Citrosuco North America, Inc. - Executive Summary |
|
EXECUTIVE SUMMARY INTRODUCTION Citrosuco North America, Inc. (Citrosuco) is a producer of citrus products located at 5937 Highway 60 East in Lake Wales, Florida. An integral part of the production and storage of these products is an anhydrous ammonia refrigeration system. The anhydrous ammonia storage capacity of this refrigeration system, after administrative controls, is approximately 46,000 pounds. This inventory exceeds the 10,000-pound threshold for anhydrous ammonia set by EPA under the Risk Management Program (RMP) Rule codified at 40 CFR 68. Pursuant to the requirements of the rule, Citrosuco has prepared this Risk Management Program (RMP) Plan. We are proud of our environmental, health, and safety efforts and programs and our record in these areas. The following sections outline our RMP plan. OVERALL RESPONSIBILITY Our Facility Manager has the overall responsibility for ensuring that our facility operates in a safe and reliable manner. This responsibility includes overseeing the implementation of the elements of our risk management program. To ensure that our risk management program is appropriately developed and implemented, our Facility Manager has assigned the role of PSM/RMP Coordinator to the facility Safety and Compliance Director, a staff member with the necessary background, training, and experience. The PSM/RMP Coordinator, acting with the authority delegated directly from the Facility Manager, has the responsibility for the development, implementation, and integration of the EPA RMP elements and the elements of OSHA's PSM program (where applicable) as required under Section 68.15 of the RMP rule. The PSM/RMP Coordinator serves as the chairman of the facility's PSM/RMP Steering Committee. This committee comprises members with responsibilities for developing and managing specific elements of our risk management and process safety programs. The members of this committee are assigned by the Facility Manager based on recommendations from the PSM/RMP Coordinator. Currently, the members of the PSM/RMP Steering Committee include the following: * PSM/RMP Coordinator/Safety and Compliance Director * Facility Manager * Production Manager * Maintenance Manager * Purchasing Manager * Human Resources/Public Relations Manager * Employee Representative The following sections identify the specific responsibilities for each aspect of our risk management and process safety management programs. HAZARD ASSESSMENTS The Safety and Compliance Director has the responsibility for (1) ensuring that offsite consequence analysis for each regulated process are consistently performed and documented in accordance with Sections 68.20 through 68.39 and (2) selecting the scenarios that will be reported in the facility RMPlan as required under Section 68.165. The Safety and Compliance Director also is responsible for ensuring that the accident history for each covered process is appropriately documented and maintained in accordance with Section 68.42 and 68.168 of the RMP rule. The rule requires the evaluation of a worst case scenario, even though the likelihood of the occurrence of such a scenario may be extremely small. The worst case scenario has been defined as a catastrophic release of the entire anhydrous ammonia inventory, 7813 pounds, from Tank E. Although Tank E has a true capacity of approximately 9800 pounds, the inventory in the tank is maintained at or below 7813 pounds due to administrative controls. The distance to the toxic endpoint as predicted by the USAF Toxic Chemical Dispersion Model is 0.68 miles. In addition to the worst case scenario, an alternative release scenario has been modeled employing more appropriate meteorological conditions and release assumptions. In the alternative release scenario, 100 pounds of anhydrous ammonia per minute are assumed to be released due to a piping leak. Response measures are expected to take 30 minutes to mitigate the leak. Based upon the se assumptions, the distance to the endpoint as predicted by the same model employed above is approximately 634 feet. At this distance, no impact on public receptors would be anticipated. FIVE-YEAR ACCIDENT HISTORY Although not technically "reportable" under EPA's criteria, Citrosuco reported a minor release resulting from a piping leak in May 1998 to the State Warning Point as a precautionary measure. The leak was immediately contained, there were no injuries, and no emergency vehicles were required at the scene. Citrosuco has always taken a pro-active stance in the safety of its employees and the surrounding community and environment. The State Warning Point notification following the minor release was a precautionary measure only. PREVENTION PROGRAMS The PSM/RMP Coordinator has the responsibility for ensuring that the facility has an integrated, effective, and compliant prevention program that meets EPA RMP (Sections 68.65 through 68.87 of the RMP rule) and OSHA PSM requirem ents. Although the PSM/RMP Coordinator has some specific individual responsibilities, many of the responsibilities for specific program elements are assigned to other members of the PSM/RMP Steering Committee (as listed in the following sections). PROCESS SAFETY INFORMATION The responsibility for process safety information (PSI) (Section 68.65 of the RMP rule) is divided into three areas. The Safety and Compliance Director has responsibility for process chemical information, the Production Manager has responsibility for process technology information, and the Facility Manager has responsibility for equipment information. The PSM/RMP Coordinator has the responsibility of ensuring that all of this information is readily accessible for use. PROCESS HAZARD ANALYSIS In accordance with Section 68.67 of the RMP rule, the PSM/RMP Coordinator has the responsibility for ensuring that process hazard analyses (PHAs) are scheduled, conducted, and documented by trained personnel for all regul ated processes. The PSM/RMP Coordinator identifies candidate PHA team leaders from within the facility and ensures that they receive appropriate training before leading PHAs. The PSM/RMP Coordinator also uses outside contractors to lead PHAs when appropriate. The other members of the PSM/RMP Steering Committee are responsible for (1) ensuring that the information and personnel necessary to conduct PHAs are available according to the PHA implementation schedule and (2) resolving recommendations that are assigned to their respective areas. OPERATING PROCEDURES In accordance with Section 68.69 of the RMP rule, the Production Manager has the responsibility for ensuring that complete and accurate operating procedures are in place for all regulated processes. The Production Manager works closely with the Safety and Compliance Director and the Maintenance Manager to develop and maintain the facility's safe work practices. TRAINING In accordance with Section 68.71 of the RMP rule, t he Production Manager has the responsibility for (1) ensuring that operations employees receive and understand training applicable to their specific jobs and the associated processes and (2) documenting the training. The Safety and Compliance Director has the responsibility for (1) ensuring that all facility employees receive and understand training in safe work practices applicable to their jobs and (2) documenting the training. (The Maintenance Manager addresses training for maintenance workers under the mechanical integrity program.) MECHANICAL INTEGRITY In accordance with Section 68.73 of the RMP rule, the Maintenance Manager has the responsibility for the overall mechanical integrity program, with specific emphasis on written procedures, maintenance training, the equipment and instrumentation inspection/test program and documentation, and equipment deficiency resolution. The Facility Manager and the Purchasing Manager work with the Maintenance Manager to define and maintain a ppropriate quality assurance procedures for all types of equipment acquisitions/installations/repairs. MANAGEMENT OF CHANGE In accordance with Section 68.75 of the RMP rule, the PSM/RMP Coordinator has the responsibility for the overall management of change (MOC) program; however, the Production Manager, the Maintenance Manager, the Facility Manager, and the Purchasing Manager each have responsibility for ensuring that the overall MOC program is effectively implemented in their areas. PRE-STARTUP REVIEW In accordance with Section 68.77 of the RMP rule, the PSM/RMP Coordinator has the responsibility for the overall pre-startup review program, which is closely related to the MOC program. However, the Production Manager has the primary responsibility for ensuring that this program is effectively implemented before affected operations begin. COMPLIANCE AUDITS In accordance with Section 68.79 of the RMP rule, the PSM/RMP Coordinator has the responsibility for ensuring that compliance audits regularly occur (and are documented) to verify that the prevention program is working and meets EPA/OSHA requirements. Each member of the PSM/RMP Steering Committee has responsibility for resolving any identified deficiency in his or her area. INCIDENT INVESTIGATION In accordance with Section 68.81 of the RMP rule, the Safety and Compliance Director has the responsibility for designing and managing the incident investigation program, including tracking resolution of investigation findings and recommendations. The Safety and Compliance Director also has the responsibility of ensuring that only trained personnel lead our investigations. The Production Manager and Maintenance Manager each have responsibility for ensuring that all incidents in their areas are reported and investigated, and the investigations findings are resolved, documented, and communicated to affected personnel. EMPLOYEE PARTICIPATION In accordance with Section 68.83 of the RMP rule, the PSM/RMP Coordinato r, working with the employee representative on the PSM/RMP Steering Committee, has the responsibility of involving employees in the planning and implementation of the facility's prevention program elements. HOT WORK PERMITS In accordance with Section 68.85 of the RMP rule, the Safety and Compliance Director, working closely with the Production Manager and Maintenance Manager, has the responsibility of developing and maintaining the facility's hot work permit program. CONTRACTORS In accordance with Section 68.87 of the RMP rule, the Purchasing Manager has the overall responsibility for the contractor program; however, the Maintenance Manager, the Production Manager, and the Facility Manager are responsible for ensuring that the requirements of the program are implemented in their areas of responsibility. EMERGENCY RESPONSE PROGRAM In accordance with Sections 68.90 and 68.95 of the RMP rule, the Safety and Compliance Director is responsible for (1) designing, implementing, and main taining the facility's emergency response plan, (2) ensuring that all associated training is conducted and documented as necessary, (3) coordinating the site emergency response plan with the community emergency response plan, and (4) responding to local emergency planners/responders when questions arise. RMPLAN PREPARATION AND SUBMISSION The PSM/RMP Coordinator is responsible for preparing and submitting the RMPlan for the facility (after review and approval by the Plant Manager) as required under Sections 68.150 through 68.185 of the RMP rule. RMPLAN COMMUNICATION Public Relations as they relate to Citrosuco's Risk Management Program Plan are coordinated by our Human Resources Manager. This individual has the responsibility of providing RMPlan information (other than the required EPA submission) to employees and the public as required under Section 68.210 of the RMP rule. |