Campbell Soup Supply Company L.L.C.-Napoleon Plant - Executive Summary |
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A. Describe the Accident Release Prevention and Emergency Policies The Campbell Soup Plant in Napoleon, OH is committed to the protection of its employees, its property, and the environment. In fulfilling this commitment, the plant will provide and maintain a safe and healthful work environment as indicated by acceptable business practices and compliance with legislative requirements, and will strive to eliminate any foreseeable hazards that may result in fires, security losses, damage to property or the environment, and personal injuries/illnesses. Key elements of the Napoleon Plant safety program are the precautions taken to prevent or minimize accidental releases of chlorine from the treatment systems. These precautions include safety controls (alarms and automatic shutdown devices) which are designed to identify and prevent potentially unsafe conditions such as chlorine releases, a preventive maintenance program designed to maintain the on-going integrity of the systems, a trai ning program designed to ensure that the systems are operated by qualified personnel, and emergency response procedures which enable trained personnel to respond quickly to system upsets. The Supervisor of the Water Treatment, Wastewater Treatment, and Environmental Areas is responsible for the management of these chlorine safety programs. B. Stationary Source and Regulated Substances Handled The Campbell Soup Plant in Napoleon, OH produces canned food products for sale to the public. The facility uses chlorine in its water treatment and wastewater treatment systems. The combined chlorine inventory for both systems is approximately 28,000 pounds. Chlorine is the only regulated substance handled at the Napoleon Plant. C. Summary of Worst-Case and Alternative Release Scenarios The worst-case release scenario at the Napoleon Plant involves the release of 2,000 pounds of chlorine over a 10 minute period due to the failure of a 1-ton chlorine cylinder. Under worst-case condi tions, the resulting vapor cloud could have off-site consequences. The alternative release scenario at the Napoleon Plant involves the release of 900 pounds of chlorine over a 60 minute period due to the failure of a 5/16" vapor line connected to a chlorine cylinder. Under alternative release conditions, the resulting vapor cloud could have off-site consequences. The worst-case and alternative release scenarios are unlikely for the following reasons: o The weather conditions that were used for the worst-case release scenario do not occur, while those used for the alternative case are uncommon; o Industry standards were followed for the design and manufacture of the equipment in the chlorine treatment systems; o The 1-ton chlorine cylinders are located in enclosed areas that should help to contain any chlorine releases; o The chlorine cylinder rooms contain chlorine detectors and ventilation fans that should detect and mitigate the effects of any chlorine releases; o The facility h as a preventive maintenance program in place to maintain the on-going integrity of the chlorine treatment equipment; and, o The facility has a training program designed to ensure that the systems are operated by qualified personnel. D. Description of the Accidental Release Prevention Program The facility has an accident release prevention program that complies with OSHA's Process Safety Management Standard and EPA's Risk Management Program Regulation. The prevention program consists of the following elements: o Employee Participation Program o Process Safety Information o Process Hazard Analysis o Operating Procedures o Training Program o Contractor Safety Program o Pre-Startup Safety Review Procedures o Mechanical Integrity Program o Hot Work Permit Procedures o Management of Change Procedures o Incident Investigation Procedures o Compliance Audit Procedures E. Five-Year Accident History There have not been any chlorine-related incidents at the Napoleon Plant during the pr evious five years that resulted in significant on-site or offsite consequences. F. Description of the Emergency Response Program An emergency response program has been implemented at the Napoleon Plant. This program contains procedures describing how the facility will respond to chlorine spills and other emergencies, including evacuation procedures and procedures for controlling chlorine leaks. The program has been coordinated with the local Emergency Response Committee (Henry County Sheriff's Department). G. Planned Changes to Improve Safety Thirty-three changes were recommended to improve the equipment and the system operating procedures when the chlorine treatment systems were analyzed in November 1996. The recommended changes have been evaluated and will be implemented as required. |