R. B. Sandrini - Executive Summary |
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Table of Contents For Executive Summary 1. R. B. SANDRINI 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 1. R. B. SANDRINI RISK & PROCESS SAFETY MANAGEMENT PROGRAM This is to inform all interested persons, including employees, that R. B. Sandrini is preparing 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 2 9 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 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 commercial cold storage for table grapes. We store all of our packed product in cold storage. Our facility has two ammonia systems (North & South) with a combined system charge of 23,000 lbs. The systems are completely separate from one another. The north system provides refrigerating capacity to two cold storage rooms equipped with forced air cooling and three cold storage rooms for palleted product. The south system provides refrigerating capacity to one cold storage room equipped with forced air cooling, two cold storage rooms for palleted product, one hallway and the shipping area. The systems operate as follows. High pressure liquid from our main receiver is piped to each cold room, where it passes through an expansion valve into low temperature & pressure accumulator vessels. From the accumulators, cold liquid ammonia is circulated through evaporator coils. As heat is absorbed, the liquid ammonia vaporizes to form low temperature & pressure gas which is returned to the accumulator vessel. The ammonia vapor is returned from the accumulator vessels through a suction return line to our engine room, where it passes through a compressor. The high pressure discharge from the compressor is sent to a water cooled condenser where the high pressure gas ammonia is cooled, liquified and returned to our receiver. The ammonia system at our facility consists of vessels which are interconnected, or which are co-located such that a release of ammonia could impact the ability to operate vessels which are not directly connected. Therefore, we are treating our facility as a single process. 3. AMMONIA RELEASE SCENARIOS 3.1 Worst Case Scenario Our worst case scenario is the failure of our south system high pressure receiver containing 15,000 lbs of ammonia. This vessel is located in the mechanical room, and the release would be passively mitigated. The ammonia would be released over a ten minute period. Using the program RMP*Comp we estimate that the ammonia would travel 1.6 miles (rural conditions) before dispersing enough to no longer pose a hazard to the public. A ma p showing the area that would be affected is attached. 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. We assumed that a Safety Relief Valve on the north system lifts, releasing ammonia vapor to the atmosphere. Drawing upon experience, and using the modeling program ALOHA, we estimated that a severe leak could release ammonia at a rate of 57.6 lbs/min into a confined cold storage room. We assumed the leak would continue for 10 minutes until the leak was noticed and the flow of ammonia to the coil was stopped. Under this scenario 576 lbs of ammonia would be released over a time period o f 10 minutes. The release would not be passively mitigated by being outdoors. Using RMP*Comp we estimate that the ammonia would travel less than 0.2 miles (rural conditions) before dispersing enough to no longer pose a hazard to the public. A map showing the area that would be affected is attached. 4. GENERAL ACCIDENT RELEASE & AMMONIA SPECIFIC PREVENTION STEPS The ammonia refrigeration system at R. B. Sandrini is an integral part of the overall business. 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. The ammonia refrigeration system/process is constantly being monitored by our refrigeration operator. In addition, the system/process is checked frequently by our outside refrigeration contractor, California Controlled Atmosphere, who also performs an annual pre-season preventative maintenance review of our system/process e quipment. Half of our system is controlled by a computer which monitors many process variables, and allows remote control. In the event of a system upset the computer actuates a dialing program that alerts key personnel and responders. We have ammonia detectors which also trigger alerts. 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, which in the south system ar e piped to a water diffusion tank and in the north system are vented to the atmosphere. These valves limit the operating pressures of the entire system, and prevent failures due to overpressurization. All ammonia released through the safety relief valves in the south system is trapped in the water, and is not emitted into the air. All ammonia released through the safety relief valves in the north system is emitted into the air. 5. FIVE YEAR ACCIDENT HISTORY R. B. Sandrini 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" 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 plan to respond Defensively to a release. Employees will receive Defensive Training (First Responder, Operations Level) specific for ammonia response and meeting HAZWOPER criteria later this year. Under this plan our employees will take whatever steps are necessary to bring a release under control. Initial training to the defensive level (First Responder, Operations Level) as defined in the HAZWOPER regulations will take place before the end of the year. 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 performed by an outside agency. All response activities would be coordinated with the local fire department and the Fresno County Fire Department Hazardous Materials Response Team. 7. PLANNED CHA NGES TO IMPROVE SAFETY As of May 22, 2000, the time that this Executive Summary is being submitted, our Risk & Process Safety Management Plan is not complete. The reason is that we are only now expanding the system such that our ammonia inventory will be in excess of 10,000 lbs. Also, our company operates seasonally and we have found that our ability to allocate managerial and operator resources to prepare this plan depends upon our workload. In addition, we have found it necessary to obtain help from outside vendors for some critical elements, such as preparing Piping & Instrumentation Diagrams and conducting a Process Hazard Analysis. These vendors are attempting to meet the requests of numerous facilities such as ours at the same time, and have the same problem of only a limited number of people qualified to carry out the required tasks. Thus, these vendors are setting completion dates for plan elements that we cannot entirely control. However, we have prepared the following m ilestones and allotted times for the completion of our plan: Milestone Allotted Time ? Conduct Offsite Consequence Analysis Done ? Prepare RMP*Submit showing status as of 5/22/00 Done ? Collect Process Safety Information 30 days - By June 21, 2000 ? Conduct Process Hazard Analysis On or around June 6, 2000 ? Finish PHA documentation including Action List 30 days - By June 22, 2000 ? Prepare Process Prevention Program elements 60 days - By July 22, 2000 ? Prepare Standard Operating Procedures 60 days - By July 22, 2000 ? Compile all elements into Risk & Process Safety Management Program, review internally, and submit 90 days - By Aug 22, 2000 We understand our obligations to consolidate our safety activities in a Risk Management Program under the CalARP regulation. We are committed to preparing and implementing a Risk & Process Safety Management Program according to the above milestone and timeline chart. |