No-Sag Foam - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

                       Executive Summary 
   1.0  Accidental Release Prevention and Emergency Response 
At No-Sag West Chicago, IL, we are committed to operating and 
maintaining all of our processes (especially those using 
hazardous substances) in a safe and responsible manner.  We use a 
combination of accidental release prevention programs and 
emergency response planning programs to help ensure the safety of 
our employees and the public as well as protection of the 
environment.  This document provides a brief overview of the 
comprehensive risk management activities that we have designed 
and implemented, including: 
A description of our facility and use of substances regulated 
by EPA's RMP regulation 
A summary of results from our assessment of the potential 
offsite consequences from accidental chemical releases 
An overview of our accidental release prevention programs 
A five-year  
accident history for accidental releases of 
chemicals regulated by EPA's RMP rule 
An overview of our emergency response program 
An overview of planned improvements at the facility to help 
prevent accidental chemical releases from occurring and 
adversely affecting our employees, the public, and the 
The certifications that EPA's RMP rule requires us to provide 
The detailed information (called data elements) about our risk 
management program 
        2.0 Stationary Source and Regulated Substances 
Our facility produces flexible polyurethane foam using a variety 
of chemicals and processing operations.  The facility is housed 
in an approximately 150,000 sq. ft. building located in an 
industrial area.  The process area is divided into two areas; one 
being the south area which contains the process and houses the 
tank farm, which is diked. The north area contains the 
fabrication departments.  In our processes, we use the following 
chemicals that EPA has identified as having t 
he potential to 
cause significant offsite consequences in the event of a 
substantial accidental release: 
See Appendix E, MSDS for Toluene Diisocyanate. 
Our accidental release prevention programs and our contingency 
planning efforts help us effectively manage the hazards that are 
posed to our employees, the public, and the environment by our 
use of these chemicals. 
        3.0 Key offsite Consequence Analysis Scenarios 
EPA's RMP rule requires that we provide information about the 
worst-case release scenario(s) and alternative release 
scenario(s) 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: 
Worst-case Release Scenario(s) - Regulated Toxic Chemicals 
See  Appendix A, for Worst-case Release Scenario.  The scenario 
is a rail car failure dumping the entire contents of the car. 
This scenario model 
does not indicate the possibility of 
impacting public receptors.  Diagrams, and modeling information 
used to develop the Worst-case scenario is located in our written 
Alternative Release Scenario(s) - Regulated Toxic Chemicals 
For an alternative release scenario we used is a transfer hose 
break. The modeling scenario indicated that there are no public 
or environmental receptors. The modeling information is located 
in appendix a of the written program. 
Worst-case Release Scenario(s) - Regulated Flammable Chemicals 
Alternative Release Scenario(s) - Regulated Flammable Chemicals 
We are using this information to help us ensure that our 
emergency response plan and the community emergency response plan 
address all reasonable contingency cases. 
4.0 General Accidental Release Prevention Program and Chemical 
                   Specific Prevention Steps 
We take a systematic, proactive approach to preventing accidental 
releases of hazardous chemicals.  Our mana 
gement systems address 
each of the key features of successful prevention programs 
Process hazard assessment 
Process hazard review 
Operating procedures 
Mechanical integrity 
Compliance audits 
Incident investigation 
Employee participation 
Hot work permit 
The key to preventing accidental chemical releases are the 
Standard Operating Procedures that are in Appendix D. 
These individual elements of our prevention program work together 
to prevent accidental chemical releases.  Our company and our 
employees are committed to the standard that these management 
systems set for the way we do business, and we have specific 
accountabilities and controls to ensure that we are meeting our 
own high standards for accident prevention. 
                5.0 Five-Year Accident History 
We keep records for all significant accidental chemical releases 
that occur at our facility.  The following is a brief summary of 
accidental chemical releases involving materials co 
vered under 
EPA's RMP rule during the past five years: 
There have been no accidental releases of TDI in the past 5 
                6.0 Emergency Response Program 
We maintain an integrated contingency plan, which consolidates 
all of the various federal, state, and local regulatory 
requirements for emergency response planning.  Our program 
provides the essential planning and training for effectively 
protecting workers, the public, and the environment during 
emergency situations.  Furthermore, we coordinate our plan with 
the community emergency response plan. 
            7.0  Planned Changes to Improve Safety 
The following is a list of improvements that we are planning to 
implement at the facility to help prevent and/or better respond 
to accidental chemical releases: 
1.  Additional two-way radios to improve communications during 
2,  Fixed monitors. 
3.  High level alarms / monitors. 
4.  Offloading platform 
5.   Air compressor dryer 
6.   Earthen berm system to co 
ntain minor spillage 
7.   Installation and use of spill pan collection system 
                      8.0 Certifications 
Based on the criteria in 40 CFR 68.10, our Risk Management 
Program is written to comply with Program level two.  The 
distance to the specified endpoint for the worst-case accidental 
release scenario for the covered process does not impact any 
public receptors. 
Within the past five years, the process has had no accidental 
releases that caused 
offsite impacts provided in the RMP rule (40 CFR 68.10(b)(1)). 
We have taken voluntary measures  to improve our operations to 
minimize potential releases of covered materials 
in order to protect both our employees and the public.  In the 
event of fire, explosion, or a release of a regulated substance 
from the process, entry within the distance to the 
specified endpoint may pose a danger to public emergency 
responders.  Therefore, public 
emergency responders should not enter this area except as 
arranged with the emergency contact 
indicated in the RMPlan.  The 
undersigned certifies that, to the best of my knowledge, 
information, and belief, formed after reasonable inquiry, the 
information submitted is true, accurate, and complete. 
Signature_______Joe Progar__________________________________ 
Title____________Branch Manager_________________________________ 
                     9.0 RMP Data Elements 
The following pages present additional information about our risk 
management program that EPA's RMP rule has asked us to provide. 
The information is categorized as follows: 
-    Registration 
-    Offsite consequence analysis 
-    Five-year accident history 
-    Program 2 prevention program 
-    Emergency response program
Click to return to beginning