Campbell Soup Supply Company LLC -Sacramento Plant - Executive Summary |
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A. Describe the Accident Release Prevention and Emergency Policies It is the policy of Campbell Soup Supply Company that the receipt, storage, and handling of chlorine at its facility in Sacramento, CA be done in a manner that meets regulatory requirements and minimizes the probability and severity of releases of chlorine to the atmosphere in order to protect the health and safety of its workers, the public, and the environment. In order to accomplish this goal, Campbell Soup Supply Company has gathered safety information on chlorine, performed a structured assessment of hazards of the process and external events that might affect the process, performed an offsite consequence analysis of defined release scenarios, established a written program for prevention and mitigation of releases, and established a written emergency action plan coordinated with emergency response agencies. The Manager-Maintenance is responsible for the management of the chlorine safety program. B. Stationar y Source and Regulated Substances Handled The Campbell Soup Supply Company prepares food ingredients, blends food ingredients, and fills food products into containers for sale throughout the Western United States. The facility uses chlorine at the site as a disinfectant for process water. The chlorine inventory is approximately 4,000 pounds. Chlorine is the only regulated substance handled at the Sacramento Plant. C. Summary of Worst-Case and Alternative Release Scenarios The worst-case release scenario at the Sacramento 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 conditions, the resulting vapor cloud could have off-site consequences. The alternative release scenario at the Sacramento Plant involves the release of 2 pounds of chlorine over a 1 minute period due to an error in a container hook-up. 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 system; o The facility has 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 system is operated by qualified personnel. D. Description of the Accidental Release Prevention Program The facility has an accident release prevention program that complies with the California Accidental Release Prevention Program (CalARP), OSHA's Process Safety Management Standard and EPA's Risk Management Program Regulation. The prevention program consists of the following elements: o Employee Participation P rogram 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 Sacramento Plant during the previous five years that resulted in significant on-site or offsite consequences. F. Description of the Emergency Action Plan An emergency action plan has been implemented at the Sacramento Plant. The emergency action plan for this facility consists of notifying first responders and evacuating personnel to designated assembly areas upwind of the release location. The plan has been coordinated with local response agencies. G. Planned Changes to Improve Safety Six changes were recommended to improve the equipment and the system oper ating procedures when the chlorine treatment system was analyzed in 1994. The recommended changes have been evaluated and will be implemented as required. |