Kingsburg Apple - Executive Summary |
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1. THE KINGSBURG APPLE, RISK & PROCESS SAFETY MANAGEMENT PROGRAM This is to inform all interested persons, including employees, that Kingsburg Apple 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 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 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. We have: (1) prepared a unified program based on the PSM plan to meet CalARP obligations as well; (2) reorganized the program so that it meshes more closely with general Kingsburg Apple business practices; and (3) reviewed plan documentation forms and responsibilities. The unified Risk & Process Safety Management Plan sets forth rules, procedures and practices which will help our employees protect themselves and our neighbors. 2. DESCRIPTION OF AMMONIA SYSTEM The Kingsburg Apple facility is a commercial packinghouse for deciduous tree fruit, primarily apples. The facility has two ammonia systems, the North System and the South System. They are not linked; however, they are located close enough together so that an accident involving one may impact the other. Therefore, they are being treated as a single system. The south system is older. It has three reciprocating compressors in an engine room providing cooling capacity to a precool room, two cold storage zones, and four controlled atmosphere rooms. The ammonia system has a single high pressure receiver, a single BAC condenser, and a single main suction accumulator with liquid transfer vessel. The north system is newer. It has five screw compressors in two engine rooms providing cooling capacity to two precool rooms, three fumigation rooms, and four controlled atmosphere rooms. The ammonia system has three high pressure receivers, two of which are linked by liquid and vapor transfer lines. The third receives liquid from the first two by a transfer line controlled by a liquid switch and solenoid valve. It has four BAC co ndensers, two main suction accumulators with liquid transfer vessels, a hydrocooler, and two thermosyphon oil cooling vessels. A computer system is used to control the North System. Both systems operate in a similar fashion. High pressure liquid from a high pressure receiver is piped to a series of a liquid feed solenoid valves outside of each cold room, where it passes through an expansion valve into a low pressure accumulator vessel. Low temperature liquid circulates by thermal convection through the evaporator coils located behind bunker walls in the cold rooms. Low pressure and temperature gas collects in the accumulator vessel, and passes through a pressure regulator into a suction line. The suction line returns the vapor to a main suction accumulator vessel located in the engine room, which separates any residual liquid from the gas. The gas is piped to compressors which elevate the temperature and pressure of the gas. The high pressure discharge from the compressor is s ent 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 maain suction accumulator drains into liquid transfer vessels. Operation of a float switch activated solenoid valve raises the pressure in the liquid transfer vessel to the point the liquid can be drained into the high pressure receiver. The facility was built by professional refrigeration engineers in accordance with the Uniform Mechanical Code and Uniform Building Code applicable at the time of construction, and good industry practice. 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 a water diffusion tank if the pressure in the system exceeds their set point. In addition, ammonia detectors are located in selected areas of the facility, and will shut down equipment if ammonia is detected. Lastly, emergency "dump boxes" contain switches and valves to turn off equipment and vent ammonia if necessary. 3. AMMONIA RELEASE SCENARIOS 3.1 Worst Case Scenario At Kingsburg Apple, the worst case scenario is the failure of one of our three interconnected high-pressure receivers on the North system. This vessel contains 18,000 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 other connected vessels, or in the pipework connected to the vessel. In our scenario, the release would not be mitigated because the receiver vessel is outside. The ammonia would be released over a ten-minute period. Using RMP*Comp we estimate that the ammonia would travel 2.6 miles (rural conditions) before dispersing enough to no longer pose a hazard to the public. The potent ially affected area can be found on a site map in Appendix A. 3.2 Alternative Case Scenario 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 over pressurization. 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 less than 0.1 miles (rural conditions) before dispersing enough to no long er pose a hazard to the public. The potentially affected area can be found on a site map in Appendix A. 4. GENERAL ACCIDENT RELEASE & AMMONIA SPECIFIC PREVENTION STEPS The ammonia refrigeration systems at the Kingsburg Apple facility are an integral part of the overall business. The system contains a total charge of approximately 32,000 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 journal 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 performs an annual pre-season preventative maintenance review of our system/process equipment. We inform our employees of the dangers o f an accidental release of ammonia in pre-season safety meetings. 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. Our ammonia refrigeration system was designed and built by professional refrigeration engineers in accordance with good industry practice and codes. It was also built in compliance with the Uniform Building Code and Uniform Mechanical Code applicable at the time of construction. 5. FIVE YEAR ACCIDENT HISTORY Kingsburg Apple 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, "Hazardou s Waste Operations and Emergency Response," and Title 29 CFR 1910.120). Strategically, we will respond defensively to a release. Under this plan our ammonia refrigeration personnel will take whatever steps are necessary 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. To better prepare for this type of action, initial training to the defensive level (First Responder, Operations Level) as defined in the HAZWOPER regulations will take place within the next year. All response activities would be done in coordination with the local fire department and the Visalia Fire Department Hazardous Materials Response Team. Every year at the beginning of the season we review with our employees our evacuation procedures in the event of an emergency, including an ammonia release. 7. PLANNED CHANGES TO IMPROVE SAFETY Our company has an outstanding safet y record, one that we are quite proud of. Many policies and procedures have been implemented to promote overall plant, worker and public safety. Nevertheless, Kingsburg Apple continually strives to improve in all areas, including safety. Preparation of this Risk & Process Safety Management Program has been the primary recent improvement, and implementation of the program is our plan for improved safety in the near future. The Risk & Process Safety Management Program has been written so that program elements are aligned with Kingsburg Apple business practices rather than the order presented in the law. Thus, Safe Operating Procedures are grouped together for the benefit of our system operator. Safe Operating Policies are 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. The Risk & Process Safety Management Program documentation forms and company poli cy forms pertaining to employee, contractor, and community safety have been carefully reviewed so as to prevent unnecessary complexity and redundancy. Our operator assisted in the writing of Standard Operating Procedures, and they are presented in a format which is easy to use. For the future, Kingsburg Apple now thinks of the Risk & Process Safety Management Program as a "living document". It is an interactive framework that guides safe action for Kingsburg Apple employees, but allows for feedback and continual improvement. Through the Risk & Process Safety Management Program Kingsburg Apple will continue to profit while maintaining overall plant, worker and public safety. |