J. R. Simplot Company - Pasco Plant - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | Executive Summary |

This is to inform all interested persons, including employees that the J.R. Simplot Company Pasco Washington facility is complying with OSHA's Process Safety Management Standard (called Process Safety Management or PSM), Title 29 Code of Federal Regulations (CFR) 1910.119, and EPA's Risk Management Program regulations (called RM Program), Title 40 CFR Part 68, to deal with the risks involved with the storage, handling, and processing of hazardous chemicals.  In this way we promote overall plant, worker, and public safety. 
 
These programs enable our facility to prevent the occurrence, and minimize the consequences, of significant releases of toxic substances as well as fires, explosions, and other types of catastrophic accidents.  Overall, these programs prevent accidental fatalities, injuries and illnesses and avoid physical property damage. 
 
Our safety programs are applied to any activity involving hazardous chemicals including any use, storage, manufacturing, handling, or the on-site 
movement of such chemicals, or combination of these activities.  Any group of vessels that are interconnected and separate vessels, which are located, such that a hazardous chemical could be involved in a potential release shall be considered a single process. 
 
Our safety programs prevent accidents because they focus on the rules, procedures, and practices which govern individual processes, activities, or pieces of equipment.  These rules are detailed and improved as necessary.  They are also communicated to and accepted by all employees at the facility. 
 
J.R. Simplot Company operates a vegetable processing facility in Pasco, Washington.  The only chemical that was found to be present above its respective RM program quantity threshold at this facility is anhydrous ammonia.  There is a single Program Level 3 ammonia refrigeration process.  The RM program for the Pasco Facility, which is separately documented in detail, consists of the specific elements listed below. 
 
Management Plan: 

he facility has a system in place to manage the implementation of the RM program elements. The Plant Manager is the designated facility RM Program Manager and therefore has the overall responsibility for the Pasco facility RM Program.  As Plant Manager, this individual has the authority to assign company resources to develop, implement, update, and integrate all applicable RM program elements at the Pasco facility.  The Plant Manager/RM Program Manager has identified a team of Pasco facility personnel that have been granted the responsibility for implementing and maintaining the RM Program.  Members of the RMP/PSM Team include the Plant Engineer, the Safety Coordinator, and the Boiler and Refrigeration Lead.  The RMP/PSM Team is responsible for all five elements of the RM program, including management, prevention, hazard assessment, emergency response, and RM plan updates.  
 
The RMP/PSM Team members are responsible for implementing and maintaining of the Pasco RM Program.  The RMP/PSM  
Team has responsibilities that are shared among its members and others that are assigned to specific team members.  Typically, the responsibilities that are shared among the RMP/PSM Team are those responsibilities that can be performed prior to an emergency such as emergency planning, RM Program development, and RM Program maintenance activities.  Responsibilities that must be performed during an emergency are assigned to specific individuals to lower the potential for confusion over responsibilities during emergency response.  Each member of the RMP/PSM Team must delegate their specific responsibilities to an alternate during periods of prolonged absence and/or vacation. 
 
The RMP/PSM Team reports to the RM Program Manager and receives direction and support from the Vice President of Environment and Regulatory Affairs and the Division Safety Manager.  The Plant Manager/RM Program Manager reports to division management.  The chain of management above the plant manager is as follows: 1)  
the Senior Director of Operations; 2) the Food Group President; and lastly 3) the Chief Executive Officer. 
 
Chemical Release Prevention Program: 
The facility has a chemical release prevention program for the ammonia system.  This prevention program is required by both RM Program and Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) regulations, which are quite similar with respect to release prevention.  The prevention program for the ammonia process was developed to comply with PSM regulations, and was most recently updated in the second quarter of 1999.  Key provisions of the facility release prevention program are as follows: 
 
7 Employees who operate these systems must receive training initially and periodically on safe startup/shutdown, operations, and emergency shutdown of the processes.   
7 Release incidents are investigated, and the results are used to improve the safety of the process.  
7 The ammonia refrigeration system is maintained through  
the mechanical integrity program, which minimizes the risk of accident and maximizes process safety. 
7 Results of incident investigations are also shared with employees who could be affected by the process.   
7 Employees participate in a process hazard analysis (PHA) which identifies potential hazards and ways to improve the safety of the process every five years, or whenever significant changes are made to the process. 
7 The facility has a management of change (MOC) program in place that mandates that changes to the ammonia system are reviewed prior to implementing the change to ensure that the change would not compromise safety. 
7 A pre-startup review is also completed after a major change and prior to a new process coming on line.   
7 A hot work (spark producing) permit program is in place.  
7 Contractors who are hired to work on or near the regulated processes must have adequate training on the hazards prior to starting work.  
7 The Pasco facility has an ammonia alarm system that n 
otifies refrigeration system operators and night-shift security staff of a potential release, which allows for rapid response minimizing the duration of accidental releases. 
 
Five Year Accident History: 
Offsite consequence analyses need to consider the release history of each process.  In the past four years (the facility has only been operational since 1995), the ammonia refrigeration system has not had releases that have resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage (i.e. no reportable accidents as defined in 40 CFR Part 68.42).   
 
Worst Case and Alternate Case Release Scenarios: 
Potential ammonia release events were modeled to evaluate potential offsite impacts to areas surrounding the Pasco facility.  Modeling procedures followed EPA guidance to identify worst case release scenarios (WCS) and alternate case release scenarios (ACS) as defined by the R 
M Program regulations.  EPA personnel freely admit that the assumptions used for WCS are not realistic and in some cases are not physically possible.  However, EPA guidance was followed and toxic endpoints were identified for the WCS and the ACS.  ACSs are considered by EPA to be more realistic and useful for emergency response planning than the WCS. 
 
Following EPA guidance the largest vessel approach was used to estimate the WCS.  The WCS for the facility was identified by assuming that the contents of the largest vessel are released in a 10-minute period. The vessel with the highest maximum intended ammonia inventory is the low pressure receiver which could contain a maximum of 23,000 pounds of ammonia liquifed under pressure.  However, this vessel is located within a diked area, which will mitigate the release rate.  The next largest vessel is the high pressure receiver which could contain a maximum of 22,000 pounds of ammonia liquified under pressure.  This tank is located outdoors 
with no passive mitigation features (i.e. dikes or berms).  Therefore, a release of the maximum contents of the high pressure receiver is the WCS.   Under worst case weather conditions, the modeled WCS release would result in an endpoint radius of 2.6 miles.  The estimated affected residential population within the 2.6 mile WCS radius is 780 persons.  This estimate does not include non-residential persons that could be located within the endpoint radius (i.e. workers, etc.) 
 
Potential ACSs were evaluated following EPA and IIAR guidelines.  The ACS that resulted in the longest distance to the endpoint was selected for presentation in this document and for reporting to EPA.  The selected ACS consists of a 0.15 square inch tear in an ammonia transfer hose.  This release would occur outdoors adjacent to the facility's high pressure receiver; therefore, no passive mitigation has been assumed.  The estimated release of liquid ammonia is 400 pounds of ammonia per minute for a maximum of 5 mi 
nutes (2,000 pounds total).  Under common weather conditions, the calculated release rate to the environment from this accident scenario results in an endpoint radius of 0.4 miles.  There are no residences located within this endpoint radius.  This estimate does not include non-residential persons that may be located within the endpoint radius (i.e. workers, etc.).  Although this accident scenario was selected as the ACS, the likelihood of its occurrence is minimal because of the process safety programs that have been instituted at the facility. 
 
Emergency Response Program: 
The Pasco facility's emergency response program is based on the OSHA requirements for Emergency Action Plans (29 CFR 1910.38 and 1910.119) and HAZWOPER (29 CFR 1910.120).  We have trained employees for emergency response and maintain a written emergency response plan.  This plan is coordinated with the Local Emergency Planning Committee (LEPC) and the local fire department.  We conduct annual drills for implementati 
on of the emergency response plan at the facility. 
 
RM Program Reporting: 
The timely submittal of the RMP*Submit program meets the RM program reporting requirements.  The J.R. Simplot Pasco facility will update this submittal every five years, or sooner if necessary, based on RM program regulation requirements or process modifications.
Click to return to beginning