Dole Fresh Vegetables, Inc. - Executive Summary |
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A. Executive Summary RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Dole Fresh Vegetables' Marina Cooling facility utilizes inspection procedures to review refrigeration equipment prior to seasonal startup and during operations. These procedures identify potential sources of release and equipment corrections required to prevent these releases. The equipment is reviewed by onsite personnel, registered engineers, and certified refrigeration contractors as required. Incidental emergency response is provided by onsite personnel. Onsite personnel will make a preliminary assessment in the event of a release and will provide first response. First response may include emergency equipment shutdown, system isolation, or controlled operations such as pump down to prevent or reduce an off-site release. Emergency response for a major release event will be provided by local fire and police departments with mutual aide response. Emergency response training is conducted yearly and as required for new employees. All ammonia refrigeration maintenance and operations personnel are required to be trained and become familiar with the company's Safety and Operating Procedures and Emergency Response Plan. Maintenance and operations personnel will also be required to become familiar with this RMP. DESCRIPTION OF SOURCE AND SUBSTANCE HANDLED This facility utilizes anhydrous ammonia in it's produce cooling and cold storage operations. OFFSITE CONSEQUENCE ANALYSIS An off-site consequence analysis was performed to identify the hazards posed to surrounding communities and sensitive population impacts. This analysis was performed by evaluating ammonia releases under a Worst-case release scenario and under am Alternative release scenario. Releases were evaluated for distance to toxic endpoints with the use of the lookup tables located in the Model Risk Management Program and Plan for Ammonia Regrigeration. This model plan was prepared under contract with the EPA by S cience Applications International Corporation (SAIC). The use of these lookup tables is recommended by the RMP Off-site Consequences Analysis Guidance as prepared by the EPA. WORST CASE RELEASE SCENARIO This scenario considers the worst case release of all ammonia in the largest system considering administrative and passive controls that limit the quantity of releases. Administrative controls limit the quantity of ammonia in the cold room/dock system to 12,000lbs. The assumptions required by EPA for a worst case release analysis are conservative. For this scenario the ammonia is released as a gas in a period of 10 minutes. The distance to the EPA endpoint is calculated is off-site. The worst-case scenario is unlikely because the company has employed the following control and mitigating measures. * Industry standards and quality controls were followed in the design of this equipment at its manufacture. * Ammonia is not corrosive in this process * Pressure safety valves limit the operating pressures in the receiver * The facility utilizes a preventive maintenance program to maintain the on-going integrity of the vessel * The facility has a training program that insures only qualified personnel operate the system * The facility requires that all PSM elements as well as company maintenance policies are followed * The facility has trained emergency response personnel and procedures on site to respond quickly to isolate any potential releases. * Only trained and authorized personnel have access to the system * The system was designed using standard practices and is maintained by rigid company standards * The maintenance program includes a mechanical integrity audit system * The maintenance program includes a by shift monitoring of the refrigeration system * Low level controls, sensors for ammonia monitoring, and available liquid supply to the PRU1 would act as active mitigation before the event met the outlines (and modeled) conclusions * The piping is routed t o avoid impact from traffic sources. ALTERNATIVE RELEASE SCENARIO This scenario considers a release from a leaking flange or fitting on a low pressure pumped liquid line. The ammonia is released at a rate of 26.23lbs/min. Due to the low pressure and temperature of the liquid, flashing will be minimized. Ammonia will be released primarily as a liquid that may form a slowly evaporating pool. Pool evaporation was not considered and this release was evaluated as releasing directly to atmosphere at the rate of release of the discharge liquid. The emergency response time was estimated to be 60 minutes. This time was considered to be the duration of the release and used to calculate the quantity released 1,575lbs and the EPA endpoint was off-site. ACCIDENTAL RELEASE PREVENTION PROGRAM As described above, the program consists of pre-startup inspection, emergency response, and regular training. A thorough review of the system including a Hazop analysis was performed prior to startup for the 1998 season. Equipment corrections and updates were made for those items determined to have the highest potential for off-site releases. Safety and equipment operational training will be conducted on a yearly basis and will include equipment operational procedures, emergency response procedures, review of Business Response Procedures, and evacuation procedures. Refrigeration equipment will be reviewed as required when changes to equipment occur or when new equipment is brought on site. FIVE YEAR ACCIDENT HISTORY No reportable releases or accidents relating to the release of ammonia refrigerant have occurred at the facility in the last five years. EMERGENCY RESPONSE PROGRAM The facility has implemented the State and County mandated emergency response plan. This plan outlines procedures for emergency ammonia release response as well as general facility response. PLANNED SAFETY IMPROVEMENTS Dole will fully implement the RMP and will initiate appropriate changes as n eed to maintain a safe operation. |