P-R Farms, Inc. - Executive Summary |
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Executive Summary Introduction The Risk Management Program at P-R Farms, Inc. complies with US EPA and Cal ARP requirements. International Institute of Ammonia Refrigeration's (IIAR) RMP and PSM Guidelines have been implemented at this facility. The procedures for complying with the RM Program regulations are outlined by the following major steps: 1. Identify Covered Processes 2. Determine Program Level 3. Establish a Management System 4. Conduct a 5 year Accident History 5. Perform Hazard Assessments 6. Develop an Accident Prevention Program 7. Develop an Emergency Response Program and 8. Prepare a Risk Management Plan (RMP) Publication or sharing of OCA portions of RMP materials can be in violation of the Chemical Safety Information, Site Security and Fuels Regulatory Relief Act (PL106-40). 1. Accidental Release Prevention and Emergency Response Policies We at P-R Farms, Inc. are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass Packing and cold storage of grapes and tree fruit. Some long term frozen storage occurs. We have 1 regulated substance present at our facility. These substances include and Ammonia (anhydrous). Ammonia (anhydrous) is used for a closed loop recirulated refrigeration system. 3. The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario The worst-case release scenario mandated by the RMP Rule is a standardized hypothetical situation intended to promote "dialogue". According to the International Institute of Ammonia Refrigeration "The worst-case situation represents an extremely improbable (and for many facilities impossible) set of circumstances rather than a credible accident scenario. Release quantities and hazard distances derived therefrom for the worst-case scenario should not be used as a basis for emergency response planning." To perform the required offsite consequence analysis for our facility, we have used the EPA's RMP Guidance for Ammonia Refrigeration Reference Tables or Equations. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves a catastrophic release from Ammonia Refrigeration. In this scenario 16506 lb. of Ammonia (anhydrous) is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 10 mi nutes. At Class F atmospheric stability and 1.5 m/s windspeed, The maximum distance of 1.63 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. The alternative release scenario for Ammonia (anhydrous) involves a release from Ammonia Refrigeration. The scenario involves the release of lb. of . Toxic liquid is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after minutes. The release is also assumed to be controlled by manual equipment isolation. These active mitigation systems have the effect of limiting release to 30 minutes. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (anhydrous) is 0.085 miles. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA. This facility was designed and constructed in accordance with NFPA-58 Standard, 1967 Edition. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information P-R Farms, Inc. maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology used to carry out these analyses is What If/Checklist (combined). The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of 5 years. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 03/31/2000. Operating Procedures For the purposes of safely conducting activities within our covered processes, P-R Farms, Inc. maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training P-R Farms, Inc. has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes. Refresher training is provided at least every 3 years and more frequently as needed. Mechanical Integrity P-R Farms, Inc. carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, pipin g systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at P-R Farms, Inc. to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 03/31/2000. 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 and to modifications in established processes are conducted as a regular practice at P-R Farms, I nc.. The most recent review was performed on 03/31/2000. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits P-R Farms, Inc. conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent comliance audit was conducted on 03/31/2000. These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation P-R Farms, Inc. promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic 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 reoccurring. All reports are retained for a minimum of 5 ye ars. Employee Participation P-R Farms, Inc. truly believes that process safety management and accident prevention is a team effort. 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, including information resulting from process hazard analyses in particular. Hot Work Permit At P-R Farms, Inc. Hot Work Permit procedures are in place and enforced. Preventing accidents related to welding and cutting while alerting others at the facility that this type of work is occuring are important prevention steps. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. P-R Farms, Inc. has a strict policy of informing th e contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History P-R Farms, Inc. has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release at the Shepherd facility during this period. 6. Emergency Response Plan P-R Farms, Inc. carries 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 response equipment is regularly inspected and serviced. In addition, the p lan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. CA-Region 5 LEPC Inland So. is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been coordinated and verified. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Additional safety training, practice and written daily equipment logs are some of the major steps we want to take to improve safety at our facility. Reviews of other items identified in the PHA are under further technical reviews and management evaluation.These changes are expected to be implemented by 11/30/00. |