Document R225Jjv4q6yBk4xeXjNqrEG8v

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Future Foam, Inc. Jason Schenandoah, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Supervisor AECAB (IL/IN) File BASIC INFORMATION Facility Name: Future Foam, Inc. Facility Location: 1900 Lusher Ave, Elkhart, IN 46517 Date of Inspection: August 30, 2022 EPA Inspector(s): 1. Jason Schenandoah, Environmental Engineer 2. Danny Nguyen, Environmental Engineer Other Attendees: 1. Tonya Ruben, HR/EHS Manager, Future Foam 2. Dennis Ruben, Plant Manager, Future Foam 3. Mike Noble, Chemist, Future Foam 4. Randy Woody, Material Unloader, Future Foam 5. Tomas Johanson, EHS Manager, Corporate Contact Email Address: Bbowen@futurefoam.com; Tjohanson@futurefoam.com; Truben@futurefoam.com Purpose of Inspection: To ensure compliance with Section 112(r) of the Clean Air Act Facility Type: Polyurethane foam product manufacturer Regulations Central to Inspection: 40 C.F.R. Part 68: Chemical Accident Prevention Provisions (CAPP) Arrival Time: 8:30 am Departure Time: 10:45 am Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided. Reason: Provided CBI warning to facility The following information was obtained verbally from Future Foam, Inc. (Future Foam Personnel unless otherwise noted. Company Ownership: On March 2, 2022, Future Foam purchased the 1900 Lusher Ave, Elkhart, Indiana facility (the Facility) from Innocor Foam Technologies. Process Description: Toluene diisocyanate (TDI) and polyol arrives at the Facility via tanker truck and are unloaded via separate loading zones into fixed roof storage tanks stored indoors. TDI and polyol is sent through process piping to the mixing zone. TDI and polyol is then combined to form a foam and is immediately placed on a trough with a conveyor. As the conveyor moves a continuous slab of foam is formed in the trough. Slabs are cut to size as the foam is formed and stored to cure. Foam slabs may be cut to shape according to customer needs. Foam products are then shipped via truck from the Facility. The storage of TDI at the Facility was the focus of the inspection. TDI is stored in nine storage tanks at the Facility and those storage tanks and associated piping are subject to the CAPP. There are four 12,000-gallon tanks and five 6,000-gallon tanks. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: The storage tanks are contained in two rooms that have containment walls around them. The four larger tanks are in their own room and the five smaller tanks share a room with all other storage Page 2 of 5 tanks operated by at the Facility. The containment walls have a section cut out of them that creates an opening between the room with the larger tanks and the room with all of the remaining tanks. The floor is continuous between the two rooms through the opening between the rooms. The worst-case release scenario used a puddle area for the size of the room with the larger tanks only. Staff Interview: The total area of the rooms containing all storage tanks is 4605 sq. ft. Future Foam staff stated that their emergency response plan (ERP) was provided to the local emergency planning committee (LEPC) and the local fire department. The Facility has no accident history. Photos and/or Videos: were taken during the inspection. One photo was taken and is logged in Appendix A: Digital Image Log. Future Foam has claimed the photo as confidential. Field Measurements: were not taken during this inspection. RECORDS REVIEW 1. Risk Management Plan (RMP) submittal 2. Aloha calculation for worst-case release scenario CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Email from the LEPC and local fire department regarding receipt of the ERP. Compliance Assistance: Future Foam personnel was informed that the worse-case release scenario should include a puddle area that includes the total area of the floor within the containment walls minus the area of each storage tank base. Page 3 of 5 Concerns: The worse-case release scenario was previously underestimated due to the puddle size used in the Aloha calculation. When the puddle size is corrected, it may include a distance to end point that will have a public receptor within its radius. DIGITAL SIGNATURES JASON Digitally signed by JASON SCHENANDOAH SCHENANDOAH Date: 2022.10.04 Report Author: _____________1_0:_54_:3_4 _-0_5'0_0'_____________ Section Supervisor: NATHAN Digitally signed by NATHAN FRANK Date: 2022.10.07 _F_R_A__N_K_______1_1:_22_:3_1 _-0_5'0_0'______________ Page 4 of 5 Facility Name: Future Foam, Inc. Facility Location: 1900 Lusher Ave, Elkhart, IN 46517 Date of Inspection: August 30, 2022 APPENDICES AND ATTACHMENTS 1. Appendix A: Digital Image Log Page 5 of 5 Facility Name: Future Foam, Inc. Facility Location: 1900 Lusher Ave, Elkhart, IN 46517 Date of Inspection: August 30, 2022 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: Jason Schenandoah 2. Archival Record Location: Electronic Records Center Image Number 1 File Name IMG_0194.jpg Date and Time (incl. Time zone and DST) 8/30/2022 9:40 am* Latitude and Longitude *The time on the camera was still programed to central time. The photo was zone and the time has been corrected in the log above to account for it. taken Description of Image Opening in containment walls between the room with the large TDI storage tanks and the room containing all other storage tanks. in the eastern time Appendices Page 1 of 1