General Foam -East Rutherford, LLC - Executive Summary |
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General Foam strives to conduct its business in a socially responsible and ethical manner with a positive commitment to protect people and the environment. Our managers are responsible for maintaining an awareness of applicable environmental, safety and health laws and regulations with the assistance of our Corporate Regulatory Affairs Department and conducting day-to-day activities required for compliance with these laws and regulations. General Foam believes that its policies and principles can be most effectively implemented by using a risk management approach to identify and prioritize potential problems, determine the probability of problems occurring, exploring alternative solutions and taking action where appropriate. General Foam manufactures flexible polyurethane foam by mechanical mixing of polyol resins with toluene diisocyanate (TDI mixed isomers) along with water, catalysts, surfactants, pigments, and other chemical compounds. The facility stores TDI in 3 indoor above-g round bulk storage tanks in a separate tank room. TDI is delivered via railcar and stored in an attached indoor railcar unloading building and occasionally by tank truck and unloaded in a designated diked area just outside the tank room. The General Foam-East Rutherford, LLC facility has implemented an accidental release prevention program which includes Process Safety Information according to a documentation plan. Process hazard analyses are conducted on a five year schedule or as required by a process hazard analysis team. The team is organized by a Process Risk Management Consultant and is typically composed of a team leader, process engineer, maintenance engineer, production engineer, regulatory affairs manager, and any other employees that may contribute to the analyses. Results and recommendations are recorded on a computerized HAZOP database program. Standard Operating Procedures (SOPs) are written by the Regulatory Affairs Manager using the technical process description in cooperation with the production managers, plant engineer and their management staffs. All existing SOPs are checked and verified for correctness once a year by these staff members. The SOPs are available throughout the plant via postings, manuals, and on the computer network. Training is formulated, tracked, and documented by the Regulatory Affairs Manager according to a training matrix individualized for each department's requirements. Understanding the training is assured by on the job observation, written tests, oral exams and demonstration of a person's job performance skills. The Preventive Maintenance/ Mechanical Integrity Program is delegated to the Plant Engineer. The program consists of equipment lists and specifications, instrument lists and specifications, pipeline lists and specifications, equipment history of repair and replacement, preventive maintenance procedures and demand work order procedures. Equipment and instrumentation reliability history is documented an d analyzed yearly. Work permits, hot work permits, and lockout/tagout are used in conjunction with the program. The Management of Change Program is quality assured by the facility's department managers. It is composed of a written program with elements to assure that repairs and replacements are documented and completed according to corporate guidelines. Compliance audits are conducted by the Regulatory Affairs Manager in cooperation with the facility managers and supervisors. Deficiencies are documented, scheduled for improvement and monitored by the Regulatory Affairs Manager. The Incident Investigation Program follows guidelines for fact determination, root cause analysis, and recommendation review, implementation and documentation. The Program is monitored by the facility's management staff. Employee participation is encouraged in each element program description. The Contractor Program follows corporate policy and is implemented by the facility management staff. Three hundre d sixty thousand pounds of toluene diisocyanate mixed isomers (TDI) is inventoried for the manufacture of flexible polyurethane foam on two production lines. The Worst Case toxic maximum computed release rate scenerio of TDI is calculated at 0.0117 lbs/min by ALOHA software for a railcar release in the unloading builing attached to the back of Building # 2. The Alternate Case toxic maxium computed release scenerio of TDI is calculated at 0.0274 lbs/min by ALOHA software for a storage tank release in the tank room enclosed in the front of Building # 3. Release prevention and chemical specific prevention used at the facility are relief valves, check valves, manual and automatic shutoffs, scrubbers, interlocks, audible and visual alarms, TDI handling SOPs, bypass piping system, emergency self-contained and forced air breathing supplies, grounding equipment, rupture disks, relief valves, and blowout containers. Mitigation systems used are sprinkler systems, firewalls, and chemical neutr alization. The process and unloading areas can be monitored by portable TDI detection devices. Operator training and refresher training are conducted as needed or on a yearly basis. The facility has not had any accidental releases in the last five years. The facility's Emergency Response Program was designed and updated according to the EPA Integrated Contingency Plan Guidance. The plan defines the response organization, coordination with city, county, state, and contracted emergency response organizations, equipment available on-site, response procedures, training, notification procedures, emergency scenerios, and drills.The plan is updated periodically according to our requirements or from deficiences uncovered from periodic tabletop and actuall drills. The facility plans no safety improvements at this time since all current state-of-the-art for design and operation is implemented. |