the Giumarra Companies - Executive Summary |
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1. THE GIUMARRA BROS. FRUIT CO., REEDLEY FACILITY, RISK & PROCESS SAFETY MANAGEMENT PROGRAM This is to inform all interested persons, including employees The Giumarra Co. is preparing a unified Risk & Process Safety Management Program to comply with California's Accidental Release Prevention (CalARP) Program (in California CCR Title 19, Chapter 4.5, Program Level 3 Elements, and Federally Title 40 CFR Part 68) and California OSHA's "Process Safety Management (PSM) of Acutely Hazardous Materials" standard (in California CCR Title 8, Section 5189, "Process Safety Management of Acutely Hazardous Materials" and Federally Title 29 Code of Federal Regulations (CFR) 1910.119). This program is being prepared to address the risks involved with the presence of anhydrous ammonia in an amount in excess of 10,000 lbs which is contained in our refrigeration system. Our program will promote overall plant, worker, and public safety. The program will enable our facility to prevent the occurrence, and minimize the consequences, of significant releases of anhydrous ammonia. Overall, the program is designed to prevent accidental fatalities, injuries and illnesses and avoid physical property damage. Our company has an exemplary safety record, one that we are quite proud of. Our program incorporates and brings together several existing safety programs which already set forth rules, procedures and practices which help our employees protect themselves and our neighbors. 2. DESCRIPTION OF AMMONIA SYSTEM We operate a Commercial Cold Storage of deciduous tree fruit - apricots, nectarines, peaches, plums, grapes, persimmons and kiwi fruit. We store all of our packed product in cold storage. Our facility has an ammonia system that provides refrigeration capacity to multiple cold rooms, some equipped with blast tunnels for cooling fruit. Each cold room is equipped with "bunker style" evaporator coils that contain chilled liquid ammonia. High pressure liquid from our main receiver is piped to each cold room, where it passes through a liquid feed valve to the low pressure refrigerated area. Low temperature and pressure gas from the coils is returned to our engine room, where it passes through a compressor. The high pressure discharge from the compressor is sent to a evaporative heat exchanger where the high pressure gas ammonia is liquified and returned to our receiver. The ammonia system at our facility consists of vessels which are interconnected, or which are co-located such that a release of ammonia could impact the ability to operate vessels which are not directly connected. Therefore, we are treating our facility as a single process. 3. AMMONIA RELEASE SCENARIOS 3.1 Worst Case Scenario Our worst case scenario is the failure of our high pressure receiver containing 58,000 lbs of ammonia. If this were to happen the release would be passively mitigated by the fact that the primary receiver vessel is inside our engine room. The engine room has approximate dimensions of 30'h x 40'l x 50'w for a room volume of 60,000 ft3. There is an emergency fan, but no other active ventilation. By following the instructions contained in Chapter 4 of EPA's "Risk Management Program Guidance for Ammonia Refrigeration (40 CFR Part 68) we estimated the mitigated release rate at 1,833 lbs/min. Over a ten minute period 18,330 lbs would be released. From the distance to endpoint tables in the EPA guidance document we estimate that the ammonia would travel 2.6 miles (rural conditions) before dispersing enough to no longer pose a hazard to the public. In our opinion, it is extremely unlikely that the worst-case scenario will ever take place. Our receiver meets industry standards for manufacture and quality control of pressure vessels; ammonia is not corrosive in this service; pressure safety relief valves limit the operating pressure in this vessel; and our operator is trained in the safe operation of our system. 3.2 Alternative Case Scenario Our alterna tive release scenario is as follows. A high pressure safety relief valve lifts and fails to reseat. The rated release rate for our high pressure safety relief valve is 70 lbs/min. We assume the leak would continue for 10 minutes until the header pipe was switched over to the backup safety relieve valve. Following industry practice, our relief valves are installed in pairs with a switch over valve, and the discharge is piped to a release point that is remote from the valve. Under this scenario 700 lbs of ammonia would be released over a time period of 10 minutes. Using RMP*Comp we estimate that the ammonia would travel 0.2 miles (rural conditions) before dispersing enough to no longer pose a hazard to the public. 4. GENERAL ACCIDENT RELEASE & AMMONIA SPECIFIC PREVENTION STEPS The ammonia refrigeration system at the Giumarra Co. is an integral part of the overall business. It has a system charge of approximately 58,000 lbs. It is extremely important that it is maintained and opera ted in a safe and efficient manner. Management is committed to making sure that all employees are made aware of the potential danger of an ammonia leak. The ammonia refrigeration system/process is constantly being monitored by our refrigeration engineer. In addition, the system/process is checked frequently by our outside refrigeration contractor, California Controlled Atmosphere, who also performs an annual pre-season preventative maintenance review of our system/process equipment. The system/process is controlled by a computer which monitors many process variables, and allows remote control. In the event of a system upset the computer actuates a dialing program that alerts key personnel and responders. We have ammonia detectors which also trigger alerts. The detectors are inspected weekly and serviced annually. Our evaporator coils are also equipped with water defrost, which can be used to absorb released ammonia. Water containing ammonia would be held in an onsite holding pond. We inform our employees of the dangers of an accidental release of ammonia through monthly safety meetings. During these meetings we also discuss the preventative measures to take, such as evacuation, in order to not be affected by a release. Our ammonia refrigeration system was designed and built by professional refrigeration engineers in accordance with ANSI/IIAR 2-1992 "Standard for Equipment, Design, and Installation of Ammonia Mechanical Refrigerating Systems." It was also built in compliance with the Uniform Building Code and Uniform Mechanical Code applicable at the time of construction. Our ammonia refrigeration system is equipped with safety relief valves. These valves limit the operating pressures of the entire system, and prevent failures due to overpressurization. 5. FIVE YEAR ACCIDENT HISTORY The Giumarra Co. facility at Reedley has not had any reportable accidents within the last five years. 6. EMERGENCY ACTION PLAN This facility's emergency response program is based on the Cal OSHA requirements for Emergency Action Plans (in California CCR Title 8, Section 3220, "Emergency Action Plans" and Federally Title 29 CFR 1910.38 and 1910.119) and HAZWOPER (standard (in California CCR Title 8, Section 5192, "Hazardous Waste Operations and Emergency Response" and Federally Title 29 CFR 1910.120). Strategically, we will respond Defensively to a release. Our engineer has received Defensive Training (First Responder, Operations Level) specific for ammonia response and meeting HAZWOPER criteria. Under this plan our employees will take whatever steps are necessary to bring a release under control. Initial training to the defensive level (First Responder, Operations Level) as defined in the HAZWOPER regulations will take place before the end of the year. The first priority will be to operate the ammonia system to bring a release under control safely, from a distance, without donning personal protective equipment. Steps might include stopping the fl ow of ammonia to a leak point, or using the compressor to suck ammonia away from a leak point. Further response requiring the donning of personal protective equipment would be done in coordination an outside agency. All response activities would be coordinated with the local fire department and the Visalia Fire Department Hazardous Materials Response Team. Every year at the beginning of the season we review with our employees our evacuation procedures in the event of an emergency, including an ammonia release. We have two (2) windsocks at our facility that employees can use to determine the "upwind" side of any point of release. 7. PLANNED CHANGES TO IMPROVE SAFETY As of June 21, 1999, the time that this Executive Summary is being submitted, our Risk & Process Safety Management Plan is not complete. The reason is that in order to do it right a lot of work must be done. We simply do not have enough qualified employees or resources to meet the initial deadline. Our company operat es seasonally and we have found that our ability to allocate managerial and operator resources to prepare this plan depends upon our workload. In addition, we have found it necessary to obtain help from outside vendors for some critical elements, such as preparing Piping & Instrumentation Diagrams and conducting a Process Hazard Analysis. These vendors are attempting to meet the requests of numerous facilities such as ours at the same time, and have the same problem of only a limited number of people qualified to carry out the required tasks. Thus, these vendors are setting completion dates for plan elements that we cannot entirely control. However, we have prepared the following milestones and allotted times for the completion of our plan: Milestone Allotted Time * Conduct Offsite Consequence Analysis - Done * Prepare RMP*Submit showing status as of 6/21/99 -Done * Collect Process Safety Information - Done * Conduct Process Hazard Analysis - On or around Oct 1, 1999 * Finish PHA documentation including Action List 30 days - By Nov 1, 1999 * Prepare Process Prevention Program elements - Done * Prepare Standard Operating Procedures - Done * Compile all elements into Risk & Process Safety * Management Program, review internally, and submit 180 days - By Jan 1, 1999 We understand our obligations to consolidate our safety activities in a Risk Management Program under the CalARP regulation. We are committed to preparing and implementing a Risk & Process Safety Management Program according to the above milestone and timeline chart. |