FARMER JOHN MEATS - Executive Summary |
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1. EXECUTIVE SUMMARY 1.1 Accidental Release Prevention and Emergency Response Policies CPC complies with the Occupational Safety Health Administration (OSHA), Hazard Communication Standard (HCS), 29 CFR 1910.1200. Employees maintain a file of Material Safety Data Sheets (MSDS) for use. They are trained in proper use of the MSDS and personnel protective equipment. CPC hosts inspections from Regulatory Agency Inspectors, the Fire Department, the Insurance Company, and numerous other agencies regulating heating and cooling systems with related pressure vessels and valves. New and transferred employees are trained concerning the hazards of the job site and instruction includes Hazard Communication, emergency response, and importance of reporting incidents immediately. Training is also provided to Supervisory and Engineering personnel. Outside Contractors are provided with an overview of working conditions and safety practices to be used prior to commencement of work at the facilit y. The facility has full sprinkler system protection, with monitors and alarms as feasible. CPC is undergoing a seismic retrofit as a result of a seismic assessment for the property location, equipment and buildings. New equipment continues to be installed to improve the refrigeration system. The propane system was installed in about 1971. As the equipment is repaired, new bracing and parts conforming to current standards and codes are being used. 1.2 Stationary Source and Regulated Substances (1) Anhydrous Ammonia CPC uses Anhydrous Ammonia as a refrigerant, for processing, storing and preserving pork products. Two separate refrigeration systems contain approximately 6,700 gallons total of anhydrous ammonia distributed among compressors, condensers, vessels, evaporators, and piping. The ammonia is utilized as a high pressure/low pressure gas/liquid and has a pressure temperature range within the system of 10 in/Hg @ -40 degrees F to 160 psig @ 88 degrees F. Liquid ammoni a at (160 psig) is allowed to expand to 15 psig within the coils of a heat exchanger (evaporator, votators, chillers). This process absorbs heat from the product in the room or water in a chiller. The low-pressure super-saturated gas is then returned to the engine room to be compressed and condensed to its liquid state to be reused (see Figure 1-3 Simplified Refrigeration System Flow Chart). The compressors, condensers and high-pressure receiver vessels are located in both North and South Engine Rooms. Evaporators, chillers and low pressure accumulator vessels are utilized in the cooler boxes and production areas throughout the facility buildings. (2) Propane System The Propane System consists of two 30,000-gallon tanks, which can be run separately, a vapor air system, a pump with an explosion-proof motor, and associated piping. A concrete/block wall encloses the tanks with vent holes at the base of the wall. The wall is 6-feet high. The entire tank area is protected by a delug e-type sprinkler system. The propane system is utilized in two ways. The system was installed in accordance with an agreement with the Southern California Gas Company (SCGC) in the late 1971 to 1973 period, to provide "Stand-by" fuel for the plant boilers. Upon notification by the SCGC, procedures are initiated to shut down the gas to the boilers and power them instead with propane. This generally occurs during particularly cold weather, when gas usage peaks. Steam from the boilers is used to heat the vapor air system to 150( to 160(. Once that temperature range is achieved, liquid propane is introduced through a 2-inch pipeline and the gas is shut off. The heat converts the liquid to gas. There are four "guns" or regulators that are pressure sensitive, increasing and decreasing the propane feed to the boilers, based upon the steam demand in plant processing. The tanks are recharged as needed by various suppliers. The propane is delivered in tank trucks. The drivers hook up hoses to the receiver; one to put liquid into the tank and a second hose to pull vapor out. The frequency of recharging the tanks depends primarily on the frequency of "standby" use. The system is rarely called on for stand-by and has not required a recharge of propane in over a year. The more common use of propane at the facility is fueling the forklifts. Liquid Propane is pumped into 5-gallon fuel tanks using the pump and a hose. The Vapor Air System is not required for this operation. There is one trained employee, under the supervision of the Mechanical Superintendent, who performs that tank-filling task. Access to the filling area is limited. The area is fenced and the gate is locked. The Superintendent, the trained worker, and plant security have keys. 1.3 Offsite Consequence Analysis The Offsite Consequence Analysis was performed using population information, sensitive receptors such as schools, hospitals, recreation areas, and convalescent centers. A worst-case scenar io model was run and studied to determine how far the hazardous material was likely to go in the surrounding areas should it be accidentally released into the atmosphere. For ammonia, the worst-case scenario involved the release of 15,000 pounds into the environment, from the one high-pressure receiver. In this case, the worst-case scenario estimated distance to toxic endpoint is approximately 1.46 miles. The estimated population within the affected radius would be 14,627 people. The worst-case scenario for a propane release involved the release of 30,000-gallons from the pressurized storage tank. The estimated distance to toxic endpoint, according to the model run, would be 0.478 square miles. The estimated population within the circle is 1,043 people. The alternate scenario chosen for modeling of a propane release involved the release of 4040 gallons of propane from damaged overhead piping. A working crane causes the damage with a heated engine, which provides an ignition sour ce for the vapor cloud. 1.4 Release Prevention and Chemical-Specific Prevention Steps Anhydrous Ammonia (AHM) Refrigeration System Clougherty Packing Company (CPC) is aware of the effects a release of anhydrous ammonia and Propane could have on the population areas surrounding the facility. In order to insure that equipment is monitored on a timely and orderly fashion, that any necessary repairs or negative deviation situations are resolved as promptly as possible by knowledgeable professionals, CPC employs a full time staff whose function is maintenance of the anhydrous ammonia refrigeration system. The team consists of (1) the Plant Engineer, (2) the Maintenance Superintendent, (3) the Lead Man-Operating Engineer, and (4) a Maintenance Engineer. Inspections and Audits In addition to other specified inspection and audit programs mentioned in this section, the Safety Director and his team conduct a monthly facility "Walk-Through Inspection" which is part of the new CMMS progr am. The CMMS "Safety Route" includes a departmental review of fire extinguishers, and will include other emergency equipment such as self-contained breathing apparatus, and chemical suits. Observations are recorded on an "Inspection" form and deviations are noted and forwarded to the appropriate department for correction. The Safety Director, or designated representative performs follow-up inspections to assure that corrective action is taken in a timely manner. Inspection documentation is maintained in file in the Human Resources office. The maintenance engineers conduct daily inspections on the compressors, pressure gauges, and watch for AHM or oil leaks, oil level, discharge temperature, suction temperature and oil temperature. Also inspected daily are the temperature of condensers, pump leaks, vibration; inspectors check the dump pots and valve operation, the accumulators solenoid valves, and they inspection receivers and evaporators, In addition to internal self-audits and inspections, the following outside organizations conduct periodic inspections and audits:City of Vernon Fire Department, annual inspectionFactory Mutual Insurance Company, semi-annual inspectionsSouthern California Air Quality Management District, annually inspects all permitted operationsOccupational Safety and Health Administration, non-scheduled inspections MainsaverIn 1985 CPC installed "Mainsaver," a computerized maintenance management program. Recently, a Revised Version has been purchased and a full time staff has been hired to better administer the program as well as procedures. Preventative maintenance (PM) work orders are automatically generated based upon the last PM date in conjunction with the inspection frequency date (annual, quarterly, monthly, according to manufacturer's recommendations) for facility equipment including the ammonia refrigeration and propane systems. In the event of a power failure, there are procedures that are followed to shut down and restart the refrigeration system.PropaneIn addition to employee training and system security, the propane system is inspected regularly by outside agencies.CalOSHA conducts inspections of the Propane system every three years. The last CalOSHA inspection was done in June 1999. The Travelers Insurance Company inspects the boiler and pressure rated vessels annually. The most recent inspection was complete in March 1999. A review of the piping on the sprinkler system, under Title 19 of the California Code of Regulations (CCR), is conducted every five years by a California licensed Fire Sprinkler Contractor (Security Fire Inspection). The review was last done in June 1997.There are no recorded incidents relating to the propane system at this facility.Five-Year Accident History There have been three accidents recorded for the anhydrous ammonia system in the past five years. There are no accident reports involving the propane system recorded in either plant or fire department records within the pa st five years and more.Emergency Response Program CPC has a written Emergency Response Plan (ERP) that was updated in March 1998. The Safety Director and Plant Manager are responsible for the Emergency Response Program (ERP), and for assuring that the program is reviewed and revised as needed and at periodic intervals (minimum every 2 years). The written plan includes evacuation procedures and employees have been trained in ERP activities. Copies of the evacuation plan are located in several areas of the plant.The ERP insures that supervisory personnel on each shift are trained in Cardio Pulmonary Resuscitation (CPR), first aid and basic fire fighting techniques. Security personnel are also trained in CPR and first aid.The bilingual (Spanish and English) evacuation procedures (see "Clougherty Packing Company - Evacuation Procedures," Figure 2-2) and muster areas are thoroughly reviewed during the employee's orientation training and are posted in each department.Evacuation drills ar e conducted on a rotating departmental basis throughout the year, with a goal of two evacuation drills per department per year (see Figure 2-3). Beginning in 1994 there will be a full plant evacuation conducted annually. Drills are carefully audited and evaluated to assure that any noted deficiencies in the plan are corrected. When evacuation of either the full facility or a portion thereof is required, notice is made by public address system, horn, two-way radio, bull horns, telephones (landline or mobile), or a combination of these methods.Employees leave the premises and proceed to the designated muster area where a head count is made by the supervisor or his representative. The employees remain in this area until the "all clear" signal is given.Health service personnel (nursing staff) proceed directly to the main gate area when the Emergency Equipment Shed is located. In the case of an actual emergency, a shelter tent will be erected in this area to treat critically injured personnel prior to the arrival of the outside emergency response.Planned Changes to improve safety There is ongoing work to retrofit many tanks, some structures and piping as a result of the seismic study conducted for the original RMPP. Old equipment, identified during the study is either scheduled for replacement or has already been replaced. Written safety programs are in effect, with employee training. Some improvements have been recommended and will be carried out. Clougherty Packing Company is committed to safety for personnel and for surrounding areas. SECTION 1. EXECUTIVE SUMMARY _____________________________________________________________________________RMP Clougherty Packing Company 1-5 RMP Clougherty Packing Company 1-1 |