Kansas City Foam - Executive Summary

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WoodBridge Corporation 
Kansas City Foam 
 
a.)  Accidental release prevention and emergency response policies at the stationary source 
 
The Kansas City Foam 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 responsable 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 and environmental    
       improvements 
 
Our complete Health Safety and 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 the document, to help ensure the safety of our employees and the public as 
well as protection 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 implemented, our plant manager has assigned the role of RMP coordinator to the process manager who has the background, training, and experience necessary to manage the program.  The RMP coordinator, acting with the authority delegated by 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. 
 
b.) The stationary source and regulated substances handled. 
 
The primary purpose of the Kansas City plant is to produce polyurethane foam seat cushions for the automotive industry.  The foam is made by high pressure mixing of chemicals immediatel 
y 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 recieved at the plant by rail car and tanker truck.  It is stored in two bulk tanks located in the contained bulk storage tank farm.  The TDI is then transferred to the process by an automated system.  Access to the tank farm is restricted to authorized employees, management personnel, and contractors.  All personnel must use the buddy system when entering the tank farm area.  The maximum amount of TDI that can be stored at the facility is approximately 430,000 lbs. 
 
c.)  Off-site conssequence analysis scenarios 
 
EPA's RMP rule requires that we provide information abou 
t the worst-case release and alternative release scenarios 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 was Aloha version 5.2.1 software for plume modeling.  Atmospheric conditions were obtained from the NCDC for the Kansas City Internatiional airport located approximately 15 miles north west of our facility.  Parameters used for the model were 98 degrees Fahrenheit air temperature, 54% relative humidity, 1.5 m/s winds from the north east, and class F stability. 
 
Worst-case Release Scenario 
Catastrophic failure of a rail car full of TDI at the rail siding, discharging its entire contents of 200,000 pounds in 10 minutes, as is stipulated in the RMP rule.  It is assumed that the maximum temperature the TDI could reach during an unload is 120 degrees F.  As th 
ere is no containment at the rail siding, it is assumed that  a 77,000 square foot pool with a 1 cm depth is formed and evaporates to form a cloud that disperses downwind.  The distance to the endpoint concentration of .007 mg/l is 217 yards.  There is no residential population within this endpoint distance, as the Kansas City Plant is located in the Platte Valley Industrial Park.  Total park working population is approximately 1190 people. 
 
Atlernative Release Scenario 
Catastrophic failure of a tank truck full of TDI at the Truck unloading site, dischargine its entire contents in 10 minutes.  The resulting liquid forms a pool with and area of 18,500 square feet and a depth of 1 cm that evaporates to form a cloud that disperses downwind.  The distance to the endpoint concentration of .007 mg/L is 120 yards, and would not affect any residential areas. 
 
d.)  The general accidental release prevention program and the specific prevention steps 
 
We take a systematic approach to preventing ac 
cidental 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 
Monthly physical safety audits 
In addition, we have an established Isocyante Control Program which outlines the hazards of handling toluene diisocyanate and the controls which are in place to reduce the hazards of isocyanate exposure to the employees, the community and the environment.  Monitors are used in the process and storage areas to constantly check for any leaks, and a visual system is in place that allows remote inspection of tanks.  As well, a buddy system is used in the unloading and tank farm areas to aid in accidnent prevention. 
These listed individual elements of our prevention program work together to prevent accidental chemical releases.  Our company and ou 
r 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. 
 
e.) 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 one small release of TDI in the past five years with no resulting injuries, property damage, or environmental impact.  A thorough and complete investigation for this release was conducted in accordance with our accident/incident investigation program, root cause was determined, and appropriate corrective action was taken. 
 
f.) The emergency response program 
 
We maintain an integrated contingency plan which consolidates the various federal, state, and local regulatory requirements for emergency response planning.  The emergency response program was developed with the aid of Management Strategies 
Group, Inc., and was designed to meet OSHA 29 CFR 1910.120 (q) requirements.  Our program provides essential planning and training for effectively protecting workers, the public and the environment during emergency situations.  We have coordinated our program with the Mid America Regional Council LEPC and the Riverside Fire Department.  We have also given local hospitals information regarding medical treatment for exposure to TDI. 
 
g.)  Planned changes to improve safety 
 
The most recent review conducted at the Kansas City Plant has led to the planned implementation of a timed boiler shut off switch, pressure relief valves in the tank and truck unloading air supply, improved check lists, and supplied air has been installed at the unloading sites to eliminate the need for SCBA's.  At this time we are continuing to maintain our current safety management systems, and in addition we are investigating the possibilities for containment of our rail siding.  As well, we will continue to improv 
e the process and handling control systems as outlined in our hazard review.
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