Cryovac Rigid Packaging - Executive Summary
EXECUTIVE SUMMARY |
1. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE
The Cryovac Rigid Packaging Plant at Indianapolis has implemented an accidental release prevention policy, which integrates containment technologies, redundant safety systems, operational procedures, and management practices. All
Applicable procedures of the U.S. Environmental Protection Agency (EPA) are adhered to. The Cryovac Emergency Response Policy involves side specific plans, which are detailed in the Emergency Operations Manual (EOM). This includes a trained on site, around the clock Emergency Response Team, and procedures to notify the local fire authority.
2. THE STATIONARY SOURCE AND REGULATED SUBSTANCE HANDLED:
Cryovac Rigid Packaging manufactures plastic foam packaging used in the food industry. The plant uses pentane as a blowing agent to make plastic foam. This is the only regulated substance in threshold quantities at this locatio
n. Pentane (CAS 109-66-0) is a flammable alaphatic hydrocarbon similar to gasoline. Pentane is used and stored as a liquid, but is released (slowly outgassed) from the product during the manufacturing process.
3. THE WORST AND ALTERNATIVE CASE SCENARIOS:
The "worst-case release" scenario as defined by EPA assumes a rail car delivery container completely fails, all safety systems fail, worst case weather conditions exist, the vapors find an ignition source and 10% of release explodes. The endpoint is at 1 psi overpressure is .37 miles. The "alternative release" scenario or more credible scenario is based on an analysis of potential hazards at our facility. Maximum release is 2000 gallons form a breach of a railcar or catastrophic failure of the delivery piping. The impact distance is based on maxi- mum distance at which the radiant heat effects of a vapor cloud fire might have serious consequences, .06 miles or in most cases, within our property lines. T
he impact distance in both cases has been derived using the EPA "RMP Offsite Consequence Analysis Guidance" document.
4. THE GENERAL CRYOVAC ACCIDENTAL RELEASE PREVENTION
PROGRAM AND CHEMICAL SPECIFIC PREVENTION STEPS:
* E.A.T. training of operators
* PSM process- completed HAZOP review of all stages of process
* Spill containment and 30,000 gallons capture vault for unloading areas
* Monitored double wall tanks and piping
* Hydrocarbon sensor safety interlock system
* Redundant alarms for potential upset conditions
* Preventative maintenance program
* Check-off sheet procedures for non-routine activities such as unloading or draining of piping.
* Use NFPA guidelines as a minimum standard for all fire protection systems.
Chemical - specific prevention steps include having detection meter calibrated to pentane and plant wide training on the properties, risks, and safe use of pentane.
5. FIVE -YEAR ACCIDENT HISTORY:
There have been four acci
dental releases over the past five years of which the largest release was one gallon. There were no injuries, property damage or off site consequences as a result of these incidents. In place systems resulted early detection and mitigation.
6. EMERGENCY RESPONSE PROGRAM:
The Emergency Response program incorporates an on-site Emergency Response Team fully trained and equipped for interior and exterior fire fighting, technician level hazmat response, confined space rescue, and first responder first aid. Pre-plans, joint training and drills are coordinated with Pike Township Fire Department who is responsible to Marion County Hazardous Materials Planning Committee (LEPC) on a county wide mutual response. Emergency operation and response procedures are reviewed on an annual basis.
7. PLANNED CHANGES TO IMPROVE SAFETY:
Numerous changes to improve safety and reduce risks have been implemented that were identified in the HAZOP review of PSM in 1994 and 1997. Safe
ty is an ongoing process and the highest priority at Cryovac facilities. Safety items are first on the agenda of the daily production meeting and overall direction, control, and follow up is provided by the monthly Management Safety Committee meeting.