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.  
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 
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 
operational issues. 
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