Woodbridge Corporation's Atlanta Foam Plant - Executive Summary

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1. Accidental release prevention and emergency response policies. 
The Atlanta Foam Plant, as part of the Woodbridge Group of companies, believes the health and safety of its employees and the protection of the natural environment, is the utmost concern in the operation of its business.  We are committed to operating and maintaining all of our processes in a safe and responsible manner. 
It is our policy to: 
Comply with all applicable laws, regulations, and standards. 
Review and assess our operations for the purpose of making health, safety & environmental  improvements. 
Our complete Heath Safety & Environmental policy statement, signed by our plant manager, is posted in the lobby of our facility.  
We use a combination of prevention programs and emergency response planning, which are described later in this document, to help ensure the safety of our employees and the public as well as prot 
ection of the environment. Our Plant Manager has the overall responsibility for ensuring that our facility operates in a safe and reliable manner.  This responsibility includes overseeing the implementation of the elements of our risk management program.  To ensure that our risk management program is appropriately developed and implemented, our Plant Manager has assigned the role of RMP coordinator to a staff member with the background, training, and experience necessary to manage the program. The RMP Coordinator, acting with the authority delegated directly from the Plant Manger, is responsible for coordinating the development, implementation and integration of the RMP elements as is required under Section 68.15 of the RMP rule.  
2. The stationary source and regulated substances handled. 
The primary purpose of the Atlanta Foam Plant is to produce polyurethane foam seat cushions for the automotive industry. The foam is made by high pressure mixing of chemicals as they are poured into 
a mold that is attached by carrier to a continuously moving line. The mold moves through a curing oven. Upon exiting the oven, the foam pads are removed from the mold, vacuum or mechanically crushed, trimmed and prepared for shipment to customers.  
Toluene Diisocyanate (TDI), which is regulated by EPA's risk management program rule, is one of the reactants required to manufacture polyurethane foam. TDI is received at the plant by railcar and tanker truck, and is stored in 2 tanks located in the contained bulk storage tank room. The TDI is then transferred to the process utilizing a computer-controlled system.  
Access to the site is restricted to authorized facility employees, management personnel, and contractors. The maximum amount of TDI that can be stored at this facility is 210,000. pounds. 
3. Off-site consequence analysis scenarios  
EPA's RMP rule requires that we provide information about the worst-case release and alternative release scenario's for our facility.  The follow 
ing are brief summaries of these scenarios, including information about the key administrative controls and mitigation measures to limit the exposure distances for each scenario.   
The methodology used to determine the distance to the toxic endpoint as established by the RMP rule was  ALOHA.  
Worst-case Release Scenario. 
Catastrophic failure of a railcar full of TDI at the railcar unloading site, discharging its entire contents of 180,000 pounds in 60 minutes, using the ALOHA model. It is assumed that the maximum temperature the TDI could reach during an unload is 120 degrees F. As there is no containment at the railcar unloading site, it is assumed that a pool with a depth of 1 cm is formed,covering 80,000 sq. ft. and evaporates to form a cloud that disperses downwind. The distance to the endpoint concentration of 0.007 mg/l is 0.12 miles, or 217 yards. There are no residences within this boundary. 
Alternative Release Scenario.  
An accidental railcar movement that severs a 25-ft le 
ngth of 2-inch hose would trigger a release of TDI. Excess flow valves function to stop the flow, and only the contents of the hose are released. The resulting liquid forms a pool with a depth of 1 cm that evaporates to form a toxic cloud, which disperses downwind. The distance to the endpoint concentration of 0.007 mg/L is .04 miles or 86 yards. This release should not leave the facility boundary. 
4.The general accidental release prevention program and the specific prevention steps.  
We take a systematic, proactive approach to preventing accidental releases of chemicals. Our management systems for our TDI process address each of the key features of successful prevention programs including:  
Contractor Awareness 
Hot Work Permitting 
Monthly Workplace inspections by members of H S & E team. 
Safety information  
Hazard reviews of our processes 
Operating procedures 
Equipment Maintenance Program 
RMP Compliance Audits 
Accident/Incident Investigation 
In addition, we have an est 
ablished Isocyanate Control Program that outlines the hazards of handling toluene diisocyanate and the controls, which are in place to reduce the hazards of isocyanate exposure to the employees, the community and the environment.  
These listed 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 conduct business, and we have specific accountabilities and controls to ensure that we are meeting our own high standards for accident prevention. 
5.Five-year accident history.  
The Atlanta Foam Plant has not had any TDI releases that qualify for listing in the EPA's required five-year accident history report.   
6. The emergency response program. 
We maintain an integrated contingency plan, which consolidates the various federal, state and local regulatory requirements for emergency response planning.  Our program provided essential p 
lanning and training for effectively protecting workers, the public and the environment during emergency situations. As our LEPC and SEPC are one and the same, we have coordinated our program with the local fire department. A representative group from the fire department routinely visits this plant to discuss how to respond to a release of TDI.  We have also given local hospitals information regarding medical treatment for exposure to TDI. 
7. Planned changes to improve safety. 
At this time we are continuing to maintain our current safety management systems.  In addition, we are investigating the possibilities for containment of our railcar-unloading site and continue to improve the computerized process control system as outlined in our hazard review. We also anticipate improving our training programs in the area of specific maintenance tasks.
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