Fowler Packing Company Plant #1 - Executive Summary
General Executive Summary for Fowler Plant #1 |
This report and Risk Management Plan was developed to comply with US EPA and Cal ARP
requirements. Resources used in the process was International Institute of Ammonia
Refrigeration Guidelines, RMP Pro 98 Software by Dyadem
and Cold Storage Technologies.
Report organization includes; Certification statement, Summary, Detailed Elements and Map of
1. Accidental Release Prevention and Emergency Response Policies
We at Fowler Packing Company Plant #1 are strongly committed to employee, public and
environmental safety. This commitment is demonstrated by our comprehensive accidental
release prevention program that covers areas such as design, installation, operating procedures,
maintenance, and employee training associated with the processes at our facility. It is our policy
to implement appropriate controls to prevent possible releases of regulated substances.
2. The Stationary Source and the Regu
lated Substances Handled
Our facilitys primary activities encompass Packing and storage of grape and non-citrus tree
fruit. We have 2 regulated substances present at our facility above threshold quantities. These
substances include Ammonia (anhydrous) and Chlorine. Chlorine quantity on site is below
Federal toxic thresholds and above California thresholds. Ammonia (anhydrous) is used for
Refrigeration and Chlorine for water treatment in a hydro-cooler. Chlorine is kept in 2-150 lb.
cylinders adjacent to the Hydro-cooler. Typical operating quantity of Ammonia (anhydrous) in
the High Pressure Receivers, Condensers and piping that could release at one time is
approximately 50% of the total quantity or 10,000 lb.. This is typical of a flooded Ammonia
system that does not operate seasonally and pump down the system. Since the system has
sufficeint capacity to store the total Ammonia charge on the High Pressure side no active
mitigation is being considered.
3. The Worst Cas
e Release Scenario(s) and the Alternative Release
Scenario(s), including administrative controls and mitigation measures to
limit the distances for each reported scenario
To perform the required offsite consequence analysis for our facility, we have used the EPA's
RMP Guidance for Ammonia Refrigeration Reference Tables or Equations. The following
paragraphs provide details of the chosen scenarios.
The worst case release scenario submitted for Program 2 and 3 toxic substances as a class
involves a catastrophic release from Ammonia Refrigeration. In this scenario 20047 lb. of
Ammonia (anhydrous) is released. The toxic liquid released is assumed to form a 1 cm deep
pool from which evaporation takes place. The entire pool is estimated to evaporate over 10
minutes. The released quantity is assumed to be the total system charge since it can be stored in
the High Pressure Receivers, Condensers and HPL Piping. At Class F atmospheric stability and
1.5 m/s windspeed, the maximum
distance of 2.84 miles is obtained corresponding to a toxic
endpoint of 0.14 mg/L.
The alternative release scenario for Ammonia (anhydrous) involves a Safety Relief Valve failure
and release from the High Pressure Receiver. This scenario based on the recent PHA would be a
more likely worst case scenario. It involves an SRV release rate based on HPR vessel size of
42 lb./min for 60 minutes. Toxic gas is assumed to be released to the atmosphere directly.
Passive mitigation controls of reducing the total release by manually switching to the standby
SRV are taken into account to calculate the scenario. Under neutral weather conditions, the
maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (anhydrous) is 0.19 miles or
1000 ft.. The most common release based on operating experience is a compressor shaft seal
failure. Since these are mitigated by the mechanical room enclosure, off-site impacts are not
common and therefore not allowed as an alternate scenario.
The General Accidental Release Prevention Program and the Chemical-
Specific Prevention Steps
Our facility has taken all the necessary steps to comply with the accidental release prevention
requirements set out under 40 CFR part 68 of the EPA. This facility was designed and
constructed in accordance with applicable mechanical codes. The following sections briefly
describe the elements of the release prevention program that is in place at our stationary source.
Process Safety Information
Fowler Packing Company Plant #1 maintains a detailed record of safety information that
describes the chemical hazards, operating parameters and equipment designs associated with all
Process Hazard Analysis
Our facility conducts comprehensive studies to ensure that hazards associated with our processes
are identified and controlled efficiently. The methodology used to carry out these analyses is
What If/Checklist (combined). The studies are undertaken by a team of qualified pers
expertise in engineering and process operations and are revalidated at a regular interval of 5
years. Any findings related to the hazard analysis are addressed in a timely manner. The most
recent PHA/update was performed on 06/05/1999.
For the purposes of safely conducting activities within our covered processes, Fowler Packing
Company Plant #1 maintains written operating procedures. 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 in the processes.
Our system is remotely monitored and maintained by a qualified Ammonia Refrigeration
Contractor. The system also includes a redundant control system.
Fowler Packing Company Plant #1 has a comprehensive training program in place to ensure that
mployees who are operating processes are competent in the operating procedures associated
with these processes. Refresher training is provided at least every 3 years and more frequently as
Fowler Packing Company Plant #1 carries out highly documented maintenance checks on
process equipment to ensure proper operations. Process equipment examined by these checks
includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems,
emergency shutdown systems, controls and pumps. Maintenance operations are carried out by
qualified personnel with previous training in maintenance practices. Furthermore, these
personnel are offered specialized training as needed. Any equipment deficiencies identified by
the maintenance checks are corrected in a safe and timely manner. A complete Mechanical
Integrity check was recently completed as part of the implementation of IIAR guidelines.
Management of Change
Written procedures are
in place at Fowler Packing Company Plant #1 to manage changes in
process chemicals, technology, equipment and procedures. The most recent review/revision of
maintenance procedures was performed on 05/14/1999. Process operators, maintenance
personnel or any other employee whose job tasks are affected by a modification in process
conditions are promptly made aware of and offered training to deal with the modification.
Pre-start up safety reviews related to new processes and to modifications in established processes
are conducted as a regular practice at Fowler Packing Company Plant #1. The most recent
review was performed on 05/14/1999. These reviews are conducted to confirm that construction,
equipment, operating and maintenance procedures are suitable for safe startup prior to placing
equipment into operation.
Fowler Packing Company Plant #1 conducts audits on a regular basis to determine whether the
provisions set out under the RMP
rule are being implemented. The most recent compliance audit
was conducted on 05/14/1999. These audits are carried out at least every 3 years and any
corrective actions required as a result of the audits are undertaken in a safe and prompt manner.
Fowler Packing Company Plant #1 promptly investigates any incident that has resulted in, or
could reasonably result in a catastrophic release of a regulated substance. These investigations
are undertaken to identify the situation leading to the incident as well as any corrective actions to
prevent the release from reoccurring. All reports are retained for a minimum of 5 years.
Fowler Packing Company Plant #1 truly believes that process safety management and accident
prevention is a team effort. Company employees are strongly encouraged to express their views
concerning accident prevention issues and to recommend improvements. In addition, our
employees have access to all informatio
n created as part of the facilitys implementation of the
RMP rule, including information resulting from process hazard analyses in particular.
On occasion, our company hires contractors to conduct specialized maintenance and construction
activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the
contractor is carried out. Fowler Packing Company Plant #1 has a strict policy of informing the
contractors of known potential hazards related the contractors work and the processes.
Contractors are also informed of all the procedures for emergency response should an accidental
release of a regulated substance occur.
5. Five-year Accident History
Fowler Packing Company Plant #1 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
Fowler Packing Company Plant #1 carr
ies a written emergency response plan to deal with
accidental releases of hazardous materials. 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.
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.
County of Fresno is the Local Emergency Planning Committee (LEPC) with which our
emergency plan has been coordinated and verified.
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. Implementation of IIAR Ammonia
Guidelines for PSM and RMP are some of the major
steps we want to take to improve safety at
our facility. The complete implementation of IIAR guidelines for Ammonia Refrigeration is
expected to be implemented by 9/15/99. Changes resulting from the recent PHA will be in place
within 12 months.