WOODBRIDGE ROMULUS CORPORATION - Executive Summary |
EPA's RISK MANAGEMENT PLAN EXECUTIVE SUMMARY FOR ROMULUS PLANT 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 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 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 rule. 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 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 200,000 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 summaries of these scenarios, 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 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 data. 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 for 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 Training 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. |