Accra Pac Inc. - Executive Summary

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Accra Pac Inc., located at 2730 Middlebury Street, Elkhart, Indiana, offers full service custom packaging for various consumer product inductries, such as pharmaceutical, household, cosmetic, personal care, and automotive care.  The products packaged for these industries consist of liquids, semi-liquid creams, lotions, and aerosols.  Some of the types of products that Accra Pac packages include: hair mousse, cooking sprays, household cleaners, tire cleaners, air fresheners, breath spray, etc.  Many of these products are aerosols and use a flammable gas like propane to pressurize the containers so that the desired product can be sprayed from the aerosol cans. 
 
Accra Pac Inc., is committed to promoting a safe operating environment for the facility, its employees and the surrounding community.  The facility is complying with the EPA's Risk Management Program rule as well as the OSHA Process Safety Management (PSM) standard.  The purpose of these regulations is to ensure that  covered proc 
esses are safely designed, operated and maintained.  The Accra Pac Risk Management Plan includes two similar processes:  aerosol packaging performed at the North and Main plants (located on the north side of Middlebury Street) and aerosol packaging performed at the HCI facility (located on the south side of Middlebury Street).  The HCI process contains a threshhold quantity of covered chemicals only when tank wagons are present and connected to the facility piping system.  The regulated chemicals used in the aerosol packaging processes are: 
 
Butane (CAS No. 106-97-8) 
Difluoroethane (CAS No. 75-37-6) 
Dimethylether (Methyl Ether) (CAS No. 115-10-6) 
Isobutane (CAS No. 75-28-5) 
Propane (CAS No. 74-98-4) 
Pentane (CAS No. 109-66-0) 
Isopentane (CAS No. 78-78-4) 
 
Accra Pac personnel realize that the regulated chemicals listed above pose a significant flammablility hazard and have taken steps to ensure these chemicals are handled in a safe manner.  Some of the protective measures that are in pl 
ace to ensure the safety of Accra Pac employees and the surrounding community are listed below. 
 
*  Gas detection systems are installed in all areas where there is potential for hazardous levels of flammable gas to accumulate. 
*  State of the art explosion suppression systems have been installed in all production areas where flammable gas is transferred to aerosol containers.  These systems are designed to detect and extinguish an ignition before a catastrophic explosion can occur. 
*  All production equipment is adequately grounded to reduce hazardous static electricity buildup that could ignite flammable vapors. 
*  Storage tanks that contain the flammable material are inspected to ensure structural integrity. 
*  Pressure relief valves are installed on appropriate storage tanks and piping systems to prevent them from overpressurizing. 
*  Ventilation systems are installed to prevent the accumulation of flammable vapors in processing areas. 
*  Standardized operating procedures are utiliz 
ed for unloadng and handling flammalbe materials. 
 
The "Emergency Evacuation and Contingency Plan" has been developed and emergency response procedures have been coordinated with the Elkhart Fire Department and Elkhart County Local Emergency Planning Committee.  This plan addresses emergency response procedures for fire, explosion, chemical spills, severe weather, etc.  The plan details actions to be taken by Accra Pac for such emergencies regarding the use of safety equipment, communication responsibilities, and coordination with off-site responders such as the fire department. 
 
The emergency response program is based on the OSHA requirements for Emergency Action Plans (29 CFR 1910.38 and 1910.119)  and HAZWOPER (29 CFR 1910.120).  We have trained our employees for emergency response action and maintain a written response plan.  The plan has been coordinated with the Elkhart Fire Depertment and the Elkhart County Local Emergency Planning Committee. 
 
Accra Pac has not had an accident i 
n the last five years involving the chemicals covered by the RMP regulation that resulted in injuries, property or environemental damage, evacuations or sheltering in place.  The June 1997 incident involving ethylene oxide a the North plant is not listed in the 5-year accident history as part of the Risk Management Plan.  This accident did not meet the EPA requirements to be included in this history.  In addition, this chemical is no longer used at any Accra Pac Facility.  Accra Pac acknowledges this tragic accident and its exclusion from this EPA requirement is in no way intended to minimize its tragic consequences. 
 
The extremely unlilkely worst-case release scenario is based on the failure of the largest storage tank, a 30,000 gallon tank of isobutane and a resulting vapor cloud explosion.  The distance to the flammable endpoint of 1 psi over-pressure was determined to be 0.4 miles. 
 
In addition, an alternative release scenario has been modeled based on a piping system failure while 
the propellant pump is operating and a resulting vapor cloud fire.  The distance to the flammable endpoint was determined to be less than 0.1 mile. 
 
Accra Pac is committed to continuously improving and updating safety systems in order to reduce the risk to its employees and the surrounding community.
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