Royal Valley Fruit Growers Association - Executive Summary |
|
Executive Summary for Royal Valley Cold Storage Introduction This report and Risk Management Plan was developed to comply with US EPA and Cal ARP requirements. Royal Valley Growers Association chose Cold Storage Technologies to review it?s existing policy?s, procedures, documentation and refrigeration system for compliance with new requirements. After the review Royal Valley Growers Association decided to choose to implement an Ammonia industry standard for regulation compliance. The IIAR Guidelines provide Ammonia Refrigeration specific detailed templates that are customized for a specific facility. Resources used in the process were International Institute of Ammonia Refrigeration (IIAR) Guidelines and RMP Pro 98 OCA Software by Dyadem. Executive Summary organization includes; Certification statement, Summary, Detailed Elements and Map of Potential Impact. A current copy of RMP, PSM and PHA materials can be reviewed at the facility by contacting Ken Suemoto. Since the ma terials consist of several 2" binders and facility drawings which are constantly updated as changes are implemented, any reproduction becomes obsolete at the time of printing. 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). This facility will not make specific RMP or OCA information available to the public until a final ruling is made. General details only will be discussed at a required public meeting scheduled for 1/12/2000. Any accidental or authorized release of information in section 2-5 by government officials violates Federal Law. 1. Accidental Release Prevention and Emergency Response Policies We at Royal Valley Fruit Growers Association are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our use of Industrial Refrigeration Contractors for all maintenance including remote system monitoring in addition to 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 and perform preventative maintenance to prevent possible releases of regulated substances. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities are consistent with SIC code 0723. Specific activities include washing, packing, pre-cooling and cold storage of grapes and tree fruit. The flooded Ammonia refrigeration system provides 3 pre-coolers, 3 storage rooms 1 refrigerated hallway/dock and a hydro-cooler. Ammonia (anhydrous) refrigerant is the only regulated substance present at our facility above thresholds requiring an RMP. Total system NH3 capacity is estimated at 17,700 lbs.. Sulphur Dioxide seasonally used for fumigation is also present however quantities are under 300 lbs. 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 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. No specific unusual external events were included due to the facilities rural location, remote equipment location and recent construction meeting all applicable seismic and safety codes. Potential impacts by forklift or other facility traffic typical to this type of operation were included. Any catastrophic type events would result in the same impacts as presented in this OCA or less. The following paragraphs provide details of the chosen scenarios. 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 involv es a catastrophic release from Ammonia Refrigeration . In this scenario 10739 lb. of Ammonia (anhydrous) is released. This is the combined capacity of the interconnected High Pressure Receivers. The actual amount used for calculations was 15,000 lbs. since it was the closest table value available. 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 minutes. Evaporation at this rate is required but very unlikely. The released quantity has been limited to 61% of the maximum capacity of the source by the flooded refrigeration system design characteristics and limited HPR capacity. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 1.42 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. Tree?s surround the facility providing an urban-like setting. Estimated population within this circle is 195. Population impacted would be approximate ly 10% or less based on a plume footprint. This scenario does not represent historical performance of these types of refrigeration systems. The alternative release scenario for Ammonia (anhydrous) involves a release from Ammonia Refrigeration . The scenario involves the release of 3000 lb. of Ammonia (anhydrous). 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 30 minutes. Under neutral weather conditions, an urban setting because of the surrounding orchards, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (anhydrous) is 0.085 miles. Estimated public receptors are 17.. This alternate release scenario follows EPA guidelines for Ammonia refrigeration however it does not represent typical releases from a flooded Ammonia system. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all t he 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 Royal Valley Fruit Growers Association 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 10/21/1999. Operating Procedures For the purposes of safely conducting activities within our covered processes, Royal Valley Fruit Growers Association 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 Royal Valley Fruit Growers Association 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 Royal Valley Fruit Growers Association 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, piping 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 Royal Valley Fruit Growers Association to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 11/29/1999. 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 Royal Valley Fruit Growers Association. The most recent review was performed on 04/01/1999. 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 Royal Valley Fruit Growers Association conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent compliance audit was conducted on 11/29/1999. 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 Royal Valley Fruit Growers Association promptly investi gates 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 years. Employee Participation Royal Valley Fruit Growers Association 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. Contractors Our company hires contractors to conduct maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performa nce of the contractor is carried out. Royal Valley Fruit Growers Association has a strict policy of informing the 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 Royal Valley Fruit Growers Association 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 during this period. 6. Emergency Response Plan Royal Valley Fruit Growers Association 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 decontamin ation of affected areas. To ensure proper functioning, our emergency response 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. 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. Redundant system isolation valve access, valve labeling, more frequent relief valve replacement and daily walkthrough logs of important pressures are some of the major steps we want to take to improve safety at our facility. These changes are expected to be implemented by 6/1/2000. |