Flexible Foam Products, Inc. - Executive Summary |
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Flexible Foam Products, Inc. owns and operates a polyurethane foam manufacturing facility at 1900 W. Lusher Avenue in Elkhart, Indiana. Flexible Foam receives raw materials at its facility, mixes the materials to produce a polyurethane bun on a foam production line. The bun is then cured and stored on site prior to shipping to customers. Some limited fabrication takes place at the facility. The polyurethane foam produced by Flexible Foam is used in many common household products, including seat cushions, bedding and pillows, and many other products where soft foam cushions are required. One of the components used in the production of polyurethane foam is toluene diisocyanate (TDI). This compound is subject to EPA's Risk Management Rule. Toluene diisocyanate is delivered to the Lusher Avenue facility in tank trucks. The trucks are off-loaded to a storage tank located inside the building. Because the storage of TDI takes place inside the building, the probability of release of toluene diisocyanate vapors into the atmosphere is reduced. As a result the impact of such a release on the surrounding community is minimized. There are no receptors (buildings or people other than the Flexible Foam facility) that would be impacted by the release of stored toluene diisocyanate. Because there are no public receptors and there has been no incidents of release in the last five years, Flexible Foam's Lusher Avenue facility is classified as "Program 1" facility. The release of TDI from the Flexible Foam's Lusher Avenue facility is mitigated by concrete containment located inside a building. The modeled release of TDI (using Aloha 5.2) results in an endpoint of 33 ft. This endpoint is on Flexible Foam's property and does not impact any public receptors. RMP*submit would not allow the entry of the correct modeling data for the worst case release scenario. After contacting the 112r hotline, Flexible Foam was advised to enter minimum default data in the submit forms an d clarify the modeling results in the executive summary. The following information presents the results of the modeled release of 6500 gal of TDI at Flexible Foam. MODEL: ALOHA 5.2 ATMOSPHERIC INFORMATION: Wind: 1.5 meters/sec from 90 degrees true at 10 meters No Inversion Height Stability Class: F Relative Humidity: 50% Cloud Cover: 5 tenths Air Temperature: 100 degrees F Ground Roughness: Open Country SOURCE STRENGTH INFORMATION: Puddle Area: 869.4 square feet Puddle Volume: 6500 gallons Soil Type: Concrete Ground Temperature: 100 degrees F Initial Puddle Temperature: 100 degrees F Release Duration: ALOHA limited the duration to 1 hour Max Computed Release Rate: 8.29e-04 pounds/min Max Average Sustained Release Rate: 8.26e-04 pounds/min (averaged over a minute or more) Total Amount Released: 0.049 pounds FOOTPRINT INFORMATION: Dispersion Module: Gaussian User-specified LOC; 7 mg/ (cu.m) Max Threat Zone for LOC; 11 yards |