Enns Packing Co., Inc. - Executive Summary
General Executive RMP Summary for Enns Packing |
1. Accidental Release Prevention and Emergency Response Policies
We at Enns Packing Co., Inc. 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 Regulated Substances Handled
Our facility's primary activities encompass Packing and storage of grapes and non-citrus tree fruit. We have 3 Federal and State regulated substances and one regulated by the State only at our facility. Ammonia (anhydrous) is the only substance above Federal and/or State minimum thresholds. Propane, Sulfur dioxide (anhydrous) and Methyl Bromide are below State and federa
l thresholds. Ammonia (anhydrous) is used for Refrigeration. Propane is used for fork lift fuel. Sulfur dioxide (anhydrous) and Methyl Bromide are used for fumigation.
The maximum inventory of Ammonia (anhydrous) at our facility is 35308.40 lb. distributed in various vessels, pipes and coils. Regulated substances falling below minimum threshold criteria are 4848 lb. of Propane in a single vessel, Sulfur dioxide (anhydrous) in 70 lb. cylinders at 3 locations totaling 560 lb. and Methyl Bromide in 5 - 175 lb. cylinders or 875 lbs..
3. Worst Case and Alternative Scenario Description
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 equipment. In this
scenario 13461 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 has been limited to 38 % of the maximum capacity of the source by typical flooded Ammonia system design and limited High Pressure Receiver capacity. In the event of a leak/rupture liquid NH3 in room evaporators cannot return to the HPL side. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 1.42 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. Because of the rural location and prevailing wind potential for off-site exposure would be minimal. The owner and several other family members live onsite and are closer than public receptors.
The alternative release scenario for Ammonia (anhydrous) involves a release from Ammonia Refrigeration equipment. The scenario involves releasing 1500 lb. from a typical sigh
t glass, seal, valve or gasket failure on liquid vessels or piping. Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 15.00 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (anhydrous) is 0.085 miles.
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 NFPA-58 Standard, 1967 Edition. The following sections briefly describe the elements of the release prevention program that is in place at our stationary
Process Safety Information
Enns Packing Co., Inc. maintains a detailed record of safety information that describes the chemical hazards, operating paramet
ers 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 personnel 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 05/28/1999.
For the purposes of safely conducting activities within our covered processes, Enns Packing Co., Inc. 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 i
s regularly reviewed and is readily accessible to operators involved in the processes.
Enns Packing Co., Inc. has a comprehensive training program in place to ensure that employees 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.
Enns Packing Co., Inc. 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 a qualified personnel or Refrigeration Contractor with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are cor
rected in a safe and timely manner.
Management of Change
Written procedures are in place at Enns Packing Co., Inc. to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 05/28/1999. 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 Enns Packing Co., Inc.. The most recent review was performed on 05/23/1999. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation.
Enns Packing Co., Inc. 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 during March of this year. At this time we elected to implement the International Institute of Ammonia Refrigeration Guidelines for PSM and RMP. 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.
Enns Packing Co., Inc. 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.
Enns Packing Co., Inc. 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 information created as part of the facility's 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. Enns Packing Co., Inc. has a strict policy of informing the contractors of known potential hazards related the contractor's 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
Enns Packing Co., Inc. 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 repotable accidental release during this period.
6. Emergency Response Plan
Enns Packing Co., Inc. carries 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.
Tulare County Environmental Health 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 el
ements of our accidental release prevention program.
Adoption of the International Institute of Ammonia Refrigeration Process Safety Management and Risk Management Program procedures and standards along with more frequent Safety Relief Valve replacements are some of the major steps we want to take to improve safety at our facility.
These changes are expected to be implemented during the next 12 months.