Seneca Foods Corporation - Executive Summary
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
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
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.
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
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
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
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
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