Wm. Bolthouse Farms, West facility - Executive Summary |
|
1. WM. BOLTHOUSE FARMS, INC., WEST FACILITY RISK & PROCESS SAFETY MANAGEMENT PROGRAM This is to inform all interested persons, including employees, that Bolthouse West has prepared a unified Risk & Process Safety Management Program to comply with California's Accidental Release Prevention (CalARP) Program (in California CCR Title 19, Chapter 4.5, Program Level 3 Elements, and Federally Title 40 CFR Part 68) and California OSHA's "Process Safety Management (PSM) of Acutely Hazardous Materials" standard (in California CCR Title 8, Section 5189, "Process Safety Management of Acutely Hazardous Materials" and Federally Title 29 Code of Federal Regulations (CFR) 1910.119). This program has been prepared to address the risks involved with the presence of anhydrous ammonia in an amount in excess of 10,000 lbs which is contained in our refrigeration system. Our program promotes overall plant, worker, and public safety. The program enables our facility to prevent the occurrence, and minimiz e the consequences, of significant releases of anhydrous ammonia. Overall, the program is designed to prevent accidental fatalities, injuries and illnesses and avoid physical property damage. Our company has an exemplary safety record, one that we are quite proud of. Our program incorporates and brings together several existing safety programs which already set forth rules, procedures and practices which help our employees protect themselves and our neighbors. 2. DESCRIPTION OF AMMONIA SYSTEM******************************* We operate a facility that prepares and packages carrots for sale. Ice Maker system, and Pre-Processing Plant. Our facility has one ammonia system that provides refrigeration capacity to eight cold rooms and a staging area. Each cold room is equipped with evaporator coils that contain chilled liquid ammonia. There is one ammonia system at our facility. Therefore, we are treating our facility as a single process. 3. AMMONIA RELEASE SCENARIOS 3.1 Worst Case Scenario At Bolthouse West, the worst case scenario is the failure of our high-pressure receiver. This vessel contains 26,000 lbs. of ammonia. Following the instructions set forth in EPA's "Risk Management Program Guidance for Ammonia Refrigeration (40 CFR Part 68)," we considered the failure of one vessel. We did not include any liquid ammonia in pipework connected to the failed vessel or in any other vessel that could discharge directly into pipework connected to the failed vessel. This scenario would result in a 10-minute release of the entire contents of the high-pressure receiver,26,000 lbs. of ammonia. Wedid not consider passive enclosure mitigation because the vessel is located outside. Using RMP*Comp the estimated distance that the ammonia would travel before dispersing enough to no longer pose a hazard to the public is 2.9 miles (rural conditions). In our opinion, it is extremely unlikely that the worst-case scenario will ever take place. Our receiver meets industry standards for manufacture and quality control of pressure vessels; ammonia is not corrosive in this service; pressure safety relief valves limit the operating pressure in this vessel; and our operators are trained in the safe operation of our system. 3.2 Alternative Case Scenario Our alternative release scenario is as follows. A forklift strikes a high pressure liquid feed line in one of the cold rooms, and shears a hole 1/4" in diameter. Using the modeling program ALOHA the initial release rate can be estimated as 80 lbs/min. We assume the leak would continue for 10 minutes until the flow of ammonia to the leak point could be stopped. Under this scenario 800 lbs of ammonia would be released over a time period of 10 minutes. The release would be passively mitigated by the fact that the ammonia would be contained in the c old room. Using RMP*Comp we estimate that the ammonia would travel less than 0.1 miles (urban conditions) before dispersing enough to no longer pose a hazard to the public. 4. GENERAL ACCIDENT RELEASE & AMMONIA SPECIFIC PREVENTION STEPS The ammonia refrigeration system at Bolthouse West is an integral part of the overall business. It has a system charge of approximately 26,000 lbs. It is extremely important that it is maintained and operated in a safe and efficient manner. Management is committed to making sure that all employees are made aware of the potential danger of an ammonia leak. Our refrigeration personnel monitor the ammonia refrigeration system/process and keep an active diary of all procedures and transactions that pertain to ammonia. In addition, the system/process is checked frequently by our outside refrigeration contractor, California Controlled Atmosphere, who also assists us in performing an annual pre-season preventative maintenance review of our system/process equipment. Our refrigeration personnel performs scheduled maintenance on system/process equipment at the end of each season. We inform our employees of the dangers of an accidental release of ammonia through monthly safety meetings. During these meetings we also discuss the preventative measures to take, such as evacuation, in order to not be affected by a release. Our ammonia refrigeration system was designed and built by professional refrigeration engineers in accordance with ANSI/IIAR 2-1992 "Standard for Equipment, Design, and Installation of Ammonia Mechanical Refrigerating Systems." It was also built in compliance with the Uniform Building Code and Uniform Mechanical Code applicable at the time of construction. Our ammonia refrigeration system is equipped with safety relief valves. These valves limit the operating pressures of the entire system, and prevent failures due to overpressurization. 5. FIVE YEAR ACCIDENT HISTORY Bolthouse West has not had any reportable acciden ts within the last five years. 6. EMERGENCY ACTION PLAN This facility's emergency response program is based on the Cal/OSHA requirements for Emergency Action Plans (in California CCR Title 8, Section 3220, "Emergency Action Plans" and Federally Title 29 CFR 1910.38 and 1910.119) and HAZWOPER (standard (in California CCR Title 8, Section 5192, "Hazardous Waste Operations and Emergency Response" and Federally Title 29 CFR 1910.120). Strategically, we will respond Defensively to a release. Under this plan our ammonia refrigeration personnel will initially take defensive take steps to bring a release under control. The first priority will be to operate the ammonia system to bring a release under control safely, from a distance, without donning personal protective equipment. Steps might include stopping the flow of ammonia to a leak point, or using the compressor to suck ammonia away from a leak point. Further response requiring the donning of personal protective equipment would be done with teams formed in coordination with an outside agency. To better prepare for this type of action, initial training to the offensive level (Hazardous Materials Technician) as defined in the HAZWOPER regulations will take place before the end of the year. All response activities would be coordinated with the local fire department and the Kern County Fire Department Hazardous Materials Response Team. To date, two of our employees have been trained to respond defensively (First Responder, Operations Level) as defined in the HAZWOPER regulations. 7. PLANNED CHANGES TO IMPROVE SAFETY As of November 15, 1999, the time that this Executive Summary is being submitted, our Risk & Process Safety Management Plan is complete. We established and met our milestones and allotted times required for the completion of our plan. Milestone Allotted Time * Conduct Offsite Consequence Analysis -- Done * Prepare RMP*Submit showing status as of 6/21/99 -- Done * Collect Process Safety Information 60 days - Done * Conduct Process Hazard Analysis -- Done on Aug. 23, 1999 * Finish PHA documentation including Action List 30 days - Done * Prepare Process Prevention Program elements 90 days -Done * Prepare Standard Operating Procedures 90 days - Done * Compile all elements into Risk & Process Safety Management Program, review internally, and submit 120 days -Done We understood our obligations to consolidate our safety activities in a Risk Management Program under the CalARP regulation. We have prepared a Risk & Process Safety Management Program according to the milestone and timeline chart shown above. In short, the RMP plan is in place. However, some elements such as management of change have not been used. |