Foamex LP - Executive Summary

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Accidental release prevention and emergency response policies 
At the Foamex LP Plant in Compton, CA, we handle toluene diisocyanate (TDI), which is considered hazardous and regulated by the EPA.  The same properties that make TDI valuable for use at our facility also make it necessary to observe certain safety precautions in the handling of the substance.  Safety precautions have been implemented to prevent unnecessary human exposure, to reduce the threat to our own personal health as well as our co-workers, and to reduce the threat to nearby members of our community.  It is our policy to adhere to all applicable federal and state rules and regulations. 
We are committed to the safety of our employees and the public, and to the preservation of the environment, through the prevention of accidental releases of hazardous substances.  Successful implementation of our accidental release prevention program will help ensure that emergencies are unlikely and reduce the like 
lihood that emergency response procedures will be needed.  Nevertheless, an emergency such as a release of TDI is possible.  We have emergency response procedures to help ensure that accidents will be mitigated properly without undue risk to the public, environment, employees, contractors, or other personnel within the plant. 
Description of the facility and the regulated substances handled 
The primary purpose of this facility is to produce flexible polyurethane foam, which is sold to other facilities and used to produce bedding, furniture, and packaging and a number of other products.  TDI is one of the reactants required to produce polyurethane foam.  TDI is received by rail car and by tank truck, and is stored in a 30,000-gallon outdoor storage tank.  The maximum quantity of TDI stored in rail cars and in storage tanks at our plant is approximately 500,000 pounds.  The TDI is piped to a mix head where it is mixed with other reactants to produce a slab of polyurethane foam.  The foa 
m is conveyed to cutting stations where it is cut to the size and shape specified by our customers. 
TDI is the only substance handled at our plant that is regulated by EPA's risk management program (RMP) rule.  TDI is covered because the maximum quantity stored onsite exceed EPA's threshold quantity (TQ) of 10,000 pounds. 
Offsite consequence analysis of release scenarios 
An offsite consequence analysis (OCA) was performed to estimate the potential for an accidental release to affect the public or the environment.  The OCA consists of evaluating worst case release scenarios (WRSs) and alternative release scenarios (ARSs).  We do not expect a worst case release scenario to ever occur.  An ARS represents a release that might occur during the lifetime of a facility like ours.  ARSs help us to work with the local emergency planning committee (LEPC) to improve the community emergency response plan. 
The main objective of performing the OCA is to determine the distance at which certain eff 
ects might occur to the public because of an accidental release (called the endpoint distance).  The following effects could occur at the endpoint distance: 
7 Most people at the endpoint distance of a TDI release would be able to walk away from the exposure without any long-term health consequences, although some short-term consequences (e.g., strong eye or throat irritation) are likely.  Some people who are particularly susceptible to the released substance could be incapacitated. 
Worst case release scenarios.  Catastrophic failure of a TDI railcar, having a capacity of 200,000 lbs. TDI, would be a worst case release for a toxic substance because a TDI railcar is the largest outdoor TDI container that is not in a diked area at the plant.  The TDI vendors limit the quantity of TDI loaded into a railcar to 190,000 lbs. maximum to allow space for thermal expansion during possible heating of the TDI.  During cold weather, we pre-heat the TDI to a maximum temperature of 67 0F to facilita 
te unloading and prevent TDI solidification.  During hot weather, the TDI temperature could reach the maximum ambient temperature of 95 0F.  Because a release at a higher temperature will result in the greatest endpoint distance, we assumed the release would occur at 95 0F.  We also assumed that the entire contents of the railcar would be released as a liquid, form a pool that would spread to cover an area of approximately 76,000 ft2 with a depth of about 0.4 inches (1 cm), and evaporate to form a cloud that would disperse downwind.  Dispersion modeling predicts a distance of 0.3 miles from the rail car to the TDI toxic endpoint concentration of 0.98 ppm (0.007 mg/L). 
Alternate Release Scenarios.  Rupture of the transfer hose from the railcar to the TDI storage tank loading line would release TDI to the ground at the rate of 6,076 LB/min.  We assumed that the release would continue for the 10 minutes required for an employee to stop the flow of compressed air.  The resulting pool woul 
d spread to cover an area of approximately 24,300 ft2 with a depth of 0.4 inches and evaporate to form a cloud that would disperse downwind.  Dispersion modeling predicts a distance of less than 0.1 miles from the pool to the TDI toxic endpoint concentration of 0.98 ppm. 
The general accidental release prevention program and specific prevention steps 
The plant has implemented programs and procedures that comply with EPA's Level 2 Accidental Release Prevention Program Rule.  Our facility qualifies for Level 2 coverage because (1) our worst case release scenarios for TDI can impact persons across the property boundary of the nearest public receptor, and (2) TDI is not a substance covered by OSHA's process safety management standard (PSM).  Our accidental release program is designed to systematically accomplish the following functions: 
- Control the creation and retention of safety information regarding the regulated substances, processes and equipment 
- Conduct hazard reviews to identi 
fy, evaluate, and control process hazards associated with the regulated substances, processes, and procedures 
- Create, maintain, and evaluate operating procedures for activities within or near processes that use regulated substances 
The general accidental release prevention program and specific prevention steps (continued) 
- Provide training for personnel who operate covered processes so that they safely perform their jobs 
- Monitor and control maintenance activities that can affect the mechanical integrity of equipment used in covered processes 
- Confirm through compliance audits that RMP practices at the plant are consistent with our written programs and that the programs are adequate to address all of the requirements of the RMP rule 
- Ensure that process incidents, particularly those of catastrophic magnitude or potential, are thoroughly investigated using our incident investigation procedures and that relevant findings are communicated throughout the company to help prevent rec 
The TDI process at our plant has hazards that are carefully managed to ensure continued safe operation.  The prevention program outlined above is applied to the TDI process.  Collectively, these prevention program activities help prevent potential accidental releases that could be caused by equipment failures, human errors, and by management system failures. 
In addition to the accidental release prevention program, our plant has safety features on many units to help (1) contain or control a release, (2) quickly detect a release, and (3) reduce the consequences of or mitigate a release.  The following types of safety features are used in various units of the TDI process: 
Release detection  
- Process alarms 
Release Containment/Control 
- Curbing or dikes to contain TDI liquid releases 
- TDI storage tank located inside a diked area 
- Automated shutdown systems for critical process parameters (e.g., high level, high pressure 
- Pressure/vacuum relief devices on vesse 
ls to prevent rupture or collapse 
- Magnetic drive TDI centrifugal pumps without seals 
- Valves to permit isolation of the process 
- TDI railcar inner tank is surrounded by an outer shell filled with insulation 
- TDI railcars are top unloaded through a nozzle in the top of the tank 
The general accidental release prevention program and specific prevention steps (continued) 
Release Mitigation 
- Fire suppression and extinguishing systems 
- Trained emergency response personnel 
- Personal protective equipment (e.g., protective clothing, self-contained breathing apparatus, breathing air stations) 
Five-year accident history 
We have had no releases of TDI in the last 5 years that resulted in deaths, injuries, or significant property damage on site, or known deaths, injuries, evacuations, sheltering-in-place, property damages.  We have had 1 small release of TDI over the past 5 years.  This release occurred outside, inside of a fully contained area and was too small to result in injuri 
es or significant damage. 
Emergency Response Program 
Our emergency response program is based on the requirements in OSHA's emergency action and fire prevention plan regulation, OSHA's hazardous waste and emergency operations regulation, and EPA's emergency response program requirements in its RMP rule.  Our program consists of procedures for responding to a release of TDI.  The procedures address all aspects of emergency response, including proper first aid and medical treatment for exposures, evacuation plans and accounting for personnel after an evacuation, notification of local emergency response agencies and the public if a release occurs, and post-incident cleanup and decontamination requirements.  In addition, the plant has procedures that address maintenance, inspection and testing of emergency response equipment.  Employees receive training in these procedures as necessary to perform their specific emergency response duties.  The emergency response program is updated when nec 
essary, based on modifications made to plant processes or other facilities.  Personnel affected by changes in the program are informed and or trained on those changes. 
The overall emergency response program for the plant is coordinated with the LEPC.  This coordination includes participation in periodic meeting of the committee, which includes local emergency response officials, local government officials, and other industry representatives.  The plant has around-the-clock communications capability with the appropriate LEPC officials and emergency response organizations such as the fire department.  This provides a means of notifying the public of an incident, if necessary, as well as facilitating quick response to an incident.  The plant also conducts periodic emergency drills that involve the LEPC and emergency response organizations. 
Planned changes to improve safety 
We strive to continuously improve the safety of our plant TDI process through periodic safety reviews and a progra 
m of soliciting safety suggestions from employees.  Our hazard review and incident investigation programs are especially designed to identify needed process safety improvements, some of which result in changes to the processes.  The following changes are currently planned for implementation: 
' Upgrade inspections and tests of selected equipment and instrumentation designed to prevent TDI releases. 
' Consider further examination of process safety shutdown interlocks for possible implementation. 
' Continue the enhancement of process safety employee training.
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