Bidart Bros. Potato Packing House - Executive Summary |
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PREVENTION & RESPONSE POLICY Bidart Bros. uses a comprehensive environmental management system approach to integrate both accidental release prevention and emergency response requirements under the "One Plan" format. STATIONARY SOURCE & REGULATED SUBSTANCES Bidart Bros. potato packing house cleans, culls, and packages potatoes for produce distribution. Ton containers of chlorine are used to sanitize produce wash water. Chlorine is utilized during the potato packing season only, and is not typically maintained above threshold quantities on site during the remainder of the year. Therefore, this initial RMP submission coincides with the date on which chlorine is again seasonally present in the water treatment process, above the threshold quantity, in accordance with the RMP rule. WORST CASE SCENARIO The worst case toxic gas gas release scenario is considered to be a ton container of chlorine releasing its entire contents in ten minutes. The worst case is neither realistic nor likely to occur, but is addressed in the federal regulations primarily as a baseline reference of comparative risk. Theoretically speaking, a complete volatilization of the ton container of chlorine in ten minutes time could produce a vapor cloud of harmful concentrations which may extend over a considerable distance. If such a release were even physically plausible, there could be residential populations (depending on wind direction) and industrial sites affected. Such would not necessarily be the case for the more credible alternative release scenario. ALTERNATIVE RELEASE SCENARIO The alternative toxic gas release scenario is considered to be a slightly damaged valve or fusible plug on the chlorine ton container with a predicted release rate of 15 pounds per minute. This is a more credible worst case scenario and could result in a chlorine vapor cloud of harmful concentrations which may extend a relatively shorter distance from the facility as compared to the theoretical worst case re lease. There could be at least one off-site residental receptor as well as neighboring industrial facilities affected in the more credible alternative release scenario. ACCIDENTAL RELEASE PREVENTION PROGRAM Bidart Bros. has integrated the California Accidental Release Program (CalARP) requirements within a comprehensive environmental management system based on the "One Plan" format. FIVE YEAR ACCIDENT HISTORY Bidart Bros. has not had an accidental release of a regulated substance during the past five years. EMERGENCY RESPONSE PROGRAM Bidart Bros. uses a comprehensive environmental management system approach to integrate both accidental release prevention and emergency response requirements under the "One Plan" format. PLANNED CHANGES TO IMPROVE SAFETY All chlorine containers will be secured to anchored trunnions or otherwise chocked and secured with valves in the 6 and 12 o'clock positions while in service or storage. All regulated substance storage areas will be labeled with the appropriate National Fire Protection Agency (NFPA) hazard warning placards. |