AGRIFROZEN FOODS - PLANT 8 - Executive Summary |
|
AGRIFROZEN FOODS, PLANT NO. 8 RISK MANAGEMENT PLAN EXECUTIVE SUMMARY Introduction AgriFrozen Foods is a cooperative owned, Willamette Valley Oregon based, vegetable processor with plants located in both Oregon and Washington. AgriFrozen Foods, Plant No. 8, located southeast of Woodburn, Oregon, repackages bulk frozen fresh vegetables from our processing facilities into institutional and retail sized containers for marketing. Anhydrous ammonia, used as a refrigerant in the cold storage rooms, is located at this facility and is an invaluable component in maintaining our vegetable quality. Agrifrozen Foods is aware that anhydrous ammonia requires certain safe handling precautions to prevent unnecessary human and environmental exposure reducing the threat to our employee's health as well as the health of our neighbors and the community. Regulatory Background OSHA's Process Safety Management (PSM) regulations are defined by OSHA 29 CFR 1910.119. EPA's Risk Management Program (RMP) is def ined in Section 112R of the Clean Water Act (40 CFR 68). These regulations establish the requirements of both the PSM and RMP programs for facilities that are either specifically designated by the rules or for facilities that possess certain chemicals in excess of threshold quantities. Ammonia is the chemical used at this facility in quantities that trigger the RMP requirements. The RMProgram further assigns various program levels to facilities with specific Standard Industry Codes (SIC's). Frozen vegetable processors are designated as Program level 3 facilities because they are identified as SIC 2037 industries. Under these regulations, facilities are required to develop a complex multi-element safety program for related systems and plant operations as well as, under the RMP rules, an analysis of the off-site consequences that could result from a catastrophic release. Major tasks defined in these regulations address the following areas: 1. Employee Participation 9. Process Hazard An alysis 2. Process Safety Information 10. Hot Work Permits 3. Mechanical Integrity 11. Employee Training 4. Contractor Safety 12. Emergency Response Plans 5. Operating Guidelines 13. Compliance Audits 6. Pre-start Up Safety Review 14. Risk Management Plan 7. Management of Change 15. Off-Site Consequence Analysis 8. Incident Investigation 16. Trade Secrets Facility Background Agripac Inc, a vegetable processing cooperative, started business in 1971 with the consolidation of two grower cooperatives known as the Blue Lake Packers and the Eugene Fruit Growers Association. Plant No. 8 was constructed, by Agripac, in 1992 on a portion of the AgriFrozen Foods, Plant 3 wastewater irrigation field. Plant 8 began production in November 1993 and has not changed significantly since construction. The Agripac Cooperative was recently sold and this plant became an AgriFrozen Foods facility in February 1999. Facility Siting and Human Factors AgriFrozen Foods Plant No. 8, occupies a single 387,00 squa re foot building located on 22.62 acres of property located in an industrial zone near the southeast city limits of Woodburn, Oregon. This facility is bordered by AgriFrozen Foods, Plant 3, property on the north, east, and south sides, and commercial and farm properties on the west side. Several factors, including facility siting and human factors, were considered during the preparation of the facility's Process Hazard Analyses and the Offsite Consequence reviews. Chemicals and Processes AgriFrozen Foods, Plant No. 8, uses anhydrous ammonia as the refrigerant to operate its refrigeration components and has approximately 30,050 total pounds of ammonia in the system. The system includes: a single engine room that houses compressors and controls, condensers, high and low pressure receivers, evaporators, located outside the building, a large cold storage room, and necessary interconnecting piping. Actual in stock quantities of ammonia may vary with process usage and restocking schedules. O ff-Site Consequence Analysis Qualified facilities must conduct multiple offsite consequence analyses (OCA's) and report, to the government and to the public, the potential consequences of the accidental release scenarios studied. A typical OCA consists of two elements; a worst-case release scenario and an alternate release scenario. The EPA has defined a worst-case release as the rapid release of the largest quantity of a regulated substance, from a single point, that could result in the greatest distance to an endpoint during weather conditions most apt to augment the plume distance. An alternate scenario is defined as a release that also reaches an endpoint offsite but is more likely to occur than the worst-case scenario. A chemical's endpoint is defined as the distance a chemical cloud could travel before dissipating to the point that serious injuries from short-term exposures should no longer occur. The distances to the various endpoints may be determined using sophisticated comput er models or from the more conservative lookup tables provided by the EPA. Scenarios for this facility were determined using the EPA's lookup tables and are likely to reach further than those provided by computer simulation. Worst-Case Scenario: While it is not believed that a release of the magnitude required by the RMProgram criteria would likely occur, AgriFrozen Foods Plant No. 8 has chosen to assume their worst case scenarios would be a rapid release of the entire contents of either of the Plant's refrigeration system. We have assumed this would result from the major breaching of the plant's high pressure receiver (HPR) such as might occur from mechanical impact and damage. Factors limiting the potential for this magnitude of a release include the location of the receiver away from normal traffic areas and safeguards such as operating guidelines, maintenance, policies, and procedures. Because the HPR is located inside the building, it has been shown that this would be a mitigating factor that would greatly reduce the distance an offsite plume of ammonia would travel. In accordance with the RMP rules, worst-case scenarios are based on a fixed set of weather factors that would accentuate the distance a chemical plume would travel. Based on historical weather data, actual weather conditions for this area would likely decrease the extent of the endpoint of this chemical from the reported table-top exercise. Alternate Scenario: The required release determined for the alternate, more likely to occur, scenario would involve a release of ammonia from one of the system's pressure relief valves, resulting in a significantly smaller release than the worst case, with the distance to the endpoint barely reaching any receptors off the facility's property. This release scenario, while never having occurred at this site, has occurred in similar facilities and was felt more likely to occur in the future than the worst-case. To make the release scenario reach off-site receptors, it was assumed that the relief valves in question would also be located on one of the high pressure receivers. In reality, based on documented incidents of this type, this release would most likely be contained on-site and/or not affect anything off-site. As part of the facility's maintenance guidelines, the plant has a valve maintenance program that would further decrease the likelihood of a significant release Accident Prevention & Emergency Response Policies The safety of our employees and our neighbors depends on the manner in which our employees handle our chemicals as well as our standard operating and maintenance guidelines and the safeguards we utilize at our facilities. AgriFrozen Foods practices and adheres to state and federal safety regulations including, confined space, lockout/tagout, hot work permits, safe chemical handling, and emergency response programs. Contractors are also required to adhere to these rules and regulations. All employees are informed of the chemical s used at the facilities and any risks that may be associated with those chemicals. Material Safety Data Sheets are available to every employee if there is any question as to the proper precautions that should be observed in the handling of the chemicals. Any AgriFrozen Foods employee that handles chemicals as part of their job function is further trained in the proper handling of those chemicals. Accesses to chemical storage areas are restricted to authorized facility employees, authorized management personnel, and authorized contractors. Emergency Response Program Each AgriFrozen Foods plant has written emergency response programs to provide guidelines for handling various types of emergencies including the release of a chemical such as anhydrous ammonia. In addition, certain fulltime employees are trained and equipped to respond to and mitigate chemical emergencies and releases. Each plant's emergency response plan prescribes the procedures to be followed by our employees during an emergency including evacuations and notifications of management, on-site response teams, and governmental agencies. In the case of a release of a toxic chemical that could reach off the facility's property, local emergency response agencies would be immediately notified of the release. Communications between the plant's Emergency Response Coordinator and the local emergency responders regarding such factors as the chemical released, extent of the release, and wind direction will determine the need for evacuation or shelter-in-place of our neighbors. Notifications and evacuations of neighbors will be conducted by the local emergency responders. 5-Year Accident History The RMProgram requires that all releases of a criteria chemical which occurred within the previous five years and caused any damages, injuries, or evacuation off-site, be reviewed. There have been no ammonia releases from this refrigeration system. If there were any releases, these incidents, regardless of how small, woul d be reviewed and steps taken to prevent the incident from reoccurring. Summary At AgriFrozen Foods, protecting the community and the environment are high priorities. AgriFrozen Foods accepts responsibility for maintaining and operating facilities that are an asset to the communities in which they are located. This responsibility includes taking reasonable steps toward protection against injuries or environmental contamination and damage. Equipment and procedures at all facilities are inspected continuously and environmental protection programs reviewed periodically to assure operation within established guidelines. AgriFrozen Foods capital improvement projects often include safety and pollution control equipment and operational techniques that are needed to operate in compliance with local, state, and federal regulations. In situations where regulations are lacking, AgriFrozen Foods plant managers are encouraged to set site objectives whenever there is a potential risk to safety or t he environment. These objectives may include the actions necessary to help prevent, reduce, abate, or control noise, air, or water pollution and to accomplish the goal of being an asset rather than a nuisance to the community. As future changes and improvements are made, the safety of our employees and neighbors will always be foremost on our minds. |