Orange-co of Florida, Inc. - Executive Summary |
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April 01, 1999 From: Tim Barron, Utilities Manager PO box 2158, 2020 us hwy. 17 so. Bartow Fl. 33830-2158 Ph. (941)533-0551 ext. 430 Subject: OSHA 29 CFR part 1910.119 EPA 40 CFR Part 68 (Executive Summary) To whom it may concern, This is to inform all interested persons that Orange-co of Florida, Inc. has complied 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 and handling of Anhydrous Ammonia. These programs have aided our facility in preventing the occurrence and minimize the consequences of significant releases of Anhydrous Ammonia as well as fires, explosions, and other types of major hazards. Orange-co.'s safety programs prevent accidents because they focus on the rules, procedures, and practices that govern individual processes, a ctivities, and pieces of equipment. These rules are detailed and improved as necessary. They are also communicated to and accepted by all employees at this facility. Listed on the following page are two examples that were considered to be "worst case scenarios " in Orange-co of Florida, Inc. Process Hazard Analysis. Listed below them are the reasons that they are unlikely to happen. This type of modeling would not have been possible without an experienced working knowledge and a clear understanding of all the components at this facility. SCENARIO #1 Failure of the high-pressure receiver containing 28,500 lbs. of ammonia with the receiver quantity limited to 80% of the vessel capacity by facility procedures resulting in a ten-minute release. Under worst-case weather conditions, ammonia could travel 1.7 miles before dispersing enough to no longer pose a hazard to the public. This scenario is unlikely for the following reasons: 7 Worst-case weather conditions are uncommo n; 7 The vessel is enclosed in a building that would partially withstand and help to contain such a release; 7 Pressure safety valves limit operating pressure in this vessel; 7 The accident prevention program in place at the facility including the mechanical integrity program for regular maintenance, inspection and testing, and replacement of equipment, if necessary; 7 Installed ammonia sensors in the system to warn of leaks; 7 Alarms warn operating personnel of process upsets; 7 The emergency response plan and equipment in place. SCENARIO #2 Failure of a transfer hose during unloading resulting in a release of 2000 lbs. of ammonia over a time period of 10 min. Under common weather conditions, ammonia could travel .46 miles before dispersing enough to no longer pose a hazard to the public. Transfer hose failure was chosen as the alternative release scenario because it is a temporary connection and constructed of materials other than steel. This scenario is unlikely for the following reasons: 7 Emergency equipment such as an excess flow valve on the tank truck and valves to isolate the transfer hose; 7 The facility accident prevention program in place at the facility including operating procedures to have personnel present at all times during unloading, 7 The mechanical integrity program for regular maintenance, inspection and testing, and replacement of equipment, if necessary; 7 The emergency response plan and equipment in place at the facility. There were three accidental releases of ammonia in the past five years; the largest release was over 100 pounds which occurred on 7/4/97. There were no injuries to employees or local citizens during any of these releases. Orange-co took a pro-active initiative in developing, implementing, and maintaining its Emergency Response Plan to ensure a fast and efficient resolve in the event of an ammonia release. By managing and operating this facility with the highest operating standards and a philosophy th at puts safety paramount, the risk of an accidental release of Ammonia harming plant employees, near-by citizens, or the environment are greatly minimized. Orange-co.'s Emergency Response personnel have been fully trained as required by OSHA 29 CFR 1910.119, 1910.120, and 1910.38 and will, without hesitation, cooperate with fellow employees and other support personnel as directed by the Emergency Response Coordinator to assure a successful and swift resolution of any emergency. If you feel that any improvements can be made to these PSM/RM Programs, Please contact me at the address listed above. Orange-co encourages all suggestions because this facility is committed to the success and quality of our PSM/RM programs. We strive for a comprehensive, integrated prevention system which obtains clear understanding, safe behavior, and involvement in the program from every level of this facility and the public. Regards, _____ ______________________ Tim A. Barron Utilities Manager Orange-co of Florida, Inc. |