Fresh Express, Incorporated - Executive Summary

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Accidental Release Prevention and Emergency Response Policies 
The management of Fresh Express is committed to maintaining a safe work environment.  A Safety and Risk Manager has been assigned to ensure that safe practices are followed in the specification and operation of systems involving hazardous chemicals. This site has developed and trained an Ammonia Emergency Response Team to ensure rapid and appropriate response to ammonia emergencies.  The site has specific and written evacuation, reporting, and response procedures in place to protect Fresh Express employees, the public, and the environment in the event of an ammonia release.  
 
Stationary Source and Regulated Substance 
The Fresh Express plant covered by this RMP is located at 900 E. Blanco Road in Salinas, California.  The facility receives lettuce and other produce to be processed, packaged for consumer use in various salad mixes, set for short-term storage, and transported and distributed from this site.  The regulated subst 
ance is anhydrous ammonia.  One fixed ammonia refrigeration system is used for refrigerating produce at various temperatures. The total charge to this refrigeration system is 20,000 pounds of anhydrous ammonia.  A transportable (skid mounted) ammonia refrigeration system is often located on the site, but is not interconnected to the fixed system and is not considered part of the "process" for this RMP. 
 
Release Scenarios 
The worst-case release scenario considered for this process is a release of the entire ammonia system charge (20,000 lbs) from the High Pressure Receiver.  No administrative controls and mitigation measures were considered to limit the off-site consequence distance for this scenario.  The estimated distance to the toxic endpoint for the worst-case scenario is 1.7 miles.  The alternative release scenario considered for this process is a release of ammonia from a ruptured liquid line caused by thermal expansion due to double blocking of the line .  The largest-volume out 
door liquid line was assumed, and the entire length of this 2-inch nominal inside diameter line between blocking valves was included (394 feet).  No administrative controls or mitigation measures were considered to limit the off-site consequence distance for this scenario even though line lockout/tagout (an administrative control) exists.  The estimated distance to the toxic endpoint for the alternative release scenario is 0.1 miles. 
 
Accidental Release Prevention Program and Chemical-Specific Prevention Steps 
Prevention of accidental ammonia releases at Fresh Express is accomplished through sound industry practice in the original ammonia refrigeration system design and construction, the specification and review of system modifications, and the day-to-day operation and maintenance of the system.  This includes: 
 
7 compliance with industry standards and codes in effect at the time of initial construction and modification; 
7 performance of a thorough Process Hazard Analyses (PHAs) at lea 
st once every five years using accurate Process Safety Information;  
7 implementation of Operating Procedures which have been reviewed by PHA;  
7 appropriate initial and refresher training of system operations and maintenance personnel;   
7 performance of preventive and corrective maintenance according to system component manufacturer recommendations and pursuant to sitewide hazardous energy lockout and hot work permit programs; 
7 application of established auditing, inspection, and pre-start-up review protocols; and 
7 use of qualified contractors for work on the system. 
 
The detailed Ammonia System Release Prevention Program is contained in a supporting document (current revision is Rev 0, June, 1999), which is maintained at the site's Safety and Risk Management Office.   
 
Five Year Accident History 
Between June 21, 1994 and present, no ammonia releases resulted in onsite or off-ste injuries, deaths, or property damage, or off-site environmental damage, evacuations, or sheltering in p 
lace.  
 
Emergency Response Program 
Fresh Express has developed an Emergency Planning and Response document to ensure adequate preparedness with rapid and appropriate response to ammonia release emergencies.  The plan (current document Rev 0 dated June, 1999) is maintained at the site's Safety and Risk Management Office.  The document describes outside agency notification procedures in the event an ammonia release, provides detailed evacuation procedures, and includes response procedures for the mitigation of ammonia releases.  
The site has an Ammonia Emergency Response Team trained to use the Incident Command System organizational framework.  This is also described in detail in the planning document. 
 
Planned Changes to Improve Safety 
Based on the studies conducted during preparation of this RMP, the following adjustments are planned to ensure continued safe operations: 
( Ensure adequate evacuation procedures and drills for all areas. 
( Consider a flex connection on PRV threaded fittin 
g to protect against compromise during seismic event. 
( Install bollards or K-rails to protect against truck traffic near high-pressure receiver vessel and piping outdoors. 
( Consider policy and training for employees prohibiting stacking of combustible materials near propane tank. 
( Review engineering drawings and work orders to confirm that check valves were modified to allow bleed of trapped liquid and pressure. 
( Add a discharge valve closure confirmation step to the pumper maintenance procedure. 
( Walk down system piping to confirm all locations of dual blockage and ensure each has a bleed mechanism in place or Lock out Procedures are followed.  
( Update P&ID to accurately depict manual diffusion line "take off". 
( Develop procedure and disciplinary policy to eliminate storage in the fenced area. 
( Develop qualification process and employee training for oil draining procedure. 
( Examine accountability of fork truck drivers for incidents and accidents. 
( Review evaporator isolation 
procedure to ensure appropriate lockout and confirm unlock after isolation to avoid double blocked liquid line. 
( Confirm all evaporators in areas with stacking or fork truck traffic have adequate guards. 
( Update daily inspection list to include oil drain rate . 
( Develop written procedure for purging non-condensables from the system.  
( Walk down system to identify all locations of dual blockage potential for proper tagout when isolation is done during shutdown and tag removal when complete.
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