Future Foam, Inc. - Executive Summary

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It is the policy of Future Foam to comply with all applicable federal, state and local regulations.  In the event of an emergency at the facility the local EMS system will be contacted for emergency response. 
Future Foam, Inc. manufactures flexible polyurethane foam bun stock at a facility located at 1500 Sixth Street Southeast in Newton, Kansas.  The facility is located in an industrial park zoned for industrial and manufacturing and is bordered by another industrial facility and a railroad line.  The foam production and chemical storage buildings are preenginneered steel structures.  Toluene diisocyanate (TDI) is stored in three (3) tanks, the largest (bulk storage) having a capacity of 32,000 galllons and the other two (run) 10,000 galllons.  All the tanks are located inside the chemical storage building which is located inside a diked tank farm with a surface area of 10,000 square feet and a capcity of approximately 80,000 gallons.  Product is received by railcar and unloaded from 
a siding located on the side of the building next to the rail line and pumped to the bulk storage tank.  The siding is bermed by the railbeds and the side of the building and has an effective surface area of 3000 square feet and the capacity to hold the entire contents of a railcar.  During foam manufacturing, TDI is pumped from the run tank to the process mixer through a closed piping loop.  The mixer is an enclosed unit into which TDI and other processing chemicals are mixed and the reaction mixture is then transferred to the foam conveyor line.  All TDI pumps and tank valves are located inside the diked area. 
A review of the foam manufacturing process was conducted to determine applicability of Part 68 regulations to this facility.  It was determined that the facility contains one process with more than the threshold quantity of the regulated substance toluene diisocyanate (TDI) according to 68.115.  According to 68.10(b) the facility fulfills the requirements of a Program 1 facil 
ity since: 
        - there have been no accidental releases of TDI in the past five years, 
        - the worst-case release distance to the toxic endpoint does not impact a public or environmental receptor, 
        - and emergency response has been coordinated with the Newton Fire Department and informantion  
              about chemicals onsite has been supplied to the local emergency management coordinator. 
The value reported in Section 2.6 is overstated sine RMP*Submit will not accept the values modeled by ALOHA, a publically available and widely used by emergency response agencies modeling program.  ALOHA modeled a release rate of 0.0508 pounds/minute which is lower than that reported in Section 2.6. 
The "Worst Case Scenario" for the facility, as defined in 68.3 as "the release of the largest quantity of a regulated substance from a vessel or ... that results in the greatest distance to an endpoint ..." would be the catastrophic failure of a 20,000 gallon (190,000 pounds) rai 
lcar of TDI.  Such a failure pre-defined by EPA would release the entire liquid contents into a 3000 square foot bermed puddle in 10 minutes.  The release to the atmosphere was modeled using ALOHA and the following factors: 
        - puddle size = 3000 square feet 
        - liquid temperature = 100F 
        - atmospheric temperature = 100F 
        - wind speed = 1.5 M/s 
        - relative humidity = 50% 
        - cloud cover = 50% 
        - stability class = F 
        - urban topography 
        - release duration = 60 minutes 
        - toxic endpoint = 0.007 mg/L 
        - evaporation from a 3000 square foot puddle 
The model calculated a release rate of 0.0508 pounds/minute over a period of 60 minutes which resulted in a total release of 2.63 pounds of TDI.  The distance to the Level of Concern endpoint of 0.007 mg/L was calculated to be 30 yards (0.017 miles).  This distance does not extend offsite and does not impact any public or environmental receptors.  The release rate 
for TDI is such that the release duration would exceed 60 minutes, therefore, ALOHA calculates the maximum release to be 60 minutes according to Section 2.7 of the RMP*Submit User's Manual. 
In the event of a "Worst Case Release" Future Foam would notify the Newton Fire Department and the current TDI supplier to the facility.  The fire department has inspected the facility and information about the chemicals onsite has been profided to the local emergency planning coordinator.  Active mitigation of such a release could be accomplished by covering the puddle with plastic or water to minimize evaporation. 
Release prevention is accomplished through a series of active and passive methodologies.  Passive mitigation is accomplished by the rail siding unloading area berms which limit the surface area of a pool to 3000 square feet and contain the entire volume of a railcar.  Active mitigation contols include top-unloading of railcars, pipeline valving, tank high level alarms, overflow protec 
tion and pump operational monitoring systems.  Administrative controls include periodic tank level inventories prior to unloading railcars, railcar inspections, general inventory controls, physically monitoring tank valve operation, physically monitoring railcar unloading and preventative maintainence.  All personnel assoceated with the foam production operation have received training on the proper handling and use of TDI including unloading operations.
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