Turner Road Vintners East - Executive Summary
Executive Summary |
Sebastiani Vineyards, Inc.
Turner Road Vintners East
Risk Management Plan
The Turner Road Vintners East Cellars is located at 4614 West Turner Road, Lodi, California and is owned and operated by Sebastiani Vineyards, Inc. The facility was originally constructed in 1946 and was aquired by Sebastiani Vineyards in 1988. It has always been operated as a wine grape processing and wine production facility. The facility is currently dedicated to the production, packaging, and distribution of premium table wine. All process and operations conducted at the facility are integral parts of the winemaking and distribution process.
Operations conducted at the facility include processes that use certain substances identified in federal and state regulations as Extremely Hazardous Substances (EHS). Sufficient quantities of these substances are used and stored at the facility to require the development and implementation of a Risk Management Program and submit
tal of a Risk Management Plan.
The primary purpose of the Risk Management Program and Plan (RMP) is to prevent accidental releases of toxic substances. The secondary purpose is to develop the information necessary to prepare facility personnel and public agencies to respond adequately and appropriately to releases when they do occur.
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES
In matters of safety and environmental protection, Sebastiani Vineyards (The Company) maintains a proactive stance, from senior management on down. As a labor-intensive agricultural based industry, we are firmly dedicated to protection of our natural and human resources. It is our goal to be prepared and self sufficient to handle any forseable emergency and the Management believes that preparation and training are the best way to meet this goal. It is company policy however, that no employee will take unnecessary chances, and if a situation is beyond the expertise or resources of facility per
sonnel, outside assistance will be summoned at once.
Reporting of releases is an important element of the Emergency Response Plan. Procedures are in place and employees are trained to perform a rapid initial assesment and report as needed to the appropriate agencies. The company recognizes that early intervention can minimize the impact of any emergency.
Using regulations and agency guidance documents for reference and consulting with the appropriate agencies and industry experts, policies and programs are written and updated as needed to keep current. Regular training is provided for all affected employees. In additon to the RMP, some of the key programs and policies currently in place are:
7 Injury and Illness Prevention Program
7 Hazard Communication Program
7 Confined Space Procedures
7 Lock-out Tag-out Procedures
7 Respiratory Protection Program
7 Hearing Conservation Program
7 Stormwater Prevention Program
7 Spill Prevention and Control Program
7 Hazardous Materials Management
7 Emergency Action Plan (including Fire Prevention Plan and specific procedures for natural disasters and hazardous materials releases
Safety meetings are held regularly and all employees are provided with initial training and annual refresher training in all necessary safety programs. Health testing is provided for all employees in accordance with Title 8 CCR GISO
THE FACILITY AND THE REGULATED SUBSTANCES HANDLED
At the facility, there is one Federal RMP covered processes using sulfur dioxide. This process, (ID #10) is an integral part of the winemaking process. Operations consist of the transfer of sulfur dioxide from one-ton and 150 lb. cylinders into smaller gauging cylinders that are used for dispensing the gas into wine and tank headspaces. The process uses gravity assisted by inert gas counterpressure to provide the motive force.
WORST-CASE AND ALTERNATIVE RELEASE SCENARIOS
The Worst Case Release Scenaraio for this facility would be the release of 2,000 lbs. of sulfur
dioxide from a full one-ton cylinder. EPA's RMP*Comp computer modeling program was used for the analysis and yielded a distance of 3.10 miles to the toxic endpoint. Using EPA's LandView mapping and census information program the population within the zone of influence was estimated at 1,800. The only other public receptor located within the zone of influence was Turner School. No environmental receptors were located within the zone of influence.
As required, an alternative release scenario was also analyzed for sulfur dioxide. This scenario was a release of the contents of a 150-lb. sulfur dioxide cylinder when its main valve was sheared off by vehicle collision. This scenario was calculated based on a release duration of 5 minutes. This scenario was chosen because it was determined to be the more likely than the worst case release scenario.
RMP*Comp was used for the analysis and yielded a distance of 0.2 miles to the toxic endpoint. Using EPA's LandView mapping and census informati
on program the population within the zone of influence was estimated at 6. The only other public receptor located within the zone of influence was Turner School. No environmental receptors were located within the zone of influence. These results were not surprising, as the facility is located in a rural agricultural area with very low population density.
In order to generate a conservative estimate of the potential consequences, mitigatons were not considered in the analysis of the worst case or alternative release scenarios. Mitigation methods are available and would be invoked during an actual release so that the actual consequences would be significantly less than predicted by these scenarios.
The sulfur dioxide facility is equipped with a manually operated water curtain. It is estimated that this system will effectively absorb approximately 80% of any forseeable release. In addition to this sytem, 1" and 2" water hoses are provided throught the facility to provide manual water sp
ray to mitigate releases.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS
The general accidental release prevention program consists of Standard Operating Procedures (SOP) and maintenance procedures and schedules specific to each process, equipment, or system. In addition to written procedures, specific training is provided initally and refresher training is provided as needed to all employees who work with the processes. General safety inspections conducted under the IIPP are also used to ensure compliance with SOPs. Annual inspections are conducted for Storm Water Pollution Prevention compliance, Hazardous Material Inventory Reporting, and Toxic Chemical Release Inventory Reporting requirements. All programs and policies are designed for compliance with all applicable environmental and safety regulations including Title 8 CCR General Industry Safety Orders
Employees are directed to report immedately any minor leakage or other abnormal condit
ions that might be indicative of an imminent accidental release. These reports are directed to the Maintenance Department at once and top priority is given to correction of the deficiency.
FIVE-YEAR ACCIDENT HISTORY
Within the past 5 years there have been no serious accidents involving this process.
EMERGENCY RESPONSE PROGRAM
It is the goal of the Company to be as self-sufficient as possible in response to controlling and containing releases of hazardous materials or other emergencies. At the same time, we recognize that people can get hurt and a bad situation can get worse quickly when inadequately trained and equipped personnel get involved. It is for this reason that our emergency response program will always use a combination of response strategies. On site personnel are trained first in awareness and self-protection, and then in specific control and containment procedures. Particular attention is paid to reporting and communications with emergency response agencies. An ongoin
g commitment to joint participation exercises with local ER agencies is a key element of the program.
PLANNED CHANGES TO IMPROVE SAFETY
Management is always exploring new ways to enhance safety awareness and knowledge of the employees. Currently in the planning stages is a dedicated Plant Safety Day during which all plant operations will be shut down and employeest will participate in safety training covering as many topics as can be worked into a single day. It is anticipated that this event will occur at least once per year and possibly more frequently. We believe that the benefits of dedicating an entire day to safety will pay dividends well in excess of the costs.
In additition, a policy of zero tolerance for nuisnace leakage of toxic gases will be promoted to encourage employees to maintain a higher level of vigilance in prevention of accidental releases.
Consideration is also given to upgrades of certain equipment as new technologies and standards are developed and proven. Wh
ere feasible and cost effective, upgrades for compliance with new standards and methods are reviewed and considered for implementation.
It is consideration of upgrades in technology, training and procedures that allows a facility to continue to improve its Risk Management Program and demonstrate its commitment to protection of human health and safety, property, and the environment.