Basic Vegetable Products, L.P. - Executive Summary |
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1. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Basic Vegetable Products uses three hazardous chemicals in its operations that are covered processes under this program. Ammonia is used for process refrigeration; chlorine is used for treating process wash water to ensure a safe municipal water supply; and LPG (butane) is used as a curtailment fuel for the boilers and dryers. This facility recognizes the hazards associated with the use of highly hazardous chemicals. 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 the use of ammonia, chlorine, and LPG. Our program addresses safety precautions regarding the handling and operation of these covered systems as well as proper operator training for those who maintain the systems. 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 preventing unnecessary human exposures and reducing the threat to the health of our employees as well as to members of the community and the surrounding area. Safety depends upon the manner in which we handle these chemicals, the safety devices inherent in the design of this facility and its processes, 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 an ammonia, chlorine, or LPG 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 tow ard maintaining prevention and response programs appropriate to the inherent dangers with the use of hazardous chemicals. 2. THE STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED The Basic Vegetable Products facility is located in the agriculturally productive Central Valley in Modesto, California. The plant is situated at about 90 feet above sea level at the southern border of the city limits of Modesto along Whitmore Avenue. The historically agricultural land south of Whitmore Avenue is currently under residential development by the City of Ceres. The Union Pacific Railroad tracks separate the facility on the west from light industrial businesses. The Kraft Foods facility borders the northern property line of Basic Vegetable Products and shares the same gated entrance on Whitmore Avenue. Approximately 40 acres of agricultural land lie to the east, which in turn, are bordered by Morgan Road on the eastern border. The Basic Vegetable Products facility, operated since 1958, proc esses vegetables into a variety of bulk dehydrated products. The facility operates three shifts throughout the year with some variance depending upon crop availability. Raw vegetables are trucked to the site and unloaded prior to washing in the wet processing building. Once the vegetables have been washed, they are processed, dehydrated, and packaged. Plant security is provided by a guard (two guards at night), located in the guard shack at the main gate entrance to the facility. The security guard provides emergency response support under the direction of the Emergency Coordinator. Parking passes are required to enter the premises. The entire plant is enclosed by a chain-link fence, except at the main gate, where trucks and personnel enter and exit as directed by the plant security guard. All process and office buildings are fire-sprinklered and connected to a centralized, automated alarm system. The three substances at this plant that are regulated by this program are ammonia, c hlorine, and LPG. The mechanical ammonia refrigeration system is a closed loop and is used for product freezing, freeze-drying, chilled air, and chilled water. The system utilizes both liquid pumped overfeed and flooded systems. The maximum quantity of ammonia at this facility is limited by the system capacity of approximately 15,000 pounds. Chlorine is stored in one-ton cylinders as a pressurized liquid. Vacuum regulators dispense the chlorine as a gas and inject the chemical into a water piping system to create chlorinated water for process wash water. The maximum quantity of chlorine that can be stored at this plant is 4,000 pounds, which is limited by written ordering procedures. LPG is stored in three 30,000-gallon steel cylinders on the north side of the facility. The system was originally installed as an alternative fuel source in 1991 and is currently used for natural gas curtailments. The maximum quantity of LPG (butane) that can be stored at this plant is 360,000 pound s, which is the maximum capacity of the three cylinders. 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 for toxic substances were modeled using ALOHA, a computer simulation program approved by the Stanislaus County Department of Environmental Resources and EPA as appropriate for these scenarios. The worst-case release scenario and alternative release scenario for the flammable substance were modeled using the RMP Program Guidance for Propane Storage Facilities document. Simulations for releases provided estimates of the distance to the toxic endpoint for each case. Worst-Case Release Scenarios The worst-case scenarios are not the most likely scenarios but serve to demonstrate the potential effects of catastrophic events. Due to system controls such as proper operating procedures and equipment with inherent safety fea tures, these scenarios have a low likelihood of occurring. For toxic substances, the worst-case scenario assumes a complete release of liquefied chemical under pressure from the largest process vessel for a duration of ten minutes. The model assumes a low wind speed of 1.5 m/s and a very stable atmosphere. The distance to toxic endpoint was determined to be approximately 3.1 miles and involves the release of chlorine gas. The population within the area potentially affected is estimated to be 76,000 residential inhabitants. Public receptors potentially impacted by this worst-case release scenario include schools, residences, prisons or correctional facilities, public recreation areas, and commercial/office/industrial areas. For flammable substances, the worst-case scenario assumes a complete release of liquefied LPG under pressure from a 30,000-gallon cylinder which vaporizes and results in a vapor cloud explosion. A yield factor of 10 percent of the available energy released in th e explosion was used to determine the distance to the explosion endpoint assuming a TNT-equivalent model. The distance to toxic endpoint (1psi overpressure) was determined to be approximately 0.4 miles. The population within the area potentially affected is estimated to be zero residential inhabitants. Public receptors potentially impacted by this worst-case release scenario include commercial/office/industrial areas, primarily to the west of the facility. Alternative Case Release Scenarios The alternative case release scenarios were modeled using typical site and weather conditions and variables appropriate to the particular release scenario. The methodologies used in the worst-case scenarios (ALOHA and RMP Program Guidance for Propane Storage Facilities) were also used for the alternative case release scenarios. The alternative case release scenarios are those scenarios more likely to occur and that will reach an endpoint offsite, if one exists. For ammonia, the alternative sc enarios consist of three release types (vessel fracture, vessel damage, and piping damage). These releases were evaluated due to the likelihood estimates from the Process Hazard Analysis. The distances to toxic endpoints offsite ranged from approximately 400 yards to 1.4 miles. Due to the prevailing winds from the northwest, the impacts are likely to occur in the southeast direction from the facility. The public receptors potentially affected include schools, residences, correctional facilities, public recreation areas, and commercial/office/industrial areas. Though the distances to toxic endpoints are not necessarily realistic estimates of the areas in which the public might be endangered in the event of a release due to inherent uncertainty in the model assumptions, all three scenarios taken together indicate that prevention measures are essential and that emergency response may require evacuation some distance from the plant. Though mitigative measures were not considered in modeling these scenarios, most of the ammonia system equipment is inside buildings. A release is likely to occur inside and exit through the exhaust fan at the roof or be released from exit points at the roof elevation. The elevation of the release could increase dispersion of the ammonia vapor cloud though much of the release would still be subject to typical weather conditions and release as modeled. The sprinkler system will likely reduce the release quantity, also. Control measures at the plant that decrease the chance of any of the above events from occurring include trained and qualified system operators, a preventive maintenance program, and alarms and procedures for response to operation deviations. For chlorine, the alternative scenarios consist of two release types (cylinder valve damage and fire/heat exposure). These releases were evaluated due to the likelihood estimates from the Process Hazard Analysis. The distances to toxic endpoints offsite are estimated to be 1.8 and 2.1 miles, respectively. Due to the prevailing winds from the northwest, the impacts are likely to occur in the southeast direction from the facility. The public receptors potentially affected include schools, residences, prisons and correctional facilities, public recreation areas, and commercial/office/industrial areas. Though the distances to toxic endpoints are not necessarily realistic estimates of the areas in which the public might be endangered in the event of a release due to inherent uncertainty in the model assumptions, both scenarios taken together indicate that prevention measures are essential and that emergency response may require evacuation a significant distance from the plant. Control measures at the plant that decrease the chance of any of the above events from occurring include trained and qualified system operators, a preventive maintenance program, and alarms and procedures for response to operation deviations. The alternative case release scenario mode led for LPG was performed using the guidance tables with a gas factor adjustment for butane. The quantity estimated to be released is approximately 86,000 pounds, resulting in a vapor cloud explosion similar to the worst-case model assumptions. The cause is estimated to be a process piping break due to damage. The distance to endpoint is estimated to be about 0.3 miles and impact commercial, office, and light industrial public receptors to the west of the facility. No residences are located within this range. 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 and the use of qualified system operators. For the ammonia system, prevention measures include the use of qualified contractors and a preventive maint enance program for system components. Regarding the use of chlorine, the facility utilizes a recognized chlorine supplier that tests and certifies its equipment and the system uses vacuum demand regulators that incorporate vital safety features. The system is located in areas sheltered from heat. The LPG system is seldom used but is checked periodically for mechanical integrity and proper operation. 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 As per Section 2750.9, there have been no releases of ammonia, chlorine, or LPG 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 Materials 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 Ammonia System As a result of the most recent process hazard review, this facility plans to improve ammonia system safety by replacing some vessels which lack proper documentation and replace pressure relief valves as per preventive maintenance schedule. The electrical system will be reviewed by a licensed electrical engineer and the buildings and equipment will be reviewed by a structural engineer for seismic integrity. Some equipment will be replaced to reduce ammonia losses. Improvements will be made in the operating procedures and in operator training. These changes are planned for implementation on or before June 1, 2000. On or before September 1, 1999, this facility will review and revise the pressure relief valve system and label lines and valves as per industry standards. In addition, an ammonia detection system will be installed and integrated with emergency shutdown equipment. Training records will be improved, as well as the tagging methods for valves. Protective barriers will be installed near vulnerable system equipment. The water chiller will be replaced and some equipment will be modified. An inspection policy will be developed and implemented for system corrosion. As an immediate measure, the freeze dry coils will be replaced by August 1, 1999. The facility also plans to conduct drills and exercises for emergency response on an annual basis beginning in 1999. Chlorine System As a result of the most recent process hazard review, this facility plans to improve chlorine system safety by installing chlorine gas detectors and scales at the cylinders. This facility will also revise cylinder loading/unloading procedures and provide for seismic review of cylinder restraints by a licensed structural engineer. These changes are planned for implementation on or before June 1, 2000. Protective barriers, a f ence, and a locked gate will be installed on or before September 1, 1999. The facility also plans to conduct drills and exercises for emergency response on an annual basis beginning in 1999. LPG System As a result of the most recent process hazard review, this facility plans to improve LPG system safety by painting any corroded areas of the system equipment and protecting the perimeter to preclude damage. This facility will also revise operating instructions and post loading/unloading procedures at the fill points. These changes are planned for implementation on or before September 1, 1999. The safety relief valves will be replaced and temperature indicators will be installed on or before July 1, 2000. By July 1, 1999 all weeds in the vicinity of the tanks will be removed and a procedure will be implemented to keep weeds and other flammables away from the LPG equipment.. |