Ito Packing Company, Inc. - Executive Summary |
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EXECUTIVE SUMMARY MINIMIZING RISK THROUGH PLANNING, PREVENTION AND SAFETY - BENEFITING BUSINESS, EMPLOYEES AND THE PUBLIC. 1. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Ito Packing Company, Inc., is a family-owned and operated business with approximately 5,000 acres of stone fruit and grape vineyards throughout Fresno, Kings, Tulare and San Luis Obispo Counties. The main plant is located just within the Reedley city limit, to the northwest of town at Reed and South Avenues, and a maintenance facility is located just outside of the city limit to the northeast of town, on Buttonwillow and South Avenues. The refrigeration facility includes a pre-cooler and cold storage warehouse with 2,500 tons of cooling capacity for storage and shipment of produce. The original ammonia-based refrigeration system was erected in 1972 and the existing facility was completely updated and expanded in 1984. Ito Packing Company is committed to receiving, storing and operating the ammonia refrigeration and propane systems in a manner that is safe to the operators and friendly to the environment. It is the policy of the company to provide and maintain a safe and healthful environment and to follow operating practices. This program is vigorously endorsed to prevent injuries or accidents and to avoid the suffering and economic loss associated with the accidents. By virtue of the hazardous and flammable effects associated with ammonia and propane, it is necessary to observe certain safety precautions in handling these substances 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 upon the manner in which we handle hazardous substances as well as on the various safety devices incorporated into the design of our equipment. Furthermore, comprehensive training received by our employees adds to the inherent safety of our distribution facility. Our Risk Management Program (RMP) is based upon the federal standard outlined in OSHA's Process Safety Management (OSHA 3132) and NPGA's LP-Gas Safety Handbook / Guidelines for Developing Plant Emergency Procedures / How to Control LP-Gas Leaks and Fires / OTHER STANDARD or GUIDELINE. In addition to the presence of appropriate controls to prevent possible releases of propane, if a release does occur, we are coordinated with the Reedley City and Fresno County Fire Dept, which provides highly trained emergency response personnel to control and mitigate the effects of the release. The intent of Ito Packing Company is to maintain only one Risk Management program which will include the requirements of OSHA, EPA and Cal ARP. This program is referred to as the Process Safety Management/Risk Management Plan, or the PSM/RMP program. The PSM/RMP program covers both components and systems as it relates to anhydrous ammonia and propane. 2. PROCESS DESCRIPTION Anhydrous ammonia is acutely hazardous and propane a flammable material as defined by the OSHA 29 CFR 1910.119 and the EPA 40 CFR 68. The threshold quantity for these materials is established in appendix A of OSHA 1910.119 at 10,000-pounds. The CalARP program establishes a 500-pound threshold quantity. The Ito Packing Company system is thus subject to the requirements of both the OSHA 29 CFR 1910.119, the Process Safety Management Standard and the Cal ARP requirements. The two materials are 72,000 pounds of anhydrous ammonia, which is required for the operation of the cold storage units; and 80,000 lbs of propane, which is used strictly for filling the fuel tanks of forklifts and ranch vehicles. The ammonia storage/receiver tank is located in a secured area authorized for technicians only. The propane is stored in 2 tanks on the eastside of the plant and access to this site is restricted to authorized facility employees and management personnel. Both products are received via truck from authorized and trained distributors. 3. The Worst Case Release Scenarios and the Alternative Release Scenarios We have calculated the worst case release scenarios based on the RMP Comp off-sight consequences model downloaded from the federal Environmental Protection Agency @ www.epa.gov/ceppo/ The following paragraphs provide details of the chosen scenarios. Ammonia is classified as a Program 1 process. Our main receiver tank is filled to 80% capacity. Which calculates to 72,000 pounds. If the site column (protected by barriers and guards) was somehow broken off, the tank could possibly release the entire contents. In the event of a release, in this case, a worst case scenario, the ammonia would release in two forms: liquid and gas. Of the liquid portion released it would create a white vapor cloud and strong ammonia odor. A portion of the liquid, about 25% would vaporize immediately - the remaining liq uid will accumulate into very cool pools of liquid. The ammonia gas released is lighter than air and will be carried by air movement and rise slowly into the atmosphere. Under wind conditions and atmosphere, the end point of such a release would reach 2.3 miles from its origin. In the case of the main plant, the end point of the vapor would reach the entire circumference of the city, except on the very south end of town, where it would dissipate at about Cricket Hollow or the length of Olson Avenue. Propane is classified as a Program 1 process. The worst case scenario considered for this process involves a release of 38,400 lb. of propane from our Tank 1. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the maximum distance to the flammable endpoint of is 0.10 miles. This distance is less than the distance to th e nearest public receptor. Alternative Release Scenarios Our ammonia system is protected by a variety of mechanical safety systems that should prevent an accidental release (spring loaded, safety relief valves, isolation valves, purge valves). If a pop-off occurred, and the device failed to open, the result would be release of 25 pounds of ammonia into the atmosphere over a period of one minute - reaching an end point of 1/10th of a mile. There are no public receptors within this distance. For an alternative propane release - occurring during the filling of the tank, a small amount could be released due to operator error. As previously noted in the worst case scenario, any amount does not reach a public receptor. 4. The Accident Release Prevention and Emergency Response Policies at the Facility: Ito Packing Company has taken all the necessary steps to comply with the accident 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 Ito Packing Company maintains a detailed record of written safety information, which describes the chemical hazards, operating parameters and equipment designs associated with all aspects of our distribution facility. Hazard Review A checklist methodology is used to carry out hazard reviews at our facility. The reviews focus on operating procedures, equipment functions and handling practices to identify possible hazards. The studies are undertaken by a team of qualified personnel with extensive knowledge of facility operations and are revalidated at a regular interval of 5 years. Any findings 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 processes, Ito Packing Company maintains written operating procedures, computerized monitoring of ammonia refrigeration systems a nd various alarm functions. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved with the processes. Training Ito Packing Company has a comprehensive 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 annually, when certification requires, or change warrants. Maintenance Ito Packing Company carries out highly documented maintenance checks on process equipment to ensure proper functioning. Maintenance activities are carried out by qualified personnel w ith 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 timely manner. Compliance Audits Ito Packing Company 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 5 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Ito Packing Company promptly investigates any incident that has resulted in, or could reasonably result in, a catastrophic release of ammonia or propane. 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 Ito Packing Company has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. 6. Emergency Response Plan Ito Packing Company carries a written emergency response plan to deal with accidental releases of ammonia or propane. 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 upon the OSHA PSM and EPA's RMP, compliance standard, IIAR Guide to Good Practices, MSDS for anhydrous ammonia and propane, 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 processes that would require a modified emergency response. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. 7 Good safety awareness through an effective safety program 7 Computerized monitoring of refrigeration systems and functions 7 24-hour security provided with monitors to observe the refrigeration system limits 7 Extensive preventative annual maintenance program during off-season Listed below are some of the major steps we want to take to improve safety at our facility. 7 More training through RETA and IIAR for our technicians 7 Install/upgrade computer monitoring system 7 Update all of our ammonia/propane safety and procedure manuals These changes expected to be implemented by May 1, 2000 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 Daniel C. Brake: Signature: __________________________________ Title: Safety Manager Date signed: March 2, 1999 |