River Ranch Fresh Foods, Inc. - Executive Summary |
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1 Accidental Release Prevention and Emergency Response Policies We at River Ranch Fresh Foods, Inc. are strongly committed to employee, public and environmental safety. This commitment is inherent to a comprehensive accidental release prevention program in place 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. If such a release does occur, our emergency response personnel are at hand to control and mitigate the effects of the release. We are also completely coordinated with Monterey County LEPC, which provides additional emergency response expertise. 2 The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass processing of fresh vegetables, primarily salads. The plant is located at 1085 Abbot Street, Salinas CA 93901-4501 in Mo nterey County. The location of the plant in relation to the community of Salinas is depicted in Figure 1, Facility Plot Plan. The latitude and longitude of the facility is 36039'22" N / 121037'59". We have one regulated substance, ammonia, at our facility, which is used to provide refrigeration for the cooling, cleaning, and packaging of vegetables. The maximum inventory of ammonia at our facility is 18,000 lb. 3 The Worst Case Release Scenario and the Alternative Release Scenarios, 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 dispersion modeling software program ALOHA and equations provided by the EPA in the RMP Offsite Consequence Analysis Guidance. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 3 toxic substances as a class involves a catastrophic relea se from the Ammonia Refrigeration System. The scenario involves the release of 9,900 lb. of ammonia in a gaseous form over 10 minutes. At Class F atmospheric stability and 1.5 m/s wind speed, the maximum distance of 1.7 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. No credit has been taken for existing active and passive mitigation systems that, if used, are likely to reduce the maximum distance to the toxic endpoint. Two alternative release scenarios have been submitted for ammonia present in the process. The first alternative release scenario for ammonia involves a release from the Ammonia Refrigeration System process. The scenario involves the release of 560 lb. of ammonia in a liquid form over 8 minutes. The release is also assumed to be controlled by active mitigation measures that include operator intervention. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of ammonia is 0.23 miles. The second alternative rel ease scenario also involves a release from the Ammonia Refrigeration System process. This scenario involves the release of 2,142 lb. of ammonia in the gaseous form over an hour through a pressure relief valve. The release is also assumed to be controlled by active mitigation measures that include operator intervention. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of ammonia is 0.09 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 and 19 CCR '2735.5 of the California Accidental Release Prevention (CalARP) Program. The Ammonia Refrigeration process at our facility is subject to the OSHA PSM standard under 29 CFR 1910.119 and the CalOSH standard under 8 CCR '5189(d). Our facility is also subject to EPCRA Section 302 notification requir ements. The following sections briefly describe the elements of the release prevention program that are in place at our stationary source. Process Safety Information River Ranch Fresh Foods 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 process are identified and controlled efficiently. The methodology that has previously been used to carry out these analyses is HAZOP. 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. Operating Procedures For the purposes of safely conducting activities within our covered processes, River Ranch Fresh Foods 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 process. Training River Ranch Fresh Foods 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 three years and more frequently as needed. Mechanical Integrity River Ranch Fresh Foods carries out 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 qualifi ed 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. Management of Change Written procedures are in place at River Ranch Fresh Foods to manage changes in process chemicals, technology, equipment and procedures associated with the ammonia refrigeration process. 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 River Ranch Fresh Foods. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placi ng equipment into operation. Compliance Audits River Ranch Fresh Foods conducts audits on a regular basis to determine whether the provisions set out by the CalARP program rule are being implemented. 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 River Ranch Fresh Foods 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 River Ranch Fresh Foods 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 CalARP program, 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. River Ranch Fresh Foods 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 ammonia occur. 5 Five-year Accident History River Ranch Fresh Foods has had a good record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, only two accidental releases have occurred during this period. These re leases took place on February 27, 1995 and involved 50 lbs. of ammonia and the other July 5, 1995 and involved 30 lbs. of ammonia. The first incident was a result of human error, and the second mechanical failure. No deaths or injuries occurred offsite as a result of either of these accidents. Onsite, there was one (1) employee who was affected by the first accident and twenty-five (25) employees by the second accident. 6 Emergency Response Plan River Ranch Fresh Foods 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. Monterey County 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. Improved mechanical integrity for the ammonia detection system, an increased level of awareness for general employees on the hazards of ammonia, implementation of a formal training program, and a management system to track changes to the facility are some of the major steps we want to take to improve safety at our facility. These changes are expected to be implemented by June, 1999. |