Cutrale Auburndale 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. USA (Cutrale) Auburndale facility (the Facility) is located at 602 McKean Street, Auburndale, Polk County, Florida 33823 (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 ap plicable OSHA 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 Director of Auburndale Operations 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, t he Facility operates four ammonia refrigeration systems. These systems are described below: System Description Type Location 1 Main Two-Stage Throughout main plant 2 Essence Tank Farm Single-Stage Between bldgs. 37 and 45 3 Old Tank Farm Single-Stage Between bldgs. 36 and 37 4 New Tank Farm Single-Stage Bldg. 56 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 ag e of the vessel), then to the individual pieces of cooling equipment, 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 determine 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 le vels. The detailed calculations are documented in Appendix A, with the results summarized below. System Description Maximum Intended Inventory (lbs of ammonia) 1 Main 55,000 2 Essence Tank Farm 550 3 Old Tank Farm 1,800 4 New Tank Farm 6,000 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. This program meets or exceeds all requirements of applicable PSM/RMP regulations. 1.4 FIVE-YEAR ACCIDENT HISTORY In spite of the Facility's aggressive release prevention program, the Facility experienced t wo significant releases that occurred within a 24 hour period spanning January 8, 1999 and January 9, 1999. The incidents, which are described briefly below, are discussed in greater detail in Section 5.1 of this Plan. The first release occurred during a production changeover at 3:53 p.m. on January 8, 1999. Due to an operator error, an explosion of an ammonia refrigeration jacket on a process tank occurred resulting in a release of 3,250 pounds of ammonia from the bulk blend tank system over a period of approximately 2 hours and 37 minutes. Six employees were treated and transported to the hospital. The plant was evacuated, however, there was no public evacuation and there were no off-site consequences. An assessment of the total ammonia system was conducted prior to re-start. The second release occurred during system start-up at 6:10 a.m. on January 9, 1999. Due primarily to operator error, a valve was opened allowing pressurized liquid ammonia to enter an abandoned pipe, res ulting in a pipe break and the release of 5,790 pounds of ammonia over a period of approximately 7 hours and 50 minutes. Three employees were treated and transported to the hospital. The plant was evacuated, however, there was no public evacuation and there were no off-site consequences. Contributing causes of the release included the prior Facility owner not properly indicating the pipe on Facility drawings, and the valve not being disabled. 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 Auburndale 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 subst ance 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 under 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 Auburndale 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. |