Wm. Bolthouse Farms, Inc. - Executive Summary |
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Risk & Process Safety Management Program Executive Summary for Wm. Bolthouse Farms, Inc. 7200 East Brundage Lane Bakersfield, CA 93307-3099 (661) 366-7209 FAX (661) 366-8410 June 21, 1999 Prepared by: Solutions Environmental Health & Safety, Inc. 6687 N. Blackstone Avenue, Suite 103 Fresno, California 93710 (559) 435-4244 FAX (559) 435-8503 www.SEHS-Inc.com Table of Contents For Executive Summary 1. THE WM. BOLTHOUSE FARMS, INC. RISK & PROCESS SAFETY MANAGEMENT PROGRAM 1 2. DESCRIPTION OF AMMONIA SYSTEM 1 3. AMMONIA RELEASE SCENARIOS 2 3.1 WORST CASE SCENARIO 2 3.2 ALTERNATIVE CASE SCENARIO4. GENERAL ACCIDENT RELEASE & AMMONIA SPECIFIC PREVENTION STEPS 3 5. FIVE YEAR ACCIDENT HISTORY 3 6. EMERGENCY ACTION PLAN 3 7. PLANNED CHANGES TO IMPROVE SAFETY 4 1. THE WM. BOLTHOUSE FARMS, INC., RISK & PROCESS SAFETY MANAGEMENT PROGRAM This is to inform all interested persons, including employees, that Wm. Bolthouse Farms, Inc. has prepared a unified Risk & Process Safe ty 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 company has in place many policies and procedures to promote overall plant, worker and public safety. Since late 1996 our company has had a Process Safety Management program to comply with California OSHA's "Process Safety Management (PSM) of Acutely Hazardous Materials" standard (CCR Title 8, Section 5189). We have reviewed our PSM program and modified it to meet our obligations under CalARP. In so doing, we have: (1) prepared a unified program based on the PSM plan to meet CalARP obligations as well; (2) reorganized the program so that it meshes more closely with general Bolthouse business practices; and (3) reviewed plan documentation forms and responsibilities. The unified Risk & Process Safety Management Plan sets forth rules, procedures and practices which will help our employees protect themselves and our neighbors. 2. DESCRIPTION OF AMMONIA SYSTEM We operate a facility that prepares and packages carrots f or sale. Our facility utilizes four refrigeration systems to provide refrigeration for several cold/freezer rooms and process equipment: Main, North Shortcuts, Ice Maker system, and Pre-Processing Plant. All refrigeration systems operate in a similar manner. High pressure liquid ammonia is transferred from high pressure receivers to surge tanks, pump traps, or accumulator vessels via a liquid feed manifold. The liquid ammonia passes through an expansion valve as it enters the vessels, which lowers the temperature and pressure. Cold liquid ammonia is then pumped or fed by gravity into cooling devices such as evaporator coils, ice makers, or hydrocoolers. As the cooling device absorbs heat the liquid ammonia is vaporized. The low temperature ammonia vapor is transferred back to the starting vessel. From there the vapor is pulled to the compressors. Passage through the compressor raises the temperature and pressure of the ammonia vapor. Compressor discharge (hot gas) is sent t o the condensers. Water sprayed over the condenser coils removes heat from the high pressure ammonia vapor and condenses it to a high pressure liquid, which is returned to the high pressure receivers. The Main System includes several different processes that operate simultaneously: Cello Plant, South Shortcuts Plant, Bunch Plant, and Pre-Processing Plant. The North Shortcuts System is used to maintain a low temperature for the North Shortcuts carrot packaging building. The Ice Maker System uses the ammonia to make ice used for packaging carrots. The Pre-Processing Plant has three main purposes: To provide cooling for 1) hydrocooling, 2) cold storage, and 3) processing. The ammonia systems at our facility 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 one of four equally sized interconnected high pressure receivers in our Main System. Together, the vessels contain 32,000 lbs of ammonia. Following the instructions set forth in EPA's "Risk Management Program Guidance for Ammonia Refrigeration (40 CFR Part 68)" we considered the failure of one vessel without including any liquid ammonia in pipework connected to the vessel and in any other vessel that can discharge directly into pipework connected to the vessel. This would result in a release of 8,000 lbs of ammonia. The vessels are outside, and the release would not be passively mitigated. Using RMP*Comp the estimated distance that the ammonia would travel before dispersing enough to no longer pose a hazard to the public is 0.5 miles (urban conditions). A map showing the area that would be affected is attached. 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 p ressure vessels; ammonia is not corrosive in this service; pressure safety relief valves limit the operating pressure in this vessel; and our operators are trained in the safe operation of our system. 3.2 Alternative Case Scenario Our alternative 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 0.1 miles (urban conditions) before dispersing enough to no longer pose a hazard to the public. A map showing the area that wo uld be affected is attached. 4. GENERAL ACCIDENT RELEASE & AMMONIA SPECIFIC PREVENTION STEPS The ammonia refrigeration systems at the Wm. Bolthouse Farms, Inc. are an integral part of the overall business. Together, the systems contain a total charge of approximately 58,000 lbs. It is extremely important that it is maintained and operated 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 wit h 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 Wm. Bolthouse Farms, Inc. 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. 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 firs t 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 flow 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. Our engineer has received Defensive Training (First Responder, Operations Level) specific for ammonia response and meeting HAZWOPER criteria. Three more employees are currently receiving a total of 120 hours of instruction provided by the Refrigeration Engineers and Technicians Association (RETA). Fourty (40) hours of HAZWOPER training for Ammonia Offensive Responder (HAZWOPER Hazardous Materials Technician) are included in the training. The remainder of the training is in safe operation of the ammonia process. 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 a windsock at our facility that employees can use to determine the "upwind" side of any point of release. 7. PLANNED CHANGES TO IMPROVE SAFETY Our company has an exemplary safety record, one that we are quite proud of. Our company has in place many policies and procedures to promote overall plant, worker and public safety. Nevertheless, Wm. Bolthouse Farms, Inc., strives to constantly improve in all areas, of which safety is one. In 1996 our company prepared a Process Safety Management program to comply with California OSHA's "Process Safety Management (PSM) of Acutely Hazardous Materials" standard (CCR Title 8, Section 5189). New obligations under the California Accidental Release Program have caused us to review our PSM program and make changes to increase its effectiveness. One change has been to group the plan elements to align with Bolthouse business practices rather than the order presented in the law. Safe Operating Procedures are now grouped together for the benefit of our system operators. Safe Operating Policies are now grouped together so that they may be administered by appropriate office staff. The Emergency Action Plan is now separated out and distributed widely through the plant for easy reference. A second change has been to review plan documentation forms and responsibilities. Forms in the original PSM plan that are not being used are being discarded. Alternatively, forms that are being used at Bolthouse that meet plan documentation requirements, but which weren't acknowledged by the plan, are now included. A third change is that the Standard Operating Procedures have been rewritten for ease of use by operators. In addition, there is now a method for receiving operator feedback and making change s in the future. The last, but perhaps most fundamental change, is that the Risk & Process Safety Management Program is now thought of as a "living document". It is an interactive framework that guides safe action for Wm. Bolthouse Farms, Inc., employees. Through the Risk & Process Safety Management Program Wm. Bolthouse Farms, Inc., will continue to profit while maintaining overall plant, worker and public safety. |