Dole Fresh Vegetables, Inc. - Executive Summary |
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EXECUTIVE SUMMARY Dole Fresh Vegetables' Soledad, California accidental release prevention policy involves a unified approach that integrates technologies, procedures, and management practices. All applicable procedures of the EPA Prevention Program are adhered to. Dole Fresh Vegetables' emergency response policy involves the preparation of response plans which are tailored to the facility and to the emergency response services available in the community. It is also in compliance with the EPA Emergency Response Program requirements. This facility consists of the Value Added Facility which is prepared to cool, clean, and package fresh vegetables, primarily for salads. Anhydrous ammonia and chlorine are stored at this facility. The Value Added Facility uses 40,000 lbs of anhydrous ammonia for refrigeration and 12,000 lbs of liquified chlorine gas for disinfectant. The chlorine system with the Value Added Facility is a separate process from the ammonia. The offsite consequence an alysis includes consideration of two release scenarios for each process, identified as "worst case release" and "alternative release scenario." Atmospheric dispersion modeling has to be performed to determine the distance traveled by the toxic substance released before its concentration decreases to the EPA endpoint (0.14 mg/L for anhydrous ammonia and 0.0087 mg/L for chlorine). The worst case release scenarios at this facility are based on failures of the lines and all mitigation systems for the ammonia and chlorine processes. Because the ammonia systems tanks, pipes, pumps, and equipment are within proximity of each other, the total amount of ammonia that potentially could be released would amass to approximately 40,000 lbs. The total amount of chlorine that potentially could be released is 12,000 lbs. The first worst case release scenario followed the conservative conditions pre-defined by the EPA. When atmospheric dispersion modeling for the worst case scenarios were perfor med using the EPA assumptions the EPA endpoints for ammonia and chlorine were offsite. The worst-case scenario is unlikely because the company has employed the following control and mitigating measures. * Industry standards and quality controls were followed in the design of this equipment at its manufacture. * Ammonia is not corrosive in this process * Pressure safety valves limit the operating pressures in the receiver * The facility utilizes a preventive maintenance program to maintain the on-going integrity of the vessel * The facility has a training program that insures only qualified personnel operate the system * The facility requires that all PSM elements as well as company maintenance policies are followed * The facility has trained emergency response personnel and procedures on site to respond quickly to isolate any potential releases. * Only trained and authorized personnel have access to the system * The system was designed using standard practices and is maintained by ri gid company standards * The maintenance program includes a mechanical integrity audit system * The maintenance program includes a by shift monitoring of the refrigeration system * Low level controls, sensors for ammonia monitoring, and available liquid supply to the PRU1 would act as active mitigation before the event met the outlines (and modeled) conclusions * The piping is routed to avoid impact from traffic sources. The alternative release scenarios involved the rupture of a tank or line possibly due to vehicular damage or vandalism. The amount of ammonia released was predicted to be 540 lbs/min and the EPA endpoint distance was offsite. The amount of chlorine released was predicted to be approximately 200 lbs/min. The toxic endpoint distance for this release was offsite. The typical meteorological conditions used for these scenarios was a Stability Class D, wind speed 3.0 m/s, average air temperature, and average humidity. The general accidental release prevention progra m is based on the following key elements: High level of training of the operators. Preventative maintenance program. Use of state-of-the-art process and safety equipment. Use of accurate and effective operating procedures, written with the participation of the operators. Performance of a process hazard analysis of equipment and procedures. Implementation of an auditing and inspection program. Chemical specific prevention steps include availability of self-contained breathing apparatus (SCBA), worn by the operators during connection/disconnection of ammonia supply or chlorine supply, and awareness of the hazardous and toxic properties of these toxic substances. No accidental releases of anhydrous ammonia or chlorine have occurred at this facility in the past five years. The facility has its own emergency response program. This program includes an emergency response decision tree and a notification plan. Emergency response drills and drill evaluations are conducted once every year; emergency operations and response procedures are also reviewed at that time. Dole will fully implement the RMP and will initiate appropriate changes as needed to maintain a safe operation. |