Southern Gardens Citrus Processing Corporation - Executive Summary |
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RMP EXECUTIVE SUMMARY A. Accidental Release Prevention and Emergency Response Southern Gardens Citrus Processing Corporation (the Company) recognizes management's responsibility in protecting its employees, equipment, property, and the environment. The safety and health of all personnel are very important. The control of accidents has been and will continue to be a basic responsibility of all personnel in the facility. To accomplish the Company's goal in controlling accidental losses, the facility has developed a Plant Safety Program based on the Voluntary Protection Program guidelines. The mission of the plant Safety Program is to provide a safe work environment through involvement, commitment, and genuine caring by all employees. Efficiency and safety performance is measured by closely tracking Lost Work Day Index and Injury Illness Rates. One of the activities associated with the Plant Safety Program has been the development and implementation of accidental release prevent ion and emergency response programs which are designed to comply with OSHA's Process Safety Management (PSM) standard and EPA's Risk Management Program regulation. The Utilities Team Leader is responsible for the management of accidental release prevention and the Safety Resource is responsible for management of the Emergency Response Programs. The purpose of the accidental release prevention and emergency response programs is to prevent the occurrence and minimize the consequences, of significant releases of toxic substances as well as fires, explosions and other types of catastrophic events. Overall, these programs prevent accidental fatalities, injuries and illnesses and avoid physical property damage. B. Stationary Source and Regulated Substance Handled The Company operates a fruit juice processing facility at this location. The facility operates an ammonia refrigeration system to provide cooling and freezing capabilities. The amount of anhydrous ammonia (CAS #7662-41-) cont ained in the system is in excess of 10,000 pounds and the maximum inventory is 50,000 pounds. Since an ammonia release from this system could pose a risk of offsite public impact and since the system is regulated under the OSHA PSM standard, this facility is subject to the Program 3 requirements of the EPA's Risk Management Program. In the ammonia refrigeration system, ammonia is transformed from vapor to liquid then back to vapor by mechanical compression, expansion, and evaporation in order to exchange heat to acheive a desired temperature in the storage and processing areas. The high pressure ammonia vapor flows from the compressors to the condensers where heat is removed, turning the vapor into a liquid. The liquid from the condensers is collected in a high-pressure receiver. The liquid ammonia is then circulated to the units (freezers, air units, storage tanks, and chillers) located in the production and storage areas. The ammonia liquid flows across heat exchanger surface s (coils, tubes, or freezer barrels) where it picks up heat, changing from a liquid to a vapor. The ammonia vapor is then sent back to the compressor to start the cycle over. C. Summary of Worst-Case and Alternative Release Scenarios The worst-case release scenario at the facility involves release of 22,600 pounds of ammonia over a 10-minute period due to failure and loss of entire contents of one HPR. Under worst-case weather conditions, ammonia could travel 1.6 miles before dispersing enough to no longer pose a hazard to the public or environment (i.e. reaching a concentration less than 0.14 mg/L) according to the Ammonia Guidance method. The worst-case release scenario is unlikely for the following reasons: 7 The worst-case weather conditions that were used for this scenario do not occur every day; 7 Industry standards were followed for the manufacture and quality control of the receivers; 7 Ammonia is not corrosive in this service and the vessels are relatively new; 7 Pressur e safety valves limit operating pressures in the receivers; 7 The facility has a preventative maintenance program in place to maintain the ongoing integrity of the vessels; 7 The facility has a training program designed to ensure that the system is operated by qualified personnel; and 7 The facility emergency response procedures, which enable trained personnel to respond quickly to isolate any potential releases. The alternative release scenario at the facility involves the release of 2,770 pounds of ammonia over a 10-minute period due to the rupture of a 1.5-inch liquid fill line during delivery. Under alternative release weather conditions, ammonia could travel 0.2 miles before dispersing enough to no longer pose a hazard to the public in accordance with the Ammonia Guidance. The alternative release scenario is unlikely for the following reasons: 7 The facility has a Standard Operating Procedure (SOP) for offloading of ammonia to the high pressure receiver; 7 An automatic pressur e cutoff system would minimize the release; 7 The facility has a training program designed to ensure that the system is operated by qualified personnel; 7 The facility emergency response procedures, which enable trained personnel to respond quickly to isolate any potential releases; and 7 Ammonia is not corrosive in this service. D. Description of the Accidental Release Prevention Program The facility exceeds the ammonia threshold quantity for the OSHA PSM Standard 1910.119, and is therefore subject to the PSM requirements. For RMP compliance purposes, this places the refrigeration process at SGCPC in the Program 3 level. Therefore, SGCPC will use its PSM program as the required Program 3 Prevention Program. The prevention program consists of the following elements: 7 Employee Participation: This program involves the employees in establishing and implementing the program. Employees are also involved when a process hazard analysis (PHA) is conducted. The program also ensures th at all employees have access to the program. 7 Process Safety Information: Written information has been collected which enables the employees to identify and understand the potential hazards of the system. The written information includes the ammonia Material Safety Data Sheet and a description of the design of the ammonia refrigeration system. 7 Process Hazard Analysis: Qualified plant personnel have conducted studies, using the What-If Technique, to look at the system and identify potential hazards. 7 Operating Procedures: Written, detailed procedures have been developed to describe the steps that should be followed to safely operate the ammonia refrigeration process. 7 Training: A training program has been developed which ensures that employees are trained on all aspects of the systems and on the duties that they should perform to ensure the safe operation of the ammonia refrigeration system. 7 Contractors: All contractors are evaluated before they perform work on or near the ammonia refrigeration system. The contractors are also periodically evaluated to ensure safe work practices are followed. 7 Pre-Startup Safety Review: A pre-startup safety review is completed for all new ammonia projects to verify that all safety programs are in place, training has been conducted, and construction has been completed according to design standards before the project is put into use. 7 Mechanical Integrity: This program ensures that the ammonia refrigeration system is built and maintained using preventative maintenance procedures to minimize unexpected breakdowns or failures. 7 Hot Work Permit: Procedures ensure that a signed permit is obtained prior to any cutting, welding, or burning. 7 Management of Change; The procedures are designed to ensure that all changes made to the ammonia refrigeration system are properly reviewed. 7 Incident Investigation: The procedures ensure that any accidents and near misses are investigated, reviewed, and documented using an invest igation team. 7 Compliance Audits: There are procedures to conduct regular audits of the program to ensure that the PSM program is in place and working properly. The most recent formal compliance audit was conducted in March 1999. E. Five-Year Accident History No ammonia-related incidents were identified for the facility in the previous five years that resulted in significant on-site or offsite consequences. F. Description of the Emergency Response Program An Emergency Response Plan has been implemented for the facility. This program contains procedures describing how the facility will respond to ammonia spills and other emergencies, including evacuation procedures. The program has been coordinated with local Fire Departments. In addition, an emergency response consultant, Southwest Florida Safety Consultants, conducts biweekly HAZMAT drills on site. This training is available to all employees. The Emergency Response Plan consists of the following elements: 7 Organization Plan and Responsibilities 7 Communications Systems 7 Implementation of the Emergency Response Plan 7 Control Measures for Fire, Spills, Releases to Air, and Natural Disasters 7 Evacuation Plan 7 Description of Arrangements with Local Authorities and Responders 7 Decontamination Procedures 7 Emergency Power Supply System 7 Description of Available Safety Equipment FN: g:\common\scott\exec2.doc |