Cutrale Leesburg Facility - Executive Summary |
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1.0 EXECUTIVE SUMMARY 1.1 ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICY SUMMARY The Cutrale Citrus Juices USA, Inc. (Cutrale) Leesburg facility (the Facility) is located at 11 Cloud Street, Leesburg, Lake County, Florida 34748 (see Figure 1-1). The Facility is a critical part of Cutrale's Florida citrus processing operations. The Facility's main functions include extracting and blending juice and essences from oranges, grapefruits, lemons, and limes. Cutrale is committed to operating this and other Cutrale facilities in a manner that is protective of the health and safety of Cutrale and Contractor employees, the public, and the environment. In addition, Cutrale is committed to operating this and other Cutrale facilities in full compliance with applicable Occupational Safety and Health Administration (OSHA) and Environmental Protection Agency (EPA) regulatory requirements. To ensure that the Facility is operated in a safe manner and in compliance with applicable O SHA and EPA regulations relevant to accidental release prevention, Cutrale has developed this integrated Process Safety Management/Risk Management Plan (the Plan). Among the important components of this Plan are Cutrale's system of policies and procedures for operation and maintenance of the Facility, and Cutrale's Emergency Response Plan (ERP) for the Facility. Cutrale has designated its corporate Director of Quality Process and Compliance and the Facility's Manager of Technical Services as the individuals with primary responsibility and accountability for seeing that this Plan and its associated components accurately reflect Facility conditions and that it is fully implemented. 1.2 STATIONARY SOURCE DESCRIPTION The Facility is designed to extract juices and essences from locally grown citrus fruits. These products are either sold to offsite packagers for sale to the public or blended onsite and sold directly to a reseller. To support these primary functions, the Facility op erates four ammonia refrigeration systems. These systems are described below: System Description Type 1 Frozen Concentrate Single-Stage or Two-Stage 2 Food Service Single-Stage or Two-Stage 3 Chill Building (former POJ) Single-Stage 4 Bulk Storage Single-Stage The refrigeration systems are relatively simple systems typical of those that are common throughout the food processing industry. The basic technology involves the recirculation of ammonia, with a change in state from liquid to a liquid/gas mixture, then back to a liquid. Ammonia is delivered to the Facility in its liquid state and is stored in a high pressure receiver. From this vessel, the liquid ammonia is pumped to a recirculator or accumulator (different terminology indicating the same vessel, depending on the age of the vessel), then to the individual pieces of cooling equi pment, which generally include chillers and/or air handlers serving blast freezers, product storage tanks, and the like. The warmed, lower pressure, mainly liquid ammonia is then pumped (with some intermediate steps, depending on the system configuration) to a bank of compressors, from which the ammonia is routed to the condensers, which condense the ammonia to a lower temperature and higher pressure. This flow is then returned to the high pressure receiver previously described. The main difference between the two-stage and single-stage systems is that in a single-stage system, the ammonia flow is routed through only one set of compressors. In a two-stage system, the ammonia flows through two sets of compressors in series. To obtain the maximum intended ammonia inventory, a complex calculation must be performed to account for the quantity of ammonia in each of the major process vessels operating at their normal levels. The detailed calculations are documented in Appendix A of t he RMP, with the results summarized below. System Description Maximum Intended Inventory (lbs of ammonia) 1 Frozen Concentrate 36,400 2 Food Service 12,000 3 Chill Building (former POJ) 17,000 4 Bulk Storage 2,600 1.3 ACCIDENTAL RELEASE PREVENTION PROGRAM The Facility has an aggressive accidental release prevention program that is based upon a foundation of employee awareness and proactive system maintenance. This program is documented in this integrated Plan. The effectiveness of this program, which meets or exceeds all requirements of applicable PSM/RMP regulations, is evident by the fact that the Facility has had no significant releases of ammonia in the two years prior to the date of this Plan, which is the length of time the Facility has been in possession of the current owner. 1.4 FIVE-YEAR ACCIDENT HISTORY In spite of the Facility's aggre ssive release prevention program, the Facility has experienced two significant releases in the five years prior to the date of this plan. The incidents, which are discussed briefly below, are discussed in greater detail in Section 5.1 of this Plan. The first release occurred on January 23, 1995. A pressure relief valve, triggered when three evaporative condensers tripped the electrical breakers at the starters, stuck open resulting in a release of 2,000 pounds of ammonia. There were no reported onsite or offsite consequences, however, ammonia was detected by the general public in the vicinity of Lake Street and U.S. 441. The second release occurred on April 22, 1998. A leak from a globe valve on a bypass suction line resulted in a release of 645 pounds of ammonia. The plant was evacuated, and the public was evacuated from a three block area surrounding the plant. However, there were no reported injuries or impacts resulting from the release. 1.5 EMERGENCY RESPONSE PROGRAM The Facility has an Emergency Response Plan that defines the sequence of actions to be taken by Facility employees in the event of an accidental release of hazardous materials. This ERP has been communicated to the City of Leesburg Fire Department and the Local Emergency Planning Committee (LEPC). It is Cutrale's policy with regard to emergency response that its personnel are trained to the Hazardous Materials Technician Level. These are individuals who are likely to witness or discover a hazardous substance release and who have been trained to initiate an emergency response sequence by notifying the proper authorities of the release. These individuals also are trained to respond to a release by stopping the release, thereby assuming a more aggressive role than those trained to the First Responder Awareness Level. The ERP describes the conditions under which Cutrale personnel would attempt to stop a chemical release, as well as the sequence of actions that would be undertaken un der those circumstances. It is Cutrale's policy for employees to call the Facility's 24-hour guard in the event of any release emergency. It is the responsibility of the guard to call 911. The local Hazardous Materials (HazMat) Response Team has the responsibility to oversee mitigation of the release conditions. The Leesburg Fire Department, in conjunction with Cutrale, is presently responsible for determining when evacuation of offsite areas is necessary, and for public notification. 1.6 PLANNED CHANGES TO IMPROVE SAFETY This Plan incorporates a number of modifications to Facility procedures designed to improve employee safety awareness, enhance safe operation and maintenance of the ammonia systems, reduce the potential for accidental releases to occur, and increase the speed and effectiveness of the Facility's response should a release occur. |