CARGILL CITRO-LABELLE CITRUS PROCESSING PLANT - Executive Summary
CARGILL CITRO AMERICA, INC.- LABELLE FACILITY |
RISK MANAGEMENT PLAN
1. Corporate Prevention and Emergency Response Approach
The Cargill Citro- America, Inc. (Cargill Citro) Labelle Facility is located at 3645 State Road, Hwy. 80 West, Alva, Florida. Cargill Citro leases this facility from Jack M. Berry Inc., but Cargill is submitting the RMP and is responsible for the maintaining of the ammonia refrigeration process and all other citrus operations onsite, and thus is the responsible party for RMP purposes. Cargill requires each facility to develop and maintain accident prevention programs and an emergency response plan appropriate to the site. Each site is also responsible for regulatory compliance issues that apply to the site. Cargill's corporate and division environmental and safety personnel provide advise and assistance in regulatory compliance matters for individual plant sites.
2. Description of Stationary Source
The Cargill Citro Labelle facility is
located in the center of the city of Alva, Florida. The facility consists of juice manufactruing process, as well as areas for dry, frozen, and cooler storage of oranges and orange products.
The Cargill Citro Labelle facility has two separate ammonia refrigeration systems which exceed the 10,000 lb. RMP threshold quantity. The high pressure receiver (HPR) or storage vessel for Ammonia Refrigeration System 1 is located outside the main engine room. This HPR is the largest capacity vessel in both ammonia refrigeration systems capable of holding 9,221.5 lbs. of ammonia. The HPR for the Ammonia Refrigeration System 3 is the largest capacity vessel in that process, capable of holding 7,109.2 lbs. of ammonia.
3. Description of the Worst Case and Alternative Release Scenarios
The Worst Case release scenario is the rupture of the Ammonia Refrigeration System 1 HPR vessel, releasing 9,221.5 lbs. of ammonia gas over a ten minute period. Under worst case weather conditions, the ammoni
a gas could travel 1.7 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.
Since there are two separate ammonia refrigeration systems at the Cargil Citro Labelle facility, two alternative release scenarios are required to be reported. The Ammonia Refrigeration System 1 alternative-case release scenario is characterized by a release rate of 2,037 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, the ammonia gas could travel 0.80 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.
The Ammonia Refrigeration System 3 alternative-case release scenario is characterized by a release rate of 1,146.0 lb./min. from the HPR liquid supply line due to pipe connecti
on failure from worker/human error or corrosion of the pipe. Under normally expected weather conditions, taking into consideration the passive mitigation of the enclosure, the ammonia gas could travel 0.60 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.
4. Prevention Program
This facility exceeds the ammonia threshold quantity in both ammonia refrigeration systems for the OSHA Process Safety Management (PSM) Standard, 1910.119, and is therefore subject to the PSM requirements. For RMP compliance purposes, this places both of the Cargill-Citro refrigeration processes in the Program 3 level. The Cargill-Citro facility will use its PSM program as the required Program 3 Prevention Program.
The Cargill Citro facility has a program in place to comply with the OSHA Process Safety Management Standard, 29 CFR 1910.119. The PSM Program was established in 1995 for the Ammonia R
efrigeration System 1 and 1996 for the Ammonia Refrigeration System 3. 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 developing the PSM Program, the Cargill Citro 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 have been used to train all operators and mechanics who 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, also to ensure that all non-routine work can be performed sa
fely. Other components of the prevention program include collection and review of all equipment information, the maintaining of current 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 information will be available when needed. The Cargill Citro staff also performed a PHA of each process. 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 receives full support of plant management and involvement of employees at all levels.
5. Accident History
The Cargill Citro facility has had no accidental releases of ammonia in the past five years.
6. Emergency Response Program
The Cargill Citro Labelle Facility has an Emergency
Response Program in place. The program complies with 29 CFR 1910.38. The site also has some internal emergency response capabilities that complies with paragraph (q) of 29 CFR 1910.120. The current plan has been coordinated with the Labelle Fire Department and Hazardous Materials Response Team, and the District #9 Local Emergency Planning Committee. Notification is made locally by dialing 911, and by notifying Florida State Warning Point at (800) 320-0519.