Tropicana Northeast Operations - Executive Summary |
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Tropicana Products Inc. (TPI) has a comprehensive program covering accidental release prevention (ARP) and emergency response (ER) in the event of an accidental release of ammonia refrigerant from its Jersey City, New Jersey facility. Tropicana Northeast Operations and its parent company Tropicana Products Inc. are committed to safety and protection of the environment through compliance with EPA Accidental Release Prevention and New Jersey Toxic Catastrophe Prevention Act (TCPA) regulations. As part of compliance with these regulations, TPI has completed the RMP*Submit software program which is an automated tool developed by the EPA for reporting Risk Management Plan (RMP) information. ARP and ER policies: TPI demonstrates its commitment to safety for all site operations by following a written safety program communicated to all personnel at the site. The major elements of this safety program include: a statement of TPI's safety policy, provisions to ensure that all operations and equipment are designed with safety in mind and in accordance with applicable codes, routine safety inspections, failure analysis, safety training, and accident investigation. Facility description and chemicals handled: The facility is a refrigerated warehouse for storage of fruit juices. Anhydrous ammonia is used as the refrigerant. The maximum inventory on site is 69,120 lbs. of anhydrous ammonia. Worst-case and alternative release scenarios: The worst-case release scenario is the complete rupture of the controlled pressure receiver (CPR), which contains as much as 23,640 lbs. of anhydrous ammonia. The CPR is the largest vessel which is outside of the building. The 10 degree recirculator can contain more ammonia, but the release is significantly mitigated by being contained in the building, and thus would produce a shorter distance to toxic endpoint. The alternative release scenario is an ammonia leak from a failed oil valve on the high pressure receiver. This release woul d be limited by automatic shutoff valves after 5 minutes. Other alternative release scenarios were considered in the risk assessment performed as part of the process hazard analysis. Modeling of the release scenarios was performed using DEGADIS for the worst-case release scenario, and ALOHA for the alternative release scenario. Each release scenario might have some off-site impact. General ARP program: The program has been in place since before operations began at the facility in 1990. Tropicana is committed to safety and protection of the environment and accomplishes this with the following programs: 1) Development of and compliance with their Federal and NJDEP approved Risk Management Plan; 2) Review and updating of their Risk Management Plan through annual audits and safety reviews; 3) Maintenance of equipment and process integrity using preventive maintenance and inspections; 4) Appropriate and verifiable training of extraordinarily hazardous substance (EHS) equipment oper ators and other key personnel; 5) Annual emergency response exercises along with review and updating of the site's Emergency Response Plan; 6) Control and supervision of on-site contractor to confirm safe practices; 7) Review and revision of Standard Operating Procedures as necessary to comply with updated process and safety information; and 8) Use of lockout/tagout procedures and other OSHA safety measures to ensure continued safety compliance at the facility. In addition, Tropicana Northeast Operations is a member of the OSHA Voluntary Protection Program and the Jersey City facility has achieved a Star rating from this program. Five-year accident history: There were no accidental releases in the past five years. Emergency response program: Tropicana has a comprehensive emergency response program, including annual full-scale drills and tabletop exercises. The site emergency response team is trained semiannually to identify and respond to alarms, respond to ammonia releases , use emergency protection equipment, perform evacuation procedures, provide scenario-specific action plans, provide emergency medical assistance, and other specially assigned emergency response duties. The site emergency response team coordinates with the local emergency planning committee (LEPC), which is Jersey City's Emergency Management Team. Planned changes to improve safety: Tropicana has an ongoing process of reviewing and updating its document control and environmental management systems. Tropicana recognizes that maintaining safe and environmentally sound operations is a continual process. |