Seneca Foods Corporation - Executive Summary |
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Executive Summary: The Seneca Foods Corporation Buhl, Idaho facility processes (canned and frozen) seasonal vegetables along with being a labeling and distribution center. Main products are Asparagus, Sugar Snap Peas, and Sweet Corn. Ammonia is used in our product freezing and storing operations. The main operating system was upgraded in 1990 and charged with 55,000 lbs of ammonia. A separate smaller system contains 8,000 lbs of ammonia and is used to operate the 102,000 square foot frozen warehouse at a -10 degree temperature. It is the policy of the Seneca Foods Corporation to assure safe and healthful working conditions for every employee and to comply with the letter and spirit of applicable laws and regulations. The Company will provide adequate safeguards against health and safety hazards by providing a safe work environment, by job training and instruction on safe procedures, by making appropriate protective equipment available, and by the proper administration of safety programs and activities. All employees are expected to comply with safety and health rules and procedures and to take an active role in the safety and health program and activities. Our worst case release scenario involves the High Pressure Receiver on the Northside of the freezer operations building. This receiver will contain the largest quantity of ammonia on sight. The cause of the worst case release would be due to a vehicle losing control, going over the protective barricades, and hitting the High Pressure Receiver tank causing it to rupture and release ammonia. The amount of ammonia being released when the end of the vessel is removed is 25,000 lbs. The capacity of this tank is 25,000 lbs. Using the EPA's RMP Guidance for Ammonia Refrigeration Reference Tables or Equations, this release over a 10 minute period would release 2,500 lbs per minute resulting in an evacuation area of 1.9 miles surrounding the facility considering the urban setting. If the setting was strictly rural, the evacuation area could extend to 2.9 miles. The barricades protecting the High Pressure Receiver are being upgraded prior to the Corn Pack of 1999. The silage operation during corn pack presents the greatest frequency for having vehicles in the area of the High Pressure Receiver. They would also present the greatest probability of losing control due to equipment/brake failure or driver neglect. The barricades would be designed to withstand an impact with the silage truck, thus preventing the worst case scenario. The other cause of the worst case scenario could be an airplane crashing into the High Pressure Receiver area. The probability of a plane hitting is very remote. Our alternative release scenario involves the failure of a shaft seal. This release could be caused by manufacturer quality issues or maintenance neglect. This release would result in approximately 50 lbs of ammonia being released. Using the EPA's RMP Guidance for Ammonia Refrigeration Reference Tab les or Equations, this release over a 10 minute period would release 5 lbs per minute resulting in an evacuation area of .10 miles surrounding the facility considering the urban setting. If the setting was strictly rural, the evacuation area would be the same .10 miles. Being that our facility property is not strictly controlled, in terms of denying access to the public, even the small distance of .10 of a mile would be considered to have offsite impact. Our defined maintenance procedures requires review of shaft seals each maintenance session and replacement as needed. Prior to being installed seals are inspected for quality issues that could lead to failure . This release was selected due to the variables of manufacturer quality control and the human judgement error that could occur during maintenance activities. Other types of failures that could lead to a release were reviewed. These included a 4-bolt flange coming loose, a fisher valve failure, and a packing gland leak. Th e shaft seal failure was chosen due to having the possibility of the largest amount of ammonia released. The other types of failures would release a smaller amount of ammonia and would be easier to control. We have had no releases of ammonia in the last 5 years that required evacuation of our facility. We have had no onsite or offsite injuries due to an ammonia release. If a release occurred that required evacuation of our facility, the response efforts under our Emergency Action Plan are coordinated with the local Buhl City Fire Department, the Region IV MVERT (Magic Valley Emergency Response Team) and the Twin Falls County LEPC (Local Emergency Planning Commission). MVERT, based in Jerome, consists of approximately 60 Technicians of which 6 are members of the Buhl City Fire Department. The Buhl City Fire Department participates in an annual tour of our facility to understand the facility layout and associated hazards. To assure orderly evacuations of personnel, evacuation dril ls are conducted annually. Maintenance personnel in frozen operations receive training on SCBA's (Self Contained Breathing Apparatus) that can be used during routine maintenance activities to assure their safety. Operator training occurs at least every 3 years. Our formal training initiative began in 1992 with what was called Level III (24 hours) training, it was followed by Level II (24 hours) training in 1993, and then Level I (24 hours) operator training in 1994. In 1997, Gartner Refrigeration presented a 16 hour Ammonia Refrigeration Refresher Training Course. The operator training courses cover the various components of the refrigeration system, the physical factors that affect the refrigeration cycle, operation and maintenance, and safe operating procedures. The engine room operators also attend training classes put on by equipment manufacturers. The most recent being a Frick Compressor Operating Class instructed by Frick Compressor Training, Engineering, and Service personnel in December of 1997. The engine room operators have developed a 4 hour course to introduce other maintenance personnel, including electricians, to the operational aspects of the ammonia system. The operators have a defined 2 - 4 week training time frame for educating new operators on our system. Engineering safety designs are present in our ammonia system to control and minimize the possibility of an ammonia release that would endanger Seneca personnel or residents of the Buhl Community. These safety controls include simple ideas such as installing ammonia piping with avoidance of forklift traffic in mind, and using physical barriers to prevent contact with ammonia equipment. Automated high-level cutoff controls are utilized to prevent overfilling of system components by shutting down the system and controlling the migration of liquid ammonia. Relief valves are replaced every 5 years as a precautionary measure to avoid valve failure. The computerized/PLC (Programmab le Logic Controllers) operating system control was upgraded in June of 1999. The new Citect technology allows better monitoring of the ammonia system during processing. The current computerized operating system is Y2K compliant. Efforts began in March of 1999 to replace 9 reciprocating compressors with screw compressors. 4 of the 9 were replaced in phase I. Associated piping is also being replaced and upgraded. An internal SOP (Standard Operating Procedure) requires that our refrigeration system must be reviewed by an expert authority on an annual basis. Gartner Refrigeration & Manufacturing Incorporated based in Minneapolis, MN reviews our frozen operations and storage facilities for us on an annual basis. Areas of review include safety concerns, operating issues, capacity, maintenance, efficiency, Process Safety Management Compliance, Risk Management Plan and training. Our objective with this procedure is to ensure safety of plant personnel, fulfill compliance requ irements with all applicable regulations and prevent any unnecessary down time within the plant relating to the these processes. The engine room has an automated auto dialer that functions 24 hours a day, 7 days a week and will contact engine room personnel if any part of the ammonia system is not operating properly or if ammonia is present in key areas. Prior to the ammonia system being started back up each processing season, a Pre-Startup Safety Review, which includes a Safety Inspection Check List for each individual system component (i.e. compressor), is completed. Organizationally, a Frozen Operations Coordinator position was added to the facility in January of 1999. This individual's duties include coordinating operator training and working with engine room personnel to identify and complete ammonia system safety and operational issues. file=EXSEPA |