingency plan, which consolidates 
the various federal, state and local regulatory requiremen 
ts 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 visits this plant to discuss how to respond 
to a release of TDI.   
7. Planned changes to improve safety. 
   At this time we are continuing to maintain our current safety 
management systems.  We also anticipate improving our training 
programs in the area of specific maintenance tasks.  Our efforts 
are aimed more towards ensuring the saftey of our workers, since 
our calcualtions show no risk to the public.
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