Future Foam, Inc. - Executive Summary |
|
It is the policy of Future Foam to compl with all applicable federal, state and local regulations. In the event of an emergency a the facility the local EMS system will be contacted for emergency response. Future Foam manufactures flexible polyurethane foam bun stock at a plant located at 2451 Cypress Way in Fullerton, California. The plant is located in an industrial area and is bordered by other industries. The building is a concrete construction with the chemical storage and processing areas located indoors and seperated from the rest of the building by walls. Toluene diisocyanate (TDI) is stored in two (2) tanks, the largest (bulk storage) having a capacity of 27,000 gallons and the other (run) having a capacity of 5000 gallons, located in a diked tank farm with a surface area of 3700 square feet and a holding capacity of 72,000 gallons. The tank farm is located in an enclosed room inside the facitility (a building within a building). Product is received by railcar and unloa ded from an outdoor diked area into the indoor storage tanks. During the 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 tank farm. A review of the foam manufacturing process was conductred 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 as a Program 1 facility 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 beeen coordinated with the Fullerton Fire Department and information about chemicals onsite has been provided to the local emergency management coordinator. The value reported in Section 2.6 is overstated since 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 0.0569 pounds/minute which is lower than that reported in Section 2.6. The "Worst Case Scenario" for this 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 pound) railcar of TDI. Such a failure pre-defined by EPA would release the entire liquid contents into a 4000 square foot puddle in 10 minutes. The release to the atmosphere wa s modeled using ALOHA and the following factors: - puddle size = 4000 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 The model calculated a release reate of 0.0569 pounds/minute over a period of 60 minutes which resulted in a total release of 3.16 pounds of TDI. The distance to the Level of Concern endpoint of 0.007 mg/L was calculated as 32 yards (0.018 miles). This distance does extend offsite but 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 assording to Section 2.7 of the RMP*Submit User's Manual. In th e event of a "Worst Case Release" Future Foam would notify the Fullerton Fire Department and the current TDI supplier to the facility. The fire department has inspected the facility. Active mitigation of such a release could be accomplished by covering the puddle with plastic or water to minimize evaporation. Release prevention is accomploished through a series of active and passive methodologies. Passive mitigation is accomplished by the diking and draining of the rail siding unloading area to a sump area which limits the surface area of the puddle to 4000 square feet and contains the entire volume of a railcar. Active mitigation controls include top-unloading of railcars, pipline valving, tank high level alarms 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 and preventative maintainence. All personnel associated with the foam production operation have received training on the proper handling and use of TDI including unloading operations. |