Sun-Maid Growers of California- Ripperdan - Executive Summary |
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General Executive Summary for Sun-Maid Growers of California - Ripperdan Dehydrator 1. Accidental Release Prevention and Emergency Response Policies The primary function of the Ripperdan Dehydrator is to receive fruit and to act as a fruit dehydrator. Two months out of the year, usually September and October, sulfur dioxide is used in the production of one type of dehydrated fruit. By virtue of the toxic effects of high concentrations of sulfur dioxide, it is necessary to observe certain safety precautions in the handling of the sulfur dioxide, to prevent unnecessary human exposure , to reduce the threat to our own personal health as well as the health of our co-workers, and to reduce the threat to nearby members of the community. We are strongly committed to employee, public and environmental safety. Safety at our facility depends on the manner in which we handle sulfur dioxide as well as on the various safet y devices incorporated into the design of our equipment. Furthermore, comprehensive training received by our employees adds to the inherent safety of our dehydrator facility. Our emergency response program is based upon The Safe Use and Handling of Sulfur Dioxide Ton Drums from Snowden Enterprises. In addition to the presence of appropriate controls to prevent possible releases of sulfur dioxide, if a release does occur , we are completely coordinated with the Madera County Fire Department, which provides highly trained emergency response personnel to control and mitigate the effects of the release. 2. The Stationary Source and the Regulated Substance Handled. The primary purpose of this facility is to receive and dehydrate fruit. Sulfur dioxide is used in part of the operation. Sulfur Dioxide arrives at our facility via trucks in one ton drums and is stored in a storage area. Access to this site is restricted to authorized facility employees, authorized management personnel an d authorized contractors. The regulated substance handled at this facility is sulfur dioxide. The maximum amount of sulfur dioxide that is stored at this plant is 14000 lbs. 3. Worst Case Release Scenario and the Alternate Release Scenario, Including Administrative Controls and Mitigation Measures to Limit the Distances for Each Reported Scenario. We have calculated worst case release scenarios based on the EPA Risk Management Program Guidance For Wastewater Treatment Plants (40 CFR Part 68). For alternative release scenario analyses, we again used the EPA Risk Management Program Guidance For Wastewater Treatment Plants (40 CFR Part 68). The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for the Ripperdan Dehydrator involves a catastrophic release from sulfur dioxide. The scenario involves the release of 2000 lbs. of sulfur dioxide. It is assumed that the entire quantity is released as a toxic vapor cloud. Under worst case weather, the maximum distance of 3.1 miles was obtained corresponding to a toxic end point of 0.0078 mg/L (3ppm). The likelihood of DOT Approved one ton drums of releasing their entire contents while resting on the ground and in a secured area seems extremely remote. The alternative release scenario submitted for Program 2 toxic substances involves a release from sulfur dioxide resulting in a toxic vapor cloud. In this scenario a 3/8" transfer pipe liberates sulfur dioxide for 10 minutes. The release would be mitigated by the closing of valves in the system. Under neutral weather conditions, the maximum distance to the toxic endpoint is .13 mile. In either of these two above scenarios a gas tight sealed concrete block structure is immediately adjacent to the storage and hook-up area. Any large leaking container would be put in this building and it would prevent any continued leaking of the contents. The damaged container would be transferred or repaired in this structure. Also water sprays are routinely used to take the sulfur dioxide vapor out of the air. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA.The following sections briefly describe the release prevention program that is in place at our stationary source. Safety Information The Ripperdan Dehydrator maintains a record of written safety information, which describes the chemical hazards, operating paramters and equipment designs associated with all aspects of our dehydrating facility. Hazard Review A checklist methodology is used to carry out hazard reviews at our facility. The review focus on operating procedures, equipment functions and handling practices to identify possible hazards. The studies are undertaken by qualified personel with extensive knowledge of facility operations and are revalida ted at a regular interval of 3 years. Any finding related to the hazard reviews are addressed in a safe and timely manner. Operating Procedures For the purposes of safely conducting activities within our covered process, Ripperdan Dehydrator maintains written operating procedures. The information is regularly reviewed and is readily accessible to operators involved with the processes. Training Ripperdan Dehydrator has a comprehesive training program in place to ensure that employees that are operating processes are completely competent in the operating procedures associated with these processes. New employees receive basic training in process operations followed by on-the-job supervision until they are deemed competent to work independently. Refresher training is provided at least every year and more frequently as needed. Maintenance Ripperdan Dehydrator carries out maintenance checks on the process equipment to ensure proper functioning. Maintenance activities are carried out by qualified personnel with previous training in these practices. Furthermore, personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and prompt manner. Compliance Audits Ripperdan Dehydrator conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. These audits are carried out at least every 3 years and any corrective actions as a result are undertaken in a safe and prompt manner. Incident Investigation Ripperdan Dehydrator promptly investigates any incident that has resulted in, or could reasonably result in, a catastrophic release of sulfur dioxide. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from recurring. All reports are retained for a minimum of 5 years. 5. Five-year Accident History Sun-Maid Growers has only owned the Ripper dan Dehydrator for 3 years at this time, there have been no accidental releases during this time period. 6. Emergency Response Plan Ripperdan Dehydrator carries a written emergency response plan to deal with the accidental releases of sulfur dioxide. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. Our facility's emergency response plan is based on The Safe Use and Handling of Sulfur Dioxide Ton Drums, from Snowden Enterprises. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our process that would require a modified emergency response. Madera County Environmental Health Department is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes To Improve Safety There are no changes that are planned at this present time. 8. Certification Statement The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. Name: Signature: Title: Date signed: |