Warmerdam Packing Co. - Executive Summary |
Table of Contents for Preface - Executive Summary 1. THE WARMERDAM PACKING CO. RISK & PROCESS SAFETY MANAGEMENT PROGRAM 1 2. DESCRIPTION OF AMMONIA SYSTEM 1 3. AMMONIA RELEASE SCENARIOS 2 3.1 WORST CASE SCENARIO 2 3.2 ALTERNATIVE CASE SCENARIO 2 4. GENERAL ACCIDENT RELEASE & AMMONIA SPECIFIC PREVENTION STEPS 2 5. FIVE YEAR ACCIDENT HISTORY 3 6. EMERGENCY ACTION PLAN 3 7. PLANNED CHANGES TO IMPROVE SAFETY 3 APPENDIX A: OFFSITE CONSEQUENCE ANALYSIS MAPS APPENDIX B: RMP*SUBMIT PRINTOUT APPENDIX C: LETTERS OF CERTIFICATION 1. THE WARMERDAM PACKING CO., RISK & PROCESS SAFETY MANAGEMENT PROGRAM This is to inform all interested persons, including employees, that Warmerdam Packing has prepared a unified Risk & Process Safety Management Program. The program is in compliance with California's Accidental Release Prevention (CalARP) Program (in California CCR Title 19, Chapter 4.5 Program Level 3 Elements. At the Federal level, Title 40 CFR Part 68), and California OSHA's "Process Safety Ma nagement (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 is being 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 will promote overall plant, worker, and public safety. The program will enable our facility to prevent the occurrence, and minimize 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 company has many policies and procedures in place to promote overall plant, worker and public safety. The Risk Management Plan unifies our efforts, and sets forth rules , procedures and practices which will help our employees protect themselves and our neighbors. 2. DESCRIPTION OF AMMONIA SYSTEM The Warmerdam Packing facility is a commercial packinghouse for fruit - apples, cherries, peaches, nectarines and some grapes. The facility has an ammonia system that provides refrigeration capacity in support of production activities. The system has two high pressure recievers. One is valves off and empty at present. High pressure liquid from the other high pressure receiver is piped to a series of a liquid feed solenoid/expansion valves. The liquid drops in pressure and temperature as it passes through the valve groups into accumulator vessels serving cooling coils. Ceiling mounted evaporator coils are located in seven controlled atmosphere and one bin rooms, as well as two refrigerated hallways and a loading dock. Accumular vessels for these coils are located on the rooftop, or are mounted on corridor walls outside of the rooms themselves. Forced a ir evaporator coils are located in one precool and two cold storage rooms, as well as two precool zones. The coils and their accumulator vessels are behind bunker walls. There are three new and one old hydrocoolers with dual flooded coils and surge tanks. Produce from the field is cooled by water which itself has been cooled by passing over the hydrocooler coils. Low pressure vapor and liquid are returned from the accumulator vessels through a suction return line to main accumulators located in the engine rooms. The vapor is piped to one or more of six reciprocating and one screw compressors which elevate the temperature and pressure of the gas. The high pressure discharge from the compressor is sent to water cooled evaporative condensers where the high pressure gas ammonia is liquified and returned to the high pressure receivers. Liquid separated from the suction return gas in the main accumulator vessels drains into liquid transfer vessels. Operation of a float switch activat ed solenoid valve raises the pressure in the liquid transfer vessel to the point the liquid can be drained into the high pressure receiver. The ammonia system at the facility consists of vessels which are interconnected. Therefore, it was treated as a single process. 3. AMMONIA RELEASE SCENARIOS 3.1 Worst Case Scenario At Warmerdam Packing Co., the worst case scenario is the failure of our high-pressure receiver containing 17,000 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 pipe work connected to the failed vessel or in any other vessel that could discharge directly into pipe work connected to the failed vessel. This scenario would result in a 10 minute release of the entire contents of the high-pressure receiver, 17,000 lbs. of ammonia. We did not consider passive enclosure mitigation because the vessel is not located inside a room or housing. Using RMP*Comp we estimate that the ammonia would travel 2.2 miles (rural conditions) before dispersing enough to no longer pose a hazard to the public. The potentially affected area is shown on a site map in Appendix A. 3.2 Alternative Case Scenario Our alternative release scenario is as follows. A high pressure safety relief valve lifts and fails to reseat. The rated release rate for our high pressure safety relief valve is 70 lbs/min. We assume the leak would continue for 10 minutes until the header pipe was switched over to the backup safety relieve valve. Following industry practice, our relief valves are installed in pairs with a switch over valve, and the discharge is piped to a release point that is remote from the valve. Under this scenario 700 lbs of ammonia would be released over a time period of 10 minutes. Using RMP*Comp we estimate that the ammonia would travel 0.2 miles (rural conditions) before dispersing enough to no lo nger pose a hazard to the public. A map showing the area that would be affected is shown in Appendix B.. 4. GENERAL ACCIDENT RELEASE & AMMONIA SPECIFIC PREVENTION STEPS The ammonia refrigeration system at the Warmerdam Packing Co. facility are an integral part of the overall business. Together, the systems contain a total charge of approximately 17,000 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, with the aid of a computer control sysrtem, and keep an active log 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. We inform our employees of the dangers of an accidental release of ammonia in a tailgate safety meeting. New employees are made aware of the potential risk of ammonia in an employee orientation meeting. During these meetings we also discuss preventative measures, such as evacuation, in order to be prepared for a release. The facility was built by professional refrigeration engineers consistent with industry standards and in accordance with the Uniform Mechanical Code and Uniform Building Code applicable at the time of construction. The system contains numerous safety devices including sensors which stop the compressors if temperatures or pressures exceed or drop below established limits, and safety relief valves which vent ammonia gas to atmosphere or a water diffusion tank (depending upon where they are located in the system) if the pressure in the system exceeds their set point. In addition, ammonia detectors are located in selected areas of the f acility, and will shut down equipment if ammonia is detected. Lastly, an emergency "dump box" contains switches and valves to turn off equipment and vent ammonia if necessary. 5. FIVE YEAR ACCIDENT HISTORY Warmerdam Packing Co. has not had any reportable accidents 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." Federally, Title 29 CFR 1910.38 and 1910.119), HAZWOPER (standard (in California CCR Title 8, Section 5192, "Hazardous Waste Operations and Emergency Response," and Title 29 CFR 1910.120). Strategically, we will respond Defensively to a release. Under this strategy, if an ammonia release is detected emergency notifications will begin, and most facility employees will evacuate to a safe refuge area. Maps showing the safe refuge area are posted throughout the plant. Every year at the beginnin g of the season we review with our employees our evacuation procedures in the event of an emergency, including an ammonia release. We have a windsock at our facility that employees can use to determine the "upwind" side of any point of release. Selected employees who have received appropriate training shall take defensive steps (what can be accomplished by operating controls from a distance, without entering ammonia vapors) to bring the release under control. If these steps are not sufficient, then further response will be by the Visalia Hazardous Materials Response Team. When these outside responders arrive, any Warmerdam Packing Co. employees who have been trained to the offensive level shall assist and participate in carrying out offensive steps (steps which might require the donning of personal protective equipment in order to approach the point of release) to bring the release under control. 7. PLANNED CHANGES TO IMPROVE SAFETY Our company has an outstanding safety record, one that we are quite proud of. Many policies and procedures have been implemented to promote overall plant, worker and public safety. Nevertheless, Warmerdam Packing Co. continually strives to improve in all areas, including safety. We have implemented several changes to improve safety during our preparation of a Risk & Process Safety Management plan. One change has been to group the plan elements to align with Warmerdam Packing Co. business practices rather than the order presented in the law. Safe Operating Procedures are now grouped together for the benefit of our system operators. Safe Operating Policies are now grouped together so that appropriate office staff may administer them. The Emergency Action Plan is now separated out and distributed widely through the plant for easy reference. A second change has been to ensure that plan documentation forms and company policy forms pertaining to employee, contractor, and community safety are merged together to prevent unnecessa ry complexity and redundancy. Forms in the plan that are not being used will be discarded and replaced with more relevant documents. Alternatively, forms that are being used at Warmerdam Packing Co. that meet plan documentation requirements, but which weren't acknowledged by the plan, are now included. A third change is that operators have assisted in the writing of Standard Operating Procedures for ease of use. In addition, there is now a method for receiving operator feedback and making changes in the future. The last, but perhaps most fundamental change, is that the Risk & Process Safety Management Program is now thought of as a "living document". It is an interactive framework that guides safe action for Warmerdam Packing Co. employees. Through the Risk & Process Safety Management Program Warmerdam Packing Co. will continue to profit while maintaining overall plant, worker and public safety. |