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 bunstock at a facility located at 2210 Parview Road in Middleton, Wisconsin. The facility is located in an industrial park zoned for industrial and manufacturing and is bordered by other industrial and manufacturing entities and a railroad line. The foam production and chemical storage buildings are preenginneered steel structures. Toluene diisocyanate (TDI) is stored in two (2) tanks, the largest (bulk storage) having a capacity of 27,000 galllons and the other (run) 10,000 galllons. Both tanks are located inside the chemical storage building which is internally diked, having a surface area of 2450 square feet and a capcity of approximately 30,000 gallons. Product is received by railcar and unloaded from a siding loc ated on the backside 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 2000 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 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 been coordinated with the Middleton Fire Department and informantion about chemicals onsite has been reviewed with 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 0.0309 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) railca r of TDI. Such a failure pre-defined by EPA would release the entire liquid contents into a 2000 square foot bermed puddle in 10 minutes. The release to the atmosphere was modeled using ALOHA and the following factors: - puddle size = 2000 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 2000 square foot puddle The model calculated a release rate of 0.0305 pounds/minute over a period of 60 minutes which resulted in a total release of 1.66 pounds of TDI. The distance to the Level of Concern endpoint of 0.007 mg/L was calculated to be 23 yards (0.013 miles). This distance does extend offsite but does not impact any public or environmental receptors. The release rate for TD I 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 Middleton Fire Department and the current TDI supplier to the facility. The fire department has inspected the facility and scenarios have been discussed with the department and 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 berming which limits the surface area of a puddle to 2000 square feet and contains the entire volume of a railcar. Active mitigation contols include top-unloading of railcars, vapor balancing piping, pipeline valving, overflow protection 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. |