George F Joseph Orchard Siding Inc. Zillah - Executive Summary
A. Accidental Release Prevention and Emergency Response |
George F. Joseph O.S., Inc. accidental release prevention policy involves a unified approach that integrates technologies, procedures, and management practices. It is the policy of George F. Joseph O.S., Inc. to adhere to all applicable federal and state safety and environmental regulations.
George F. Joseph, Inc. emergency response policy involves the preparation of response plans and training of employees in evacuation and the handling of ammonia releases.
George F. Joseph, Inc. emergency response policy involves the preparation of response plans and training of employees. George F. Joseph, Inc. has trained its refrigeration personnel in hazardous materials response (24 hours). This training includes emphasis on anhydrous ammonia, in addition to other requirements set forth in 29 CFR 1910.120(q) and WAC 296-62, Part P (HAZWOPER).
At George F. Joseph, Inc. anhydrous ammonia is used on-site. Ammonia is considered hazardou
s 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 in order to:
- Prevent unnecessary human exposure
- Reduce the threat to our personnel
- Reduce the threat to the community
B. Facility and Regulated Substance Handled
George F. Joseph, Inc. is a fruit processing and cold storage facility, located at 1151 Cutler Way Zillah, WA 98953. The facility is located in Yakima County.
The regulated substance used at George F. Joseph, Inc. is anhydrous ammonia (CAS# 7664-41-7). The use of anhydrous ammonia is as a refrigerant.
There is 14,728 pounds of anhydrous ammonia in the refrigeration system.
George F. Joseph, Inc. uses other hazardous substances on-site, however they do not meet or exceed the threshold limits established in 40 CFR 68.130. However, George F. Joseph, Inc. believes in the concept set forth in the "General Duty Clause" of the Clean Air Act.
To this effect, George F. Joseph, 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. Worst-Case and Alternative Scenarios
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 maximum 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 14,728 pounds of anhydrous ammonia, however in order to obtain a true worst-case, the entire system inventory (rounded up) of 15,000 pounds was modeled. The release would occur inside the compressor room, which is not in direct contact with the outside.
However for modeling purposes, no mitigation was used. Modeling was done by use of ALOHA.
The distance to the toxic endpoint of 0.14 mg/L is 1.6 miles. The "risk radius" extends past the boundaries of the plant, into public receptors. Affecting a residential population of 354 and Zillah Middle School.
There are no environmental receptors within either risk radius.
Alternative Release Scenario - For the alternative scenario, it was assumed that the system would lose its entire inventory over a 30 minute period, without any mitigation. Modeling was done by use of ALOHA.
The distance to the toxic end-point of 0.14 mg/L is 0.3 mile. The "risk radius" extends past the boundaries of the plant, into public receptors. Affecting a residential population of 10.
Both the "worst-case" and "alternative" scenarios are highly unlikely due to the safeties on the system such as high temperature/pressure cutouts, computer controls and pressure relief valves to prevent an overpressure situat
A more realistic scenario would be that of a pressure relief valve lifting, discharging ammonia vapor from vents on top of the building, approximately 40 feet above the ground. In scenarios modeled for this type of an event, the risk radius was reduced down to approximately 200 yards.
The area of greatest concern is Zillah Middle School. In the event of a release, the school could be affected. The school superintendent will be contacted before school starts in the fall of 1999 and will be provided with the recommended actions for an unplanned ammonia release and notification procedures.
D. General Accidental Release Prevention Program
George F. Joseph, Inc. accidental release prevent program is based on the following key elements:
- High level of training of personnel
- Preventative maintenance program
- Written safety procedures and safety equipment
- Use of accurate and effective written operating procedures
George F. Joseph, Inc. also complies with:
- OSHA's and Washi
ngton State's process safety management rule.
- Washington State's safety regulations (WAC's 296-24 and 296-62), which are equal to, or more restrictive than OSHA regulations.
- IIAR (International Institute of Ammonia Refrigeration) standards for good work practices.
- The Uniform Fire Code for handling of hazardous materials.
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. Engine room doors are tight fitting and open outwards. Other safety devices George F. Joseph, Inc. utilizes include:
- Computerized controls, which can be operated remotely
- Suction trap hi-level float
- High discharge pressure shut down
- Low suction pressure shut down
- High discharge temperature shut down
- Oil pressure failure shut down
- High amperes shut down
- Automatic timer to prevent short cycling
- Oil filters plugged shut down
- 250 psi relief valves on high pre
ssure side, to prevent overpressure situations
- 150 psi relief valves on low pressure side, to prevent overpressure situations
- Emergency ventilation
Operating Procedures have been prepared by George F. Joseph, Inc. to be used by employees performing operational functions. The operating procedures are kept in the refrigeration manager's office. These procedures include:
- Pre-start up procedures
- Routine operations
- Response to minor releases
- Emergency action plan
E. Five-Year Accident History
George F. Joseph, Inc. has not had any accidents involving ammonia in the last five years.
F. Emergency Response Program
In addition to the operating procedures, George F. Joseph, Inc. has established Emergency Response Guidelines for releases involving ammonia. These procedures are part of the ongoing training.
Safety orientation includes making all employees aware of the evacuation plan and/or the shelter in place plan. The supervisors are provided with the contac
t numbers for our own emergency responders Milo Elander and Dan Hargroves (Zillah Fire Chief) to coordinate either the evacuation or the shelter-in-place program.
Refrigeration personnel have received 24-hour Emergency responder training and the 8 hr. Emergency response team refresher in accordance with 1910.120. The Ammonia Safety Training Institute (ASTI) did this training. The refrigeration specialists Milo Elander and Dan Hargroves (Zillah Fire Chief) has also been through the Ammonia Emergency response On-scene Incident Commander training. Industrial Consultants did this training
We have two windsocks located at either end of the plant on top of the building and are visible from indoor refrigeration office and also visible outdoors upwind of any potential release.
G. Planned Safety Improvements
Currently, George F. Joseph, Inc. plans to install separate audible alarms for both fire and an ammonia release. This will provide for distinctive warning for which ever incident w
ere to occur, providing better warning for our employees.
George F. Joseph, Inc. will continue to ensure that its employees assigned to work on the process receive current training.