Fowler Packing Company Plant #1 - Executive Summary |
|
General Executive Summary for Fowler Plant #1 Introduction 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 Potential Impact. 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. 4. 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 processes. 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 onnel with 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. Operating Procedures 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. Training Fowler Packing Company Plant #1 has a comprehensive training program in place to ensure that e 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 needed. Mechanical Integrity 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-startup Reviews 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. Compliance Audits 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. Incident Investigation 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. Employee Participation 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. Contractors 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. |