Franzia Winery Sanger - Executive Summary |
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1.0 Introduction A Risk Management Program (RMP) has been implemented at Franzia Sanger for the reduction of accidental releases of hazardous materials. The RMP summarizes the management, administrative, procedural, and technological controls that work together to minimize the risk to the community of hazardous chemical releases. The Risk Management Plan is organized to correspond with specific U.S. Environmental Protection Agency (EPA) RMP definitions and requirements, including: 7 Introduction; 7 Franzia Sanger policies to protect health, environment, and safety; 7 Facility identification and regulated substances covered processes; 7 Hazard Assessment; 7 Prevention Program; 7 Five-Year Accident History; 7 Emergency Response Plan; and 7 Planned changes to improve safety. 2.0 Franzia Sanger Policies to Protect Health, Environment, and Safety Risk management and safety are important concerns at Franzia Sanger; this RMP formalizes and documents these activities. Franzia Sanger is com mitted to conducting its operations in a safe and responsible manner and to reducing risks to human health and to the environment. This commitment to health, the environment, and safety starts with upper management. The Plant Manager, Maintenance Manager, and Operations Supervisor are members of the Safety and Health Committee and routinely dedicate time each month to review health and safety matters. One maintenance and one production employee participate each month on the committee to ensure that these concerns are communicated throughout the facility. The maintenance and production personnel are rotated as members of the Safety and Health Committee. The Committee reviews safety performance, takes corrective action when appropriate, and strives for continuous improvement. Franzia's commitment to safety is demonstrated in the training programs for all employees, including seasonal employees. The training programs provide information on preventing accidents through knowledge of hazard s and safe work practices. 3.0 Facility Identification The Franzia Sanger facility is located at 2916 South Reed Avenue, Sanger, California. The facility produces grape juice, wine, and distilled spirits. The facility uses anhydrous ammonia for refrigeration and is regulated under 40 CFR Part 68, the EPA RMP Rule. The amount of ammonia present in one of the systems is approximately 22,000 pounds, which is above the minimum threshold quantity of 10,000 pounds. 4.0 Hazard Assessment - Worst Case Scenario (WCS) The worst-case accidental release scenario is a catastrophic failure of the 5,275 gallon anhydrous ammonia tank. The ammonia is maintained as a liquid via pressurization and is limited by an 80% engineering control, resulting in 22,000 pounds of ammonia. Hazard assessment modeling shows that, under the worst-case weather conditions and a 10-minute release period, the worst-case release could travel downwind until the toxic endpoint of 200 parts per million (ppm) is reached an d affect public receptors. It should be noted that the worst-case scenario is an extremely unlikely event. 5.0 Hazard Assessment - Alternative Release Scenario (ARS) An ARS was modeled for the ammonia substance in the hazard assessment. The ARS assumes that a hose is improperly connected and causes a release while loading the contents of a 200-pound ammonia cylinder to the receiver. The release is estimated to go offsite until the toxic endpoint of 200 ppm is reached. No public receptors are impacted in this scenario, which is a more credible release than the worst-case release scenario. 6.0 General Accidental Release Prevention Program A prevention program is in place to minimize the risk of hazardous chemical releases in accordance with the California Occupational Safety and Health Administration (CalOSHA) Process Safety Management (PSM) standard (Section 5189 of Title 8, CCR) and the EPA Risk Management Program. This prevention program covers those processes that handle sulfur dioxide and ammonia above the threshold quantity of either PSM or RMP rules. The prevention program provides a structured approach to preventing accidents. Some of the specific activities in the prevention program include: 7 Process safety information is provided to all employees upon hire and is accessible at all times. 7 In-depth process hazard analyses are completed every five years by qualified personnel using techniques approved under the PSM standard. 7 Written operating procedures (kept up to date) are used for training and guiding the work of operators. 7 Training is provided to all employees upon hire, and refresher training is given annually or upon request. 7 Contractor safety performance is evaluated prior to allowing contractor work at Franzia Sanger. The contractor safety standard is currently being updated. 7 Operators, mechanics, and contractor personnel are qualified, trained in the general hazards in the facility, and informed of any temporary situati ons affecting safety. 7 Pre-startup safety reviews are conducted to insure that conditions for safe operation have been satisfied prior to starting new or modified equipment. 7 A program is in place to maintain the mechanical integrity of the process, which includes written procedures, training requirements, equipment deficiency requests for employees, work orders, scheduled maintenance, and computerized documentation. 7 A hot work permit system assures that work is done safely and properly. 7 A management of change system is in place to ensure that changes are managed safely. 7 Incidents are investigated and actions are taken as part of a continuous improvement effort. 7 Routine audits are conducted to assure that safe practices are being followed. This systematic approach to process safety involves employees and strives for continuing improvements in overall safety. The training, qualifications, and safety awareness of our operations, maintenance, and management personne l are a key element in reducing and mitigating accidents. 7.0 Five-Year Accident History Since January 1994 to the present, there have been no accidents or releases of regulated substances from covered processes that meet specific EPA criteria for the Five-Year Accident History. Such "RMP accidents" would involve serious accidents with either on-site deaths, injuries, or significant damage; or known, off-site deaths, injuries, property damage, or environmental damage. Franzia Sanger realizes that the community may also be interested in smaller releases of regulated chemicals that do not meet such criteria. We have been diligent in reporting releases of hazardous materials and in internally investigating and correcting the causes of such releases. 8.0 Emergency Response Plan The federal RMP and CalARP regulations grant exemptions for the emergency response plan for facilities that do not conduct their own emergency response. The exemption is valid provided that the facility is inclu ded in the community emergency response plan and that there is an appropriate mechanism in place to notify emergency responders when there is a need for a response. Franiza Sanger satisfies these requirements. A Business Plan has been submitted to Fresno County, which contains the required elements discussed above, and emergency response has been coordinated with the local Fire Department. 9.0 Planned Changes to Improve Safety Chemical safety is an important part of Franzia Sanger operations. The Health and Safety Committee as well as regulatory requirements have minimized chemical exposure risks to employees and the public through ongoing internal risk reduction efforts. For example, as a result of the Process Hazard Analysis (PHA), vehicle barriers were installed around the ammonia processes. Other improvements will be made when identified and approved by Management. |