Seneca Foods Corporation - Marion Processing Plant - Executive Summary |
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EXECUTIVE SUMMARY I.OVERVIEW Seneca Foods Corporation, Marion Processing Plant is located at 3732 South Main Street, Marion, New York. This Risk Management Plan is prepared to comply with 40 CFR Part 68 as issued by the U.S. Environmental Protection Agency. Anhydrous ammonia, CAS No. 7664-41-7, is stored at this facility. Anhydrous ammonia is listed as a regulated toxic substance under 40 CFR 68.130 with a threshold quantity of 10,000 pounds. Our system has the capacity to hold up to 15,000 pounds of anhydrous ammonia. It is difficult to determine exactly the amount we currently have, as ammonia is flowing throughout the system. The last delivery of anhydrous ammonia to the facility was on 8/28/96 and totaled 5,993 pounds. Anhydrous ammonia (CAS No. 7664-41-7) carries a NFPA "Health" hazard category rating of "3" (4 is maximum) and a "Flammability" hazard category of "1" (4 is maximum). Release of an entire system inventory is not a credible scenario since each piece of equipm ent can be individually isolated with block valves. Liquid ammonia, if released to the atmosphere boils at -28: F resulting in a large-scale generation of vapor which can reach harmful concentrations. Vapors are lighter than air (0.6) and therefore have a tendency to rise, assisting in dispersal. In addition, ammonia vapor is flammable in concentrations between 16 - 25% by volume in air. Although, ignition is not common. The anhydrous ammonia is used at this facility as a refrigerant for individually quick freezing of fresh vegetables. The primary frozen products are 1" cut green and wax beans and whole kernel corn. The frozen product is packed into bulk totes and shipped to an outside-refrigerated warehouse. The ammonia system is a conventional commercial/industrial refrigeration design using anhydrous ammonia as the working fluid. "High Pressure" liquid ammonia at approximately 150 psi. is fed through a distribution system in a Frigoscandia IQF freezer where heat is removed by phase-change evaporation of ammonia liquid. Vapors are returned and compressed via two separate systems operating at 5 psi and the other at 25 psi. The booster compressor discharges (at approximately 25 psi) to an intercooler where the high stage compressor takes the suction and discharges (at approximately 165 psi) to an evaporative condenser where ammonia is liquefied and routed to the high-pressure receiver. There the pressure is reduced to 150 psi and ammonia routed to the Frigoscandia IQF freezer and the cycle continues. The facility has 144 full time employees. This is broken down as follows: 75 Full time and salaried employees: 75 x 1 = 75 275 Budgeted seasonal employees working 3 months (25%): 275 x 25% = 69 Total equivalent full time employees = 144 We have not received an Air Operating Permit ID under CAA Title V from the EPA. The Air Operating Permit ID listed in the plan is a New York State issued ID number. II. ACCIDENTAL RELEASE PREVENTION A. MANAGEMENT SYSTEM This facility is in compliance with OSHA PSM 19 CFR 1910.119. The plant has a Process Safety Management Committee consisting of Plant management personnel and refrigeration operators. The committee meets monthly to discuss and update the PSM program as necessary. Program discussions and updating include, but not limited to: PSM Program Procedures Standard Operating Procedures Process Hazard Analysis (PHA) Training The Plant Manager is responsible for: Overall PSM Program implementation. Review all requested changes and initiate disposition activities. Manage the revision, distribution, and control of all PSM Program documentation. The PSM Coordinator is responsible for: Conducting Monthly PSM meetings with the PSM committee. Reviewing and updating of PSM data. Reviewing and updating Process Safety Information (PSI) including: Process & Instrumentation Diagrams, Valve tagging, Pipe markings and the Relief valve program. Maintaining an updated Material Safety Data Sheet. The Maintenance Supervisor is responsible for: All maintenance related activities on the ammonia system. The Refrigeration Operators are responsible for: Operation of the ammonia system. Performing preventive maintenance on the ammonia system per the Preventive Maintenance Manual. B. OTHER PREVENTION MEASURES We maintain a log of each relief valve installed on the ammonia system. Relief valves are replaces every five years or after a discharge. Which ever occurs first. The Marion Fire Department will be the first responders in the event of an uncontrolled release. The Wayne County Fire Coordinator will notify the Xerox Hazardous Materials Team. The Marion Fire Department and Xerox Hazardous Materials Team are each invited to tour this facility annually. The Marion Fire Department toured this facility last on April 27, 1999. The Xerox Hazardous Material Team is tentatively scheduled to tour in the fall of 1999 during the months of October or November. Outside contractors who work on the ammonia system are experienced with working on ammonia systems. C. EMPLOYEE PARTICIPATION All employees annually or upon hire, are informed of the ammonia on site and its' location. Employees are also informed of the hazards involved with ammonia. They are informed of the PSM Program and are able to review the program at any time through a written request to their supervisor. D. PROCESS HAZARD ANALYSIS (PHA) The original PHA for the facility was conducted on May 15, 1995. A PHA update was conducted on April 8, 1999. The PHA's from 5/15/95 were reviewed and a new PHA was conducted with the main emphasis on new equipment and recent changes. The entire ammonia system was covered to bring forward any concerns, which may have been missed, from the 1995 PHA's. In the plan, section 7.4H, it is stated "installation of process controls" and "installation of process detection systems" have been installed since the last PHA. This is referring to the PHA on May 15, 1995. III. FIVE YEAR ACCIDENT HISTORY No accidents or injuries have occurred in the past five years as a result of an ammonia release, both on and off site. IV. WORST-CASE SCENARIO The worst-case scenario for this facility would be a release of anhydrous ammonia from the high-pressure receiver. This vessel is located inside the compressor room. It is identified with a sign stating "HIGH PRESSURE RECEIVER". It measures 20.0 feet long by 5.0 feet high. This vessel will on occasion reach a level of 70% full with liquid ammonia and the remaining space will be ammonia vapors. At this level we have an inventory of 10,160 pounds. 10,082 pounds liquid and 78 pounds vapors. Typically, the liquid level is at 50% or less. At 50% liquid and 50% vapors, this will carry an inventory of 7,332 pounds. 7,202 pounds liquid and 130 pounds vapors. Within the compressor room, we have three 13,000 cfm each exhaust fans which will exhaust the vapors from the compressor room to the atmosphere. Tabl es and equations used to determine the distant end point were from the EPA CEPPO Model titled "Risk Management Program Guidance for Ammonia Refrigeration" dated November 1998. The size of our compressor room is 67,856 cubic feet. The compressor room will slow down the release of vapors to the atmosphere since the vessel is located indoors. The end point for this scenario equals 0.8 mile based on the model equations. The estimated residential population is 1200, within the 0.8 mile circle. This figure was arrived at using the "Wayne County Population Distribution for Risk Management Planning" map. This map is located at the Wayne County Emergency Management Office in Lyons, New York. The map was prepared by the Monroe County Department of Planning, GIS Services. Source data: US Bureau of Census - 1990. V. ALTERNATIVE-RELEASE SCENARIO The alternative-release scenario chosen for this program is the breakage of a valve off of the water chilling vessel by cans being conveyed on c an track approximately 6 inches from the vessel valves. This vessel is used to supply ammonia to a plate chiller used to chill water. This chilled water is then directly sprayed onto the product to lower the product temperature prior to freezing. This adds to the effectiveness of the freezing operation. The cans on the track are full 6/10 cans of product discharging from a nearby sterilimatic cooker. Each can weighs approximately 6 pounds 6 ounces. It is possible that cans can back up on the track and possibly fall out. As the cans fall, there is a possibly that they could strike the valves, break the valves and cause a release of ammonia. This vessel is located inside the cooker discharge room. It is identified with a sign stating "WATER CHILLER". It measures 5.5 feet long by 1.0 feet high. Typically, the liquid level is at 50% or less. At 50% liquid and 50% vapors, this will carry an inventory of 86.0 pounds. 85.5 pounds liquid and 0.5 pounds vapors. Within the cooker discharge room, we have one 2,000-cfm exhaust fan, which will exhaust the vapors from the room to the atmosphere. Tables and equations used to determine the distant end point were from the EPA CEPPO Model titled "Risk Management Program Guidance for Ammonia Refrigeration" dated November 1998. The size of our cooker discharge room is 51,205 cubic feet. The room will slow down the release of vapors to the atmosphere since the vessel is located indoors. The end point for the alternative-release scenario equals 0.1 mile based on the model equations. The estimated residential population is 50, within the 0.1 mile circle. This figure was arrived at using the "Wayne County Population Distribution for Risk Management Planning" map. This map is located at the Wayne County Emergency Management Office in Lyons, New York. The map was prepared by the Monroe County Department of Planning, GIS Services. Source data: US Bureau of Census - 1990. A map with Seneca Foods Corporation as the cent er point is maintained at the plant. On this map are the 0.1 mile and 0.8 mile circles from the plant. Also entered on this map are area roadways, and common public receptors. A separate list is also maintained of all area businesses located within the circles. VI. EMERGENCY RESPONSE PLAN An Emergency Response Plan is in place at this facility. The Plan includes an evacuation plan for the facility in the event of an emergency that requires the plant to be evacuated. It also has the plans in the event of an incidental release of ammonia as well as an uncontrolled release of ammonia. For an incidental release of ammonia, this is a small release, which can be quickly controlled and/or isolated by our own maintenance personnel. In the event of an uncontrolled release of ammonia, the facility will be evacuated using the evacuation procedure and the Fire Department will be called to respond. Seneca Foods employees are not first responders in the event of an uncontrolled release of ammonia. Wayne County Fire will notify the Xerox Hazardous Material Team to respond to the uncontrolled release of ammonia. In the event that the surrounding community must be evacuated per this Risk Management Plan, this will be handled by the Fire Department with assistance from the County Fire Control. |