Franzia Winery Tulare - Executive Summary
1.0 Introduction |
A Risk Management Program (RMP) has been implemented at Franzia Tulare for the reduction of accidental releases of hazardous materials. The RMP summarizes the management, administrative, procedural, and technological controls that work together to minimize the risk to the community of hazardous chemical releases. The Risk Management Plan is organized to correspond with specific U.S. Environmental Protection Agency (U.S. EPA) RMP definitions and requirements, including:
7 Franzia Tulare policies to protect health, environment, and safety;
7 Facility identification and regulated substances processes;
7 Hazard assessment;
7 Prevention program;
7 Five-year accident history;
7 Emergency response plan; and
7 Planned changes to improve safety.
2.0 Franzia Tulare Policies to Protect Health, Environment, and Safety
Risk management and safety are important concerns at Franzia Tulare; this RMP formalizes and documents these activities. Franzia Tulare is commit
ted to conducting its operations in a safe and responsible manner and to reducing risks to human health and to the environment.
This commitment to health, the environment, and safety starts with upper management. All managers and supervisors are members of the Safety and Health Committee and routinely dedicate time each month to review health and safety matters. The employees at Franzia Tulare attend health and safety meetings led by their supervisor or manager. Each manager and supervisor reports his/her discussions with employees each month at the Safety and Health Committee meetings. The Committee reviews safety performance, takes corrective action when appropriate, and strives for continuous improvement. Franzia's commitment to safety is demonstrated in the training programs for all employees, including seasonal employees. The training programs provide information on preventing accidents through knowledge of hazards and safe work practices.
3.0 Facility Identification
ia Tulare facility is located at 1887 North Mooney Boulevard, Tulare, California. The facility produces grape juice, wine, and distilled spirits. The facility uses sulfur dioxide for bacterial control and anhydrous ammonia for refrigeration and is regulated under 40 CFR Part 68, the U.S. EPA RMP Rule. The sulfur dioxide process is located at a single filling station. This process can have up to four 1-ton cylinders or 8,000 pounds of sulfur dioxide at the station during heavy use periods.
The ammonia refrigeration process is being modified with changes expected to be completed by August 1999. The modifications will include tying three separate ammonia refrigeration systems into one system. The pressure receivers on three existing systems will be replaced with one single vessel. The modified process will be capable of storing up to 30,000 pounds of ammonia. The data contained in this RMP registration and the off-site consequence analysis reflects the modified ammonia system.
azard Assessment - Worst Case Scenario
The worst-case accidental release scenario is a catastrophic failure of a 1-ton sulfur dioxide cylinder. The sulfur dioxide is maintained as a liquid via pressurization at ambient temperature, resulting in 2,000 pounds of sulfur dioxide.
Hazard assessment modeling shows that, under the worst-case weather conditions and a 10-minute release period, the worst-case release could travel downwind until the toxic endpoint of 3 parts per million (ppm) is reached and affect public receptors. It should be noted that the worst-case scenario is an extremely unlikely event.
5.0 Hazard Assessment - Alternative Release Scenario
An alternative release scenario was modeled for sulfur dioxide and ammonia. The alternative release scenario for sulfur dioxide assumes a 1/4-inch hole developed in a hose line. The release is assumed to occur when an employee is transferring the sulfur dioxide into a smaller cylinder. The release is estimated to travel off site
before the toxic endpoint of 3 ppm is reached. A small numbers of public receptors may be impacted in this scenario.
The alternative release scenario for ammonia assumes a release of ammonia from an oil drain valve. The oil drain valve is assumed to be opened and a plug in the line causes a rapid release of ammonia and oil out of the drain valve. The release is estimated to travel off site before the toxic endpoint of 200 ppm is reached. Although the release reaches an endpoint off site, no public receptors are impacted in this scenario, which is more credible than the worst-case release scenario.
6.0 General Accidental Release Prevention Program
A prevention program is in place to minimize the risk of hazardous chemical releases in accordance with the California Occupational Safety and Health Administration (CalOSHA) Process Safety Management (PSM) standard (Section 5189 of Title 8, CCR) and the U.S. EPA RMP. This prevention program covers those processes that handle sulfur dioxid
e and ammonia above the threshold quantity of either PSM or RMP rules.
The prevention program provides a structured approach to preventing accidents. Some of the specific activities in the prevention program include the following:
7 Process safety information is provided to all employees upon hire and is accessible at all times.
7 In-depth process hazard analyses are completed every 5 years by qualified personnel using
techniques approved under the PSM standard.
7 Written operating procedures (kept up to date) are used for training and guiding the work of operators.
7 Training is provided to all employees upon hire, and refresher training is given at least every 3 years
or upon request.
7 Operators, mechanics, and contractor personnel are qualified, trained in the general hazards in the
facility, and informed of any temporary situations affecting safety.
7 Pre-startup safety reviews are conducted to insure that conditions for safe operation have been
satisfied prior to
starting new or modified equipment.
7 A program is in place to maintain the mechanical integrity of the process, which includes written
procedures, training requirements, equipment deficiency requests for employees, work orders,
scheduled maintenance, and documentation.
7 A hot work permit system assures that work is done safely and properly.
7 A management of change system is in place to ensure that changes are managed safely.
7 Incidents are investigated and actions are taken as part of a continuous improvement effort.
7 Routine audits are conducted to assure that safe practices are being followed.
This systematic approach to process safety involves employees and strives for continuing improvements in overall safety. The training, qualifications, and safety awareness of our operations, maintenance, and management personnel are a key element in reducing and mitigating accidents.
7.0 Five-Year Accident History
Since July 16, 1995 when The Wine Group took over the facility,
there have been no accidents or releases of regulated substances from covered processes that meet specific U.S. EPA criteria for the 5-year accident history. Such "RMP accidents" would involve serious accidents with either on-site deaths, injuries, or significant damage; or known, off-site deaths, injuries, property damage, or environmental damage. Franzia Tulare realizes that the community may also be interested in smaller releases of regulated chemicals that do not meet such criteria. We have been diligent in reporting releases of hazardous materials and in internally investigating and correcting the causes of such releases.
8.0 Emergency Response Plan
The federal RMP and CalARP regulations grant exemptions for the emergency response plan to facilities that do not conduct their own emergency response. The exemption is valid provided that the facility is included in the community emergency response plan and that there is an appropriate mechanism in place to notify emergency respond
ers when there is a need for a response. Franzia Tulare satisfies these requirements. A business plan has been submitted to Tulare County, which contains the required elements discussed above, and emergency response has been coordinated with the local fire department.
9.0 Planned Changes to Improve Safety
Chemical safety is an important part of Franzia Tulare operations. The Health and Safety Committee as well as regulatory requirements have minimized chemical exposure risks to employees and the public through ongoing internal risk reduction efforts. For example, as a result of the process hazard analysis (PHA), vehicle barriers will be installed around the ammonia processes, equipment will be replaced, and procedures have been documented.
Other improvements will be made when identified and approved by management.