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
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
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
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:
Hot work permits
Hazard reviews of our processes
Equipment Maintenance Program
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
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.