Ruiz Foods, Dinuba CA Plant - Executive Summary |
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..... Risk Management Plan Executive Summary Accidental Release Prevention and Emergency Response Policies Ruiz Food Products is strongly committed to employee, public and environmental safety. This commitment is reflected in a comprehensive accidental release prevention program that addresses the design, installation, operation, maintenance, and employee training associated with the ammonia refrigeration at our facility. It is our policy to controls are in place to prevent possible releases of ammonia. If such a release does occur, our trained emergency response personnel are at hand to control and mitigate the effects of the release. We are completely coordinated with the Region 5 LEPC and the Dinuba Fire Department, who provide additional emergency response expertise. The Stationary Source and the Regulated Substances Handled Ruiz Food Products' primary activity in Dinuba is frozen food manufacturing. At our facility, located at 501 South Alta Avenue in Dinuba, CA, we prepar e, store and ship frozen food products. Ammonia is our only RMP-regulated substance, and is used to provide refrigeration for the preparation and cold storage of our products. The maximum inventory of ammonia at our facility is approximately 50,000 lb. The Worst Case Release Scenario and the Alternative Release Scenarios The worst-case release scenario selected was a release from the receiver (the vessel containing the largest amount of ammonia), over a 10-minute release period. This resulted in a release of 40,000 pounds of ammonia. Release distances were calculated using Class F atmospheric stability and 1.5 m/s wind speed, and a toxic endpoint of 0.14 mg/L. Results for the WCS were modeled using EPA's RMP*Comp based on a release of toxic gas that has been liquefied under pressure. Although the receiver is located inside a building, it is adjacent to ventilation louvers in an outside building wall, so we did not reduce the worse case scenario by considering the building to be pass ive mitigation. This resulted in a toxic endpoint distance of 2.3 miles. The alternative scenario selected was of an ammonia release occurring due to failure of a 1" fill hose while charging the system from an ammonia supply truck. This scenario resulted in a release rate of 2,080 lbs./minute. Using EPA's RMP Guidance for Ammonia Refrigeration reference tables and equations, this resulted in a toxic endpoint distance of 0.3 miles. The guidance used to develop the release distance did not assume a specific release duration, and so is applicable to releases of any duration. In the event of an actual release, it is expected that an operator would intervene to stop the release within 10 minutes. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility is taking all the necessary steps to comply with the EPA's accidental release prevention requirements set out under 40 CFR Part 68, the requirements for the California Accidental Release Pr evention program (CalARP), the OSHA PSM requirements of 29 CFR 1910.119, and the EPCRA Section 302 notification requirements. The following sections briefly describe the elements of the release prevention program that are in place at our Dinuba plant. Process Safety Information Ruiz Food Products maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment specifications associated with the ammonia refrigeration process. Process Hazards Analysis Our facility has conducted comprehensive studies to ensure that hazards associated with our processes are identified and controlled effectively. We use the What If/Checklist methodology to carry out these analyses. The studies were undertaken by a team of qualified personnel with expertise in engineering and process operations and will be revalidated at least every five years. Any findings related to the hazard analysis are addressed in a timely manner. Operating Procedures To further ensure that activities are safely conducted in our ammonia system, Ruiz Food Products is developing written operating procedures to supplement our current operator training. These procedures will address various modes of operation such as initial startup, normal operation, normal shutdown and startup, and emergency shutdown and startup. This information will be regularly reviewed and readily accessible to operators involved in the processes. Training Ruiz Foods has an on-the-job training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Written procedures are currently being developed to enhance the on-the-job training. Refresher training is provided at least every three years. All training will be documented and validated. Mechanical Integrity Ruiz Food Products carries out regular maintenance checks on all process equipment to ensure proper operations. Equipment examined by thes e checks include pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls, compressors and pumps. This maintenance is completed only by qualified personnel with training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. A written program to supplement the current maintenance procedures is being developed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are currently being developed at Ruiz Food Products to manage changes in process chemicals, technology, equipment and procedures. This will ensure that process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-start up safety reviews related to new processes a nd to modifications in established processes are conducted as a regular practice at Ruiz Foods. These review procedures are currently being documented to formally ensure that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Ruiz Foods conducts audits on a regular basis to verify that the provisions set out under the RMP rule are being implemented. These audits will be carried out at least every 3 years and any corrective actions required as a result of the audits will be undertaken in a safe and prompt manner. Incident Investigation Ruiz Food Products promptly investigates any incident that has resulted in, or could have resulted in a release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from occurring under similar situations. All reports are retained for a minimum of 5 years. Employee Participation Ruiz Foods believes that process safety management and accident prevention is a team effort and has developed a written plan to implement this philosophy. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, particularly information resulting from process hazard analyses. Hot Work Permitting Ruiz Food Produsts has developed a permitting procedure for all hot work conducted in the vicinity of the ammonia equipment. It documents that appropriate fire prevention measures have been implemented, and defines the work dates and scope of work to be performed. The permit is kept on site until completion of the work. Contractor Safety On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prio r to selecting a contractor, a thorough evaluation of the contractor's safety performance is carried out. Ruiz Food Products has a strict policy of informing the contractors of any known potential hazards related the contractor's work and the processes within our facility. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. Five-year Accident History Ruiz Food Products has had a good record of preventing accidental releases. No incidents have occurred over the last 5 years. Emergency Response Plan Ruiz Foods has developed a written emergency response plan to deal with accidental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency resp onse equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. The Ruiz Foods Dinuba facility coordinates its emergency response plan with the Region 5 LEPC and the Dinuba Fire Department. Planned Changes to Improve Safety The following changes are planned or already underway to improve the level of safety within our plant. These include: - Ongoing evaluation of recommendations made during the Process Hazards Analysis. - Further development of our operating and maintenance procedures. - Increasing the number of employees with emergency response training |