Amcor Manufacturing - Executive Summary |
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1. Accidental Release Prevention and Emergency Response policies. The subject facility manufactures and stores peracetic acid which is considered a hazardous material. The properties of the material make it necessary to observe safety precautions when handling to prevent human exposure and to reduce the threat to the facility's workers and nearby members of the community. It is the facility's policy to adhere to all applicable Federal and state rules and regulations. Safety depends upon the safe procedures used to handle peracetic acid, the safety devices and system designed and constructed into the facility, and the training of the plant personnel. 2. Stationary Source and Regulated Substances Handled Peracetic acid is manufactured, stored, and shipped at the facility. The Peracetic acid is made in a batch prrocess one tote at a time. The maximum size of a batch process is 330 gallons. The batch process is enclosed in a building then stored outside of the building in an area with secondary containment in the form of a berm. The secondary containment area can hold a rupture of the largest container size of peracetic acid. The manufacturing, storage, and handling of the peracetic acid is considered part of one complete process. 3a. Worst Case Scenario The 330 gallon tote is the largest vessel in the process. The worst case release scenario to be modeled assumes that the full 330 gallon tote is released over a one minute period resulting in a release rate of 3036 pounds per minute. The distance to the end point of .0045 mg/l for the worst case scenario is 0.6 miles. This peractice acid release will extend beyond the boundaries of the stationary source. 3b. Alternative Release Scenario The alternative release scenario for the peracetic acid 330 gallon tote assumes a release from a 1 square inch hole resulting in the release of 318 pounds of peracetic acid in one minute. The distance to the end point of .0045 mg/l for the alternative release scenario is .1 mile. The release will extend beyond the bounds of the stationary source. 3c. Administrative controls Administrative controls to limit the distances of each reported scenario exists to restrict to a minimum the amount of peracetic acid released, if a release were to occur, and preferably to not have a release occur. The administrative control is inherent in the operational procedures for the peracetic acid systems and the training provided to the operators. 3d. Mitigation measures Mitigation measures to tlimit the distances for each reported scenario exists to restrict to a minimum the amount of peracetic acid released, if a release were to occur, and preferably to not have a release ;occur. The mitication measures are based upon the design, inspection, testing, and maintenance of the peracetic acid blending and storage systems and related equipment and components. 4. General Accidental Release Prevention program and Chemical Specific Prevention Steps The fa cility complies with all applicable federal and state codes and regulations. There are safety meetings and safety training. The Process safety management program implemented at the facility for the peracetic acid related activities and equipment represents one of the facility's main active commitments to an accidental release prevention program. 5. Five year accident history There have been no incidents involving the release of peracetic acid within the past five years. 6. Emergency response plan The Emergency Response Program is based on alerting personnel the the facility of the need to evacuate the facility and await the arrival of responders from the City of Modesto Fire Department at the evacuation assembly location if a release occurs that causes the evacuation to be initiated. The Stanislaus County of Emergency Services incorporates this response into the County Area Plan for the Regional Emergency Planning Commission. 7. Planned Changes to Improve Safety There are c ommitments made under the Process Hazard Analysis element of the PSM that are being implemented at this time for the next year. Current applicable codes and regulations are reviewed as part of the PSM to determine if other commitments need to be made in order to achieve increased operational safety for the regulated process system. These commitments need to be made to achieve increased operational safety for the regulated precess system. These commitments will be prevention and mitigation measures for accidental releases of the regulated substances. |