Stemilt Growers, Inc - Executive Summary |
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A. Stemilt Growers, Inc. accidental release prevention policy involves a unified approach that integrates technologies, procedures, and management practices. It is the policy of Stemilt Growers, Inc. to adhere to all applicable federal and state safety and environmental regulations. Stemilt Growers, Inc. emergency response policy involves the preparation of response plans and training of employees in evacuation and the handling of minor ammonia releases. At Stemilt Growers, Inc. anhydrous ammonia is used on-site. Ammonia is considered hazardous by EPA and is listed on the Extremely Hazardous Substance (EHS) list. Chemical properties of ammonia make it necessary to observe certain safety precautions in handling ammonia to: (i) Prevent unnecessary human exposure, (ii) Reduce the threat to our personnel, (iii) Reduce the threat to the community. B. Stemilt Growers, Inc. is fruit processing and cold storage facility, north of the city of Wenatchee, county of Chelan, state of Washi ngton. The regulated substance used at Stemilt Growers, Inc. is anhydrous ammonia (CAS# 7664-41-7). The use of anhydrous ammonia is as a refrigerant. Stemilt Growers, Inc. process has 37,000 pounds of anhydrous ammonia in its refrigeration system. Stemilt Growers, Inc. uses other hazardous substances on-site, however they do not meet or exceed the threshold limits established in 40 CFR 68.130. However, Stemilt Growers, Inc. believes in the concept set forth in the "General Duty Clause" of the Clean Air Act. To this, Stemilt Growers, Inc. has established policies, procedures and training to reduce the risk of an accidental hazardous substance release for the safety of its employees and surrounding areas. C. The off-site consequence analysis considers two ammonia release scenarios, identified as "worst case" and "alternative" scenarios. The worst case scenario is defined by the Environmental Protection Agency (EPA), which states that "the owner or operator shall assume that the ma ximum quantity in the largest vessel is released ". The alternative scenario is defined as "more likely to occur than the worst case scenario". Worst-Case Scenario. - Failure of the largest vessel would release 13,630 pounds of anhydrous ammonia. The release would occur inside the compressor room, which is in direct contact with the outside. The distance to the toxic endpoint of 0.14 mg/L is 2.2 miles. The "risk radius" extends past the boundaries of the plant, into public and environmental receptor. D. Stemilt Growers, Inc. accidental release prevent program is based on the following key elements: 7 High level of training of personnel 7 Preventative maintenance program 7 Use of safety equipment 7 Use of accurate and effective written operating procedures The ammonia refrigeration system was installed to codes and good practices at the time of installation. Piping is elevated to prevent accidental damage to the system from moving vehicles. There are leak detectors (sniffers ) located in the CA rooms only. Other safeties Stemilt Growers, Inc. have are: 7 Cut-outs 7 Computerized controls 7 Pressure Relief Vents, vented to atmosphere Specific Suggested Operating Procedures have been prepared by Stemilt Growers, Inc. to be used by employees performing operational functions. The SOPs are kept in the engine room and the refrigeration supervisor's office. These procedures include: 7 Pre-start up procedures 7 Routine operations 7 Maintenance 7 Response minor releases 7 Emergency action plan E. Stemilt Growers, Inc. has not had any accidents involving ammonia in the last five years. F. In addition to the SOP's, Stemilt Growers, Inc. has established Emergency Response Guidelines for releases involving ammonia. These procedures are part of the ongoing training. G. Stemilt Growers, Inc. plans to install ammonia monitors throughout the areas where the system is located. The engine room ventilation fan will be connected to an ammonia monitor so that the fan wi ll activate upon reaching a threshold less than 40,000 parts per million, which is < of ammonia's lower explosive limit (LEL) of 16%, or 160,000 parts per million. The actual planned emergency ventilation activation will be based on life safety, therefore will be at a threshold of less than 1,000 part per million. |