Sunpure, LTD. Avon Park Citrus Plant - Executive Summary
SUNPURE, LTD. - AVON PARK CITRUS PLANT |
RISK MANAGEMENT PLAN
1. Corporate Prevention and Emergency Response Approach
The Sunpure, LTD. Avon Park Citrus Plant (Sunpure) is a citrus processing and storage facility, located in Avon Park, Florida. Sunpure management requires the facility to develop and maintain accident prevention programs and an emergency action plan appropriate to the site.
2. Description of Stationary Source
The Sunpure Avon Park Citrus Plant is located at 1600 Sunpure Road, in Avon Park, Florida. The facility consists of areas for processing and freezer storage of citrus products for distribution.
The Sunpure plant has an ammonia refrigeration system, which exceeds the 10,000 lb. RMP threshold quantity. The ammonia refrigeration system's equipment is located in the machine or compressor room. The high pressure receiver (HPR) is located inside the compressor room. The HPR is the largest capacity vessel in the ammonia refrigeration system, ca
pable of holding approximately 26,520 lbs. of ammonia. This vessel was used to determine the OCA for the Facility.
3. Description of the Worst Case and Alternative Release Scenarios
The Worst Case release scenario is the rupture of the HPR vessel, releasing 26,520 lbs. of ammonia gas over a 10-minute period. Under worst case weather conditions and considering passive mitigation in rural topography, the ammonia gas could travel 1.6 miles before dispersing enough to no longer pose a hazard to the public or environment (reaching a concentration less than .14 mg/L), using the EPA Ammonia Guidance method.
The Alternative Release Scenarios is a pipe leak at a mitigated release rate of 300 lb./min. from the HPR liquid supply line due to pipe connection failure from worker/human error or corrosion of the pipe. Under normally expected weather conditions, taking into consideration the passive mitigation in rural topography, the ammonia gas could travel 0.3 miles before dispersing enough to
no longer pose a hazard to the public or environment (reaching a concentration less than .14 mg/L), using the Ammonia Guidance method.
4. Prevention Program
This facility exceeds the ammonia threshold quantity for its ammonia refrigeration system for the OSHA Process Safety Management (PSM) Standard, 1910.119, and is therefore subject to the PSM requirements. For RMP compliance purposes, this also places the Sunpure refrigeration processes in the Program 3 level. The Sunpure facility will use its PSM program as the required Program 3 Prevention Program.
The Sunpure facility is developing a program to comply with the OSHA Process Safety Management Standard, 29 CFR 1910.119. The PSM Program includes a preventative maintenance plan, which requires all ammonia refrigeration equipment to be periodically inspected and serviced. This will ensure that the equipment remains in good operating condition and will minimize the probability of accidents due to faulty equipment. In developi
ng the PSM Program, the Sunpure facility also developed written operating procedures for the refrigeration processes. These procedures cover all phases of operation and include information on safety devices. These procedures will be used to train all operators and mechanics that work on the ammonia refrigeration processes to ensure consistency of operation and minimize human error. These measures ensure that all refrigeration operators and mechanics are properly trained. Existing safe work practices such as Lockout/Tagout and Hot Work Permit, were reviewed and updated to ensure that all non-routine work can be performed safely. Other components of the prevention program include collection and review of all equipment information, the development of updated Piping & Instrumentation Diagrams (P&IDs), and the correction of any equipment design deficiencies found. These actions will ensure that the equipment meets all refrigeration industry standards and that accurate equipment inform
ation will be available when needed. A Process Hazard Analysis (PHA) training will be conducted. Other PSM procedures, including Management of Change, Pre-Startup Safety Review, Compliance Audits, and Incident Investigation are also part of the program to ensure continued safe operation and prompt correction of deficiencies. The PSM Program development effort receives full support of plant management and involves employees at all levels.
5. Accident History
The Sunpure plant has had no accidental releases of ammonia in the past five years.
6. Emergency Response Program
The Sunpure Avon Park Plant has an Emergency Action Plan in place. The program complies with 29 CFR 1910.38. The current plan has been coordinated with the Avon Park Fire Department and Hazardous Materials Response Team, and the Region #7 Local Emergency Planning Committee. Notification is made locally by dialing 911, and by notifying Florida State Warning Point at (800) 320-0519 or (813) 534-7130.