North Carolina Foam Industries - Executive Summary |
|
North Carolina Foam Industries (NCFI) is a flexible polyurethane foam manufacturer. Flexible polyurethane foam is primarily used as a cushioning material in the bedding and furniture industries. NCFI receives liquids by truck trailer and rail tank car. The liquids are received and stored in tanks with secondary containment. The flexible polyurethane foam is manufactured by a process that combines these liquids and forms the solid foam through a reaction of the blended liquids on a manufacturing process called a pourline. The foam is then cured, stored, fabricated, and shipped to supply customer demand. One of the liquids that is a component of the foam process is call toluene diisocyanate (TDI). This is the only material used in a process at NCFI that requires this Risk Management Program. NCFI has a successful accidental release prevention program that is composed of both physical and procedural elements. NCFI has maintenance programs that keep all tanks (primary containment) in excellent condition. Furthermore there is passive secondary (pits and walls surrounding the tanks) and active tertiary containment (culvert plugs and gates in drainage system) that will hold materials lost from a catastrophic failure of the primary containment. NCFI has spill response programs that are designed to provide materials and procedures to handle small incidental releases. These programs are a material part of the job of personnel that are responsible for handling the liquids in our production operation. There is decontaminating solution and absorbent materials readily available in convenient location through out the areas of the process. NCFI has developed Emergency Response Procedures and coordinated these procedures with the City of Mount Airy Fire Department to respond to any significant releases of TDI. The City of Mount Airy is party to a Mutual Aid agreement with Surry County and State of North Carolina Emergency Response agencies to respond to any major incide nts occurring at NCFI's location. In addition, the North Carolina Emergency Response Commission's regional Hazardous Material Response Vehicle is stationed just 5 minutes from NCFI's facility. NCFI is proud of their accident free record and incidents of released material. During the last five years there has been no accident or incident involving a reportable release of the TDI material. NCFI's Worst Case Scenario was determined to be the loss of the entire contents of the largest storage vessel of the TDI material into the vessel's secondary containment. The containment area acts to reduce the release rate of TDI to the atmosphere. The ALOHA model was used to model this release and showed that there would be no off site areas, no Public Receptors, and no environmental receptors located within the maximum distance endpoint for TDI. Therefore NCFI qualifies for Program 1 of RMP. The RMP Submit Program only allows reports of one or more pounds of emissions per minute to be reco rded. NCFI's actual release rate is only 0.0295 pounds per minute for a total release of only 1.77 pounds for the release duration. A professional consulting firm that specializes in environmental issues modeled our scenario. NCFI has an ongoing program that support the constant process of maintaining, improving, and re-evaluating our safety, emergency, and operational procedures to insure their effectiveness. By meeting the Program 1 eligibility requirements, NCFI believes that the existing safety program is adequate. However, if any changes occur in the future that impacts the TDI process, these changes will be thoroughly revised to insure that the safety of NCFI's employees and neighbors is not compromised. |