Basic Vegetable Products, L.P. - Executive Summary |
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1. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Basic Vegetable Products uses chlorine for treating process wash water and for process wastewater before disposal to the municipal treatment facility. Before the chlorine is injected into solution, the chemical is considered hazardous by the EPA. This facility recognizes the hazards associated with the use of chlorine gas and the pressurized liquid cylinders at this location. As a reflection of our policy to adhere to all applicable federal, state, and local laws and regulations, we submit this plan to address the hazards inherent with chlorine use. Our program addresses safety precautions regarding the handling and operation of chlorinating systems as well as proper operator training for those who maintain the system. Our accidental release prevention program is clearly defined by the Process Safety Management (PSM) Program for this facility. This prevention program follows industry-recommended standards for prev enting unnecessary human exposures and reducing the threat to the health of our employees as well as to members of the community of King City and the surrounding area. Safety depends upon the manner in which we handle chlorine, the safety devices inherent in the design of this facility, and the training that we provide our personnel. This Plan is current and updated as required by law. Our emergency response plan is incorporated in the Hazardous Materials Business Plan for this plant. The Plan includes procedures for notification of the local emergency responders and of any potentially affected neighbors of the facility. The Plan includes a specific protocol for responding to a chlorine release and assigns an Emergency Coordinator to implement the response. This Plan is current and updated as required by law. It is the policy of this facility to devote the time, energy, and capital toward maintaining prevention and response programs appropriate to the inherent dangers with the us e of hazardous chemicals. 2. THE STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED Basic Vegetable Products is located in King City in the agriculturally productive Salinas River valley of Monterey County. The plant is situated at about 360 feet above sea level on a bluff in the northeast area of the city near the municipal airport. The facility is bordered by Airport Drive on the south, the airport on the east and north, and by Metz Road (Route G15) on the west. Basic Vegetable Products process garlic and onions into a variety of dehydrated products. Raw vegetables are trucked to the site and stored in warehouses or docks prior to washing. An on-site wastewater pretreatment facility processes wastewater using chlorinated water before discharge to the municipal sewer. The only substance at this plant that is regulated by this program is chlorine. The chemical is stored in one-ton cylinders as a pressurized liquid. Vacuum regulators dispense the chlorine as a gas and inject th e chemical into a water piping system to create chlorinated water for process wash water and wastewater pretreatment. The maximum quantity of chlorine that can be stored at this plant is 26,000 pounds. 3. THE WORST CASE AND ALTERNATIVE RELEASE SCENARIOS, INCLUDING ADMINISTRATIVE CONTROLS AND MITIGATION MEASURES TO LIMIT THE DISTANCES FOR EACH REPORTED SCENARIO The worst-case and alternative release scenarios were modeled using ALOHA, a computer simulation program approved by the Monterey County Department of Health and EPA as appropriate for these scenarios. The worst-case release scenario was modeled using the required parameters and provided an estimate of the distance to the toxic endpoint (3.1 miles). The scenario assumes a complete release of liquefied chlorine under pressure from a one-ton cylinder for a duration of ten minutes. The model assumes a low wind speed of 1.5 m/s and a very stable atmosphere. The population within the area potentially affected is essentially the population of King City (approximately 11,000 residents). Public receptors potentially impacted by this worst-case release scenario include schools, residences, hospitals, public recreation areas, and commercial/office/industrial areas. The alternative case release scenario was modeled using typical site and weather conditions and variables appropriate to the release scenario. This more likely (than the worst-case) scenario involves a chlorine vessel leak that could result from earthquake damage to a chlorine cylinder. The distance to toxic endpoint from the point of release is estimated to be approximately 2.0 miles. The model assumes typical weather conditions of 10 mph winds from the northwest and a moderate atmospheric stability class. The population affected by this scenario would be similar to the worst-case scenario. Public receptors potentially impacted by this alternative case release scenario include schools, residences, hospitals, public recreation areas, and commercial /office/industrial areas. 4. THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND THE CHEMICAL SPECIFIC PREVENTION STEPS This facility complies with the California Accidental Release Prevention (CalARP) Program and OSHA's Process Safety Management (PSM) Program. Key prevention steps taken by this facility to maintain safety include operator training, use of a recognized chlorine supplier that tests and certifies its equipment, and the use of vacuum regulation gas feeders that provide inherent safety features. The systems are located in areas sheltered from heat and traffic. Buildings at the facility are equipped with fire sprinklers, the plant is fenced, and traffic egress is controlled by a security guard at the gate. 5. THE FIVE-YEAR ACCIDENT HISTORY There have been no releases of chlorine at this facility in the last five years. 6. THE EMERGENCY RESPONSE PROGRAM The program for emergency response to the release of hazardous chemicals is an integral element of the Hazardous M aterials Business Plan for this facility. This Plan includes release notification for emergency responders as well as potentially affected neighbors. The Emergency Coordinator implements the response as described in the response protocol. 7. PLANNED CHANGES TO IMPROVE SAFETY As a result of the most recent process hazard review, this facility plans to improve safety by upgrading chlorine cylinder restraints, improve training programs, and replace worn piping where necessary. These changes are planned for completion in 1999. The facility also plans to conduct drills and exercises for emergency response on an annual basis beginning in 1999. |