Woodbridge Corporation - Brodhead - Executive Summary |
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EPA's RISK MANAGEMENT PLAN EXECUTIVE SUMMARY FOR WOODBRIDGE - BRODHEAD 1. Accidental release prevention and emergency response policies. The Woodbridge - Brodhead facility, 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: v Comply with all applicable laws, regulations, and standards. v Review and assess our operations for the purpose of making health, safety & environmental improvements. Our complete Heath 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 p rotection 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 implements, 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 Manger, 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 - Brodhead facility is to produce polyurethane foam seat cushions for the automotive industry. The foam is made by high pressure mixing of chemicals immediate ly 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 railcar and tanker truck. It is stored in four 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 328,000 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 102 degrees F at 50% relative humidity were used. A rural / open environment was assumed due to the characteristics of the local terrain. Worst-Case Release Scenario Catastrophic failure of a railcar full of TDI at the railsiding, discharging its entire contents of 200,000 pounds in 10 minutes, as is stipulated in the RMP rule. It is ass umed that the maximum temperature the TDI could reach during an unload is 120 degrees F. As there is no containment at the railsiding, it is assumed that a pool with a depth of 1 cm is formed and evaporates to form a cloud that disperses downwind. The distance to the endpoint concentration of 0.007 mg/l is 0.30 miles. A residential population of 150 could possibly be affected by this worst-case scenario event. Alternative Release Scenario An accidental railcar movement that severs 2-inch hose would trigger a release of TDI. The hose line rupture is recognized after 5 minutes. The resulting liquid (3,000 lbs.) forms a pool with a depth of 1 cm that evaporates to form a toxic cloud, which disperses downwind. The distance to the endpoint concentration of 0.007 mg/L is 110 yards. This release has the possibility of extending beyond the facility boundary. 4. The general accidental release prevention program and the specific prevention steps. We take a systematic, proactive approac h to preventing accidental releases of chemicals. Our management systems for our TDI process address each of the key features of successful prevention programs including: Safety information Hazard reviews of our processes Operating procedures Training Equipment Maintenance Program RMP Compliance Audits Accident/Incident Investigation Contractor Use Program Hot Work Permit 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. We have had three 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 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 safet y. At this time we are continuing to maintain our current safety management systems. In addition, we are investigating the possibilities for containment of our railsiding and truck unloading areas and continue to improve the computerized process control system as outlined in our hazard review. We also anticipate improving our training programs in the area of specific maintenance tasks. |