Tropicana Products, Inc.- Ft. Pierce Plant - Executive Summary |
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Could not verify complete submit with Executive Summary in this section. Program would not complete the import. Therefore it is the Word.doc file on the disk. Titled RMP Executive Summary.docTropicana Products, Inc., Ft. Pierce (Tropicana) maintains a strong commitment to protecting both the worker and the surrounding community from any type of hazardous incident that could potentially occur at its facility. For this purpose Tropicana has developed facility procedures that apply to both daily operations and emergency response situations, in the form of a Risk Management Program, developed and implemented specifically for the Ft. Pierce facility. The facility risk management program has been developed in accordance with federal (EPAs Risk Management Program, 40 CFR 68) and state (Florida Department of Community Affairs Accidental Release Program) requirements. Tropicana Products, Inc. is in Ft. Pierce, St. Lucie County, Florida, situated on, approximately, 315 acres of property. The plant was originally built in 1973. The facility is a citrus processing plant producing citrus juices and concentrate, d'limonene and animal feed. Fruit is transported to the facility by truck and is destemmed, washed, inspected, and graded, prior to being accepted or rejected by Tropicana and Florida Department of Agriculture inspectors. Accepted fruit is conveyed to the Processing Building, where final washing, peel oil recovery, inspection, and juice processing occurs. Juice is stored in either 280,000 gallon or 1,000,000 gallon aseptic tanks, or staged in one of three surge tanks for shipment off-site, packaged into Scholle boxes, or conveyed to evaporators for processing into concentrate. Concentrate is stored in stainless steel tanks (total capacity of 5,600,000 gallons) in the Concentrate Tank Farm. Scholle boxes are stored in the Work in Process (WIP) Building, a 120,000 square foot warehouse, with approximately 100,000 square feet of refrigerated (320F to 340F) an d approximately 20,000 square feet of freezer space (-40 to -70F). Included in the refrigerated space is approximately 20,000 square feet of area used for packaging. Juice, pulp and concentrate are then shipped off-site for distribution. Leaves and stems from Fruit Receiving and peels, pulp, rag and seed from processing are conveyed to the Feed Mill for the production into animal feed. Lime and molasses are added to the peel which is conveyed to the hammer mills, then sent to a mixing tank and pumped to presses which remove approximately 32% of the moisture (press liquor). Two gas fired, hot air rotary flow-thru dryers, operating at approximately 2500F, dry the processed peel, reducing the moisture content to approximately 11%. Exhaust heat from these dryers is used in the waste heat evaporators. The press liquor is concentrated in the waste heat evaporators, producing molasses. The waste heat evaporators also use a "flash" process to produce d-limonene, a combustible oil wi th a flash point of approximately 1150F, and condensate water. The condensate water is used (recycled) as wash water for incoming fruit. The dried finished feed is either formed into pellets or kept in bulk, with a majority being shipped off-site immediately. Some of the produced feed is stored on-site in warehouses, periodically rotated by conveyor to minimize the potential for spontaneous combustion. Tropicanas chilled juices require constant refrigeration to maintain their high quality and freshness. Refrigeration at the facility is provided by an anhydrous ammonia system. Ammonia, a regulated substance, is used instead of other refrigerants because ammonia has several advantages over the available alternatives. Ammonia is a very energy efficient refrigerant, does not cause damage to the ozone, and is one of the most widely used industrial chemicals. An Off-site Consequence Analysis (OCA) was completed for the facility evaluating potential impacts to surrounding areas from both a worst-case ammonia release scenario and an alternative release scenario. The worst-case release scenario looked at a possible failure of a storage vessel in the refrigeration system, resulting in a discharge of ammonia gas equal to the volume stored in the vessel. Tropicana believes, however, that this event is highly unlikely, based upon the safety procedures and management programs that are in place. Assuming the contents of the vessel is released over a period of 10 minutes, a mathematical model, DEGADIS (Dense Gas Dispersion Model) was used to determine the distance from the facility that would be impacted above an EPA specified concentration of ammonia (200 ppm). DEGADIS was selected based on its ability to model atmospheric dispersion of ground level dense gas releases of zero (initial) momentum into the atmosphere over flat, level terrain. Considering that ammonia is stored in the receiver under pressure and at ambient temperature, and that EPAs OCA Guidance stat es that a gas stored as a liquid under pressure should be treated as a gas, the worst-case release was modeled as a gaseous ground level release. Public receptors, including, a mental health hospital, residences, and commercial/industrial complexes were identified within this area. No environmental receptors were determined to be in this area of impact. An alternative release scenario was also evaluated to identify an area of impact that would result from an unforeseen set of circumstances that could cause a deviation from normal operating limits (conditions). This scenario entailed malfunction of the refrigeration system causing pressure to buildup in the main ammonia receiver. As a result of these conditions, a > inch pressure relief valve opens, releasing ammonia in a gaseous state, at an elevation of 25 feet above ground (vent opening). The ALOHA (Aerial Location of Hazardous Atmospheres) model, approved by EPA for purposes of modeling dense gas releases was used to determine the potential area of impact. Residences and commercial/industrial complexes (no environmental receptors) were identified in the impact area defined by the alternative release scenario. Although the probability of a significant release of ammonia from the facility is very low, results of the described models provide an excellent planning tool in identifying realistic risk factors. Consequently, Tropicana stresses the importance of both accident prevention and emergency response programs, relative to any risk posed by the use of ammonia at the facility. Tropicana complies with OSHAs Process Safety Management (PSM) standards (29 CFR 1910.119), incorporating technology, procedures, and management practices into a comprehensive program that effectively minimizes the potential for hazardous chemical releases. In addition to mitigation systems (automatic shut-off valves, high pressure relief valves, level alarms, barricades, monitoring/detection systems) engineered into the refrige ration system, Tropicana promotes safety in the operation of the ammonia system, by the following PSM program elements: 1. Involving employees in various aspects of program development and implementation; 2. Maintenance of updated process information, accessible to all employees; 3. Completion of a process hazard analysis (PHA) that identifies any hazards associated with deviation from normal operating conditions; 4. Development and implementation of standard operating procedures (SOPs); 5. Use of safe work practices in all aspects of process operation; 6. Personnel training; 7. Contractor safety program; 8. Pre-startup safety reviews prior to introduction of ammonia into the system; 9. Comprehensive inspection and maintenance program; 10. In-depth reviews of any significant changes in the ammonia system; 11. Investigation of any accidents or near misses, identifying any modifications that could prevent similar incidents in the future; 12. Internal audits, identifying any areas of program noncompliance and corrective actions required. There have been no accidents in the last five years, or in the history of the Tropicana, Ft. Pierce facility, from the ammonia refrigeration system that have resulted in deaths, injuries, or significant property damage on-site; or, off-site deaths, injuries, evacuation, sheltering in place, property damage, or environmental damage. The Tropicana on-site emergency response program entails the organization of a trained emergency response team, capable of implementing established response procedures. These procedures include response as a stand-alone response unit (on-site personnel only), or in conjunction with off-site authorities. The facility utilizes the Incident Command System for all response activities, as outlined in the current facility Emergency Response Plan. On-site capabilities include responses to fires; non-consequential ammonia releases (such as normal operating losses and small, non-impacting sudden occurr ences, etc); hazardous material spills; product (juice) releases; confined space and high angle rescue, first responder medical assistance; bomb threats; and, workplace violence events. An emergency response plan, updated at least annually, outlines the emergency response management system on-site, providing basic facility information (e.g., operations layout and description), essential response organization and procedures (e.g., on-site personnel and off-site agency information, organizational structure, evacuation and response procedures, etc.) and site specific supporting information (e.g., drawings, chemical information, detail procedures descriptions, etc.). Tropicana will also be developing an Integrated Contingency Plan (ICP) in 1999 to replace the existing emergency response plan, formatted to follow EPAs Integrated Contingency Plan Guidance. The ICP provides a single plan that insures emergency preparedness through logistical planning and coordination between facility personnel and local emergency response personnel. All aspects of Tropicanas emergency response planning are developed in coordination with appropriate state and local agencies responsible for emergency response management. Tropicana has made arrangements for coordination of emergency response activities with these agencies, as well as with additional service organizations such as hospitals, health clinics, and pre-approved contractors. Tropicanas on-site Emergency Response Team, comprised of approximately 40 members, represents expertise in environmental operations, security, safety, and refrigeration. All working shifts have representatives on the emergency response team, to facilitate on-site response to any incident 24 hours per day, 7 days per week. Most members also carry pagers for immediate notification. All emergency response team members are trained in emergency response, capable of responding aggressively to a release of a hazardous material, while donning full prot ective gear (i.e., Self Contained Breathing Apparatus). All team members have completed and initial training course either 24 or 40 hours in length, in addition to completing an 8 hour refresher course, annually. Additionally, all team members are required to maintain a complete working knowledge of the most current facility emergency response plan. Tropicana was awarded MERIT status in 1994, and STAR status in 1998, in accordance with OSHAs Voluntary Protection Program. Star status is only given to those facilities that consistently demonstrate excellence in safety and exceed regulatory requirements for maintaining a safe operation. As a result of this status, Tropicana continually strives to maintain the highest quality safety program possible. This includes evaluations of existing programs relative to any changes in facility operations, as well as recommendations that arise from incidents, such as injuries or near misses. Tropicana has, and will continue to be, an industry leader in assuring the proper and safe operation of its ammonia refrigeration system. This leadership is exemplified by Tropicana employees at all organizational levels and is the basis for the companys commitment to maintaining a comprehensive risk management program, minimizing the potential for accidental releases. |