Tropicana Products Sales, Inc. - Executive Summary |
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Tropicana Products, Inc., City of Industry (Tropicana) maintains a strong commitment to protecting both the worker and the surrounding community from any type of hazardous incident that could potentially occur at its facility. For this purpose Tropicana has developed facility procedures that apply to both daily operations and emergency response situations, in the form of a Risk Management Program, developed and implemented specifically for the City of Industry facility. The facility risk management program has been developed in accordance with both federal (EPA's Risk Management Program, 40 CFR 68) and state (California's Accidental Release Program, Title 19 CCR, Div.2, Ch. 4.5) requirements. Tropicana has also submitted an in-depth description of the facility risk management program to the HAZMAT Unit of Los Angeles Fire Department (LEPC) , to ensure proper coordination of the facility program with the local emergency planning commission. Tropicana Products, Inc. is a beverage pac kaging and distribution facility located in City of Industry, Los Angeles County, California. The facility is situated on, approximately, 15 acres of property located between Orange Avenue and Sunset Avenue. All utilities are provided by municipal sources, including water, sewer, electric, firefighting and police services. The entire site consists of office space, production areas and storage areas (dry and cold), serving as a distribution center for Tropicana products throughout the West Coast region, employing a total staff of approximately 115 employees. The plant was originally built in 1984 (under different ownership), with modifications completed in 1992. Tropicana's chilled juices require constant refrigeration to maintain their high quality and freshness. Refrigeration at the facility is provided by an anhydrous ammonia system. Ammonia, a regulated substance, is used instead of other refrigerants because ammonia has several advantages over the available alternatives. A mmonia is a very energy efficient refrigerant, does not cause damage to the ozone, and is one of the most widely used industrial chemicals. An Off-site Consequence Analysis (OCA) was completed for the facility evaluating potential impacts to surrounding areas from both a worst-case ammonia release scenario and an alternative release scenario. The worst-case release scenario looked at a possible failure of a storage vessel in the refrigeration system, resulting in a discharge of ammonia gas equal to the volume stored in the vessel. Tropicana believes, however, that this event is highly unlikely, based upon the safety procedures and management programs that are in place. Assuming the contents of the vessel is released over a period of 10 minutes, a mathematical model, DEGADIS (Dense Gas Dispersion Model) was used to determine the distance from the facility that would be impacted above an EPA specified concentration of ammonia (200 ppm). DEGADIS was selected based on its ability to model atmospheric dispersion of ground level dense gas releases of zero (initial) momentum into the atmosphere over flat, level terrain. Considering that ammonia is stored in the receiver under pressure and at ambient temperature, and that EPA's OCA Guidance states that a gas stored as a liquid under pressure should be treated as a gas, the worst-case release was modeled as a gaseous ground level release. Public receptors, including schools, residences, and commercial/industrial complexes were identified within this area. No environmental receptors were determined to be in this area of impact. An alternative release scenario was also evaluated to identify an area of impact that would result from an unforeseen set of circumstances that could cause a deviation from normal operating limits (conditions). This scenario entailed the malfunction of an evaporative condenser causing the over-pressurization of a gas compressor discharge line. A > inch pressure relief valve opens, releas ing ammonia in a gaseous state, at an elevation of 30 feet above ground (vent location). The SLAB model, approved by EPA for purposes of modeling dense gas releases, was used to determine the potential area of impact. Residences and commercial/industrial complexes (no environmental receptors) were identified in the impact area defined by the alternative release scenario. Although the probability of a significant release of ammonia from the facility is very low, results of the described models provide an excellent planning tool in identifying realistic risk factors. Consequently, Tropicana stresses the importance of both accident prevention and emergency response programs, relative to any risk posed by the use of ammonia at the facility. Tropicana complies with CalOSHA's Process Safety Management (PSM) standards (Title 8 CCR Section 5189), incorporating technology, procedures, and management practices into a comprehensive program that effectively minimizes the potential for haza rdous chemical releases. In addition to mitigation systems (automatic shut-off valves, high pressure relief valves, level alarms, barricades, monitoring/detection systems) engineered into the refrigeration system, Tropicana promotes safety in the operation of the ammonia system, by the following PSM program elements: 1. Involving employees in various aspects of program development and implementation; 2. Maintenance of updated process information, accessible to all employees; 3. Completion of a process hazard analysis (PHA) that identifies any hazards associated with deviation from normal operating conditions; 4. Development and implementation of standard operating procedures (SOPs); 5. Use of safe work practices in all aspects of process operation; 6. Personnel training; 7. Contractor safety program; 8. Pre-startup safety reviews prior to introduction of ammonia into the system; 9. Comprehensive inspection and maintenance program; 10. In-depth reviews of any significant changes in th e ammonia system; 11. Investigation of any accidents or "near misses," identifying any modifications that could prevent similar incidents in the future; 12. Internal audits, identifying any areas of program noncompliance and corrective actions required. There have been no accidents in the last five years, or in the history of the Tropicana, City of Industry facility, from the ammonia refrigeration system that have resulted in deaths, injuries, or significant property damage on-site; or, off-site deaths, injuries, evacuation, sheltering in place, property damage, or environmental damage. The Tropicana on-site emergency response program entails the organization of a trained emergency response team, capable of implementing established response procedures. These procedures include response as a stand-alone response unit (on-site personnel only), or in conjunction with off-site authorities. The facility utilizes the Incident Command System for all response activities, as outlined in the current facility Emergency Response Plan. On-site capabilities include responses to small (incipient) fires and non-consequential ammonia releases, such as normal operating losses and small, non-impacting sudden occurrences. Tropicana is in the process of developing an Integrated Contingency Plan (ICP), detailing the facility's emergency response capabilities, in a format the follows EPA's (as NRT's chair) Integrated Contingency Plan Guidance. The ICP provides a single plan that insures emergency preparedness through logistical planning and coordination between facility personnel and local emergency response personnel. The ICP provides basic facility information; contains essential response organization and procedures; and, provides site specific supporting information such as drawings, detailed procedures, and incident history. All aspects of Tropicana's emergency response planning are developed in coordination with appropriate state and local agencies responsible for eme rgency response management. Tropicana has made arrangements for coordination of emergency response activities with these agencies, as well as additional service organizations such as hospitals, health clinics, and pre-approved contractors. Tropicana's on-site Emergency Response (HAZMAT) Team, comprised of approximately 15 members, represents expertise in environmental operations, security, safety, and refrigeration. All working shifts have representatives on the emergency response team, to facilitate on-site response to any incident 24 hours per day, 7 days per week. Most members also carry pagers for immediate notification. All emergency response team members are trained in emergency response, capable of responding aggressively to a release of a hazardous material, while donning full protective gear (i.e., SCBAs). All team members complete an 8 hour annual refresher course and have a complete working knowledge of the current facility emergency response plan. Tropicana was awar ded Star status, in accordance with CalOSHA's Voluntary Protection Program in 1996. Star status is only given to those facilities that consistently demonstrate excellence in safety and exceed regulatory requirements for maintaining a safe operation. As a result of this status, Tropicana continually strives to maintain the highest quality safety program possible. This includes evaluations of existing programs relative to any changes in facility operations, as well as recommendations that arise from incidents, such as injuries or near misses. Tropicana has developed a safety issue tracking report to ensure any safety issues identified as a result of daily operations, or scheduled inspection/walkthroughs, are properly addressed and resolved in a timely manner. The report describes the corrective action required; lists the person responsible for completing the corrective action; identifies the source of the issue (walkthrough, inspection, safety meeting, etc.); and provides the actua l or expected date of completion. Tropicana has, and will continue to be, an industry leader in assuring the proper and safe operation of its ammonia refrigeration system. This leadership is exemplified by Tropicana employees at all organizational levels and is the basis for the company's commitment to maintaining a comprehensive risk management program, minimizing the potential for accidental releases. |