Dole Fresh Vegetables, Inc. - Executive Summary |
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Dole Fresh Vegetables 600 Benjamin Drive Springfield, OH 45502 D-U-N-S #00-315-5558 NAICS #311911 Executive summary of the Risk Management Plan A: Description of Accidental Release Prevention and Emergency Policies To accomplish it's goal in controlling accidental losses, the facility has established an in Plant Safety Program. The objectives of the Plant Safety Program are to achieve maximum efficiency and safety performance. Dole Fresh Vegetables has established a Plant Safety Program for it's Springfield Ohio facility. This program includes the development and implementation of accidental release prevention and emergency response programs which are designed to comply with OSHA's Process Safety Management (PSM) standard (Process Safety Management of Highly Hazardous Chemicals, title 29CFR 1910.119) and the EPA's Risk Management Program (RM Program) regulation (Risk Management Programs for Accidental Release Prevention, title 40CFR Part 68). B: Stationary Sources and Regulated S ubstances Handled The Company operates a value-added food processing facility(NAICS #311991 Perishable Prepared Food Manufacturing) at this address.. The facility operates one single stage ammonia refrigeration system, that provides cooling of the process area as well as chilling of process water. The maximum amount of anhydrous ammonia (CAS#7664-41-7) contained in this refrigeration system is 30,000 pounds. The refrigeration system is subject to the Program 3 requirements of the EPA's Risk Management Program (RMP) and to OSHA's Process Safety Management (PSM) program. The facility also operates a chlorinator induction system utilizing one ton containers of chlorine (CAS# 7782-50-5) connected to the system. This chlorinator system has a maximum inventory of 8,000 pounds of chlorine and is therefore subject to the OSHA and EPA compliance programs. The chlorine system is subject to the Program 3 requirements of the EPA's RM Program. C: Summary of Worst-case and Alternative Release Scenarios 1 Anhydrous Ammonia The worst-case release scenario at the facility involves the release of 26,000 pounds of ammonia over a 10-minute period due to a failure of the HPR1 (Hi Pressure Receiver #1). The maximum level of the HPR1 is limited to 90% (26,000 pounds total) of the vessel capacity during pump down operations by facility administrative controls based on ANSI/ASHREA 15-1994 standards. Under worst-case weather conditions the ammonia would reach the EPA endpoint off-site. The assumptions required by EPA for worst-case release analysis are conservative. 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 in tegrity 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 rigid 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 first alternate release scenario modeled at the facility involves the release of 2 280 pounds per minute of anhydrous ammonia over a 10-minute period due to a failure of a one-inch liquid line feeding an evaporator at a roof valve station. The modeled OCA (Off-site Consequence Analysis) for this scenario has the EPA endpoint off-site. Chlorine The worst-case release scenario at the facility involves the release of 2,000 pounds of chlorine over a ten-minute period due to failure of the chlorine storage containers. Under the worst-case weather conditions, the chlorine would reach the EPA endpoint off-site. The worst-case scenarios are unlikely because the company has employed the following controls and mitigating measures: * Industry standards were followed for the manufacture of these containers, and the containers are supplied by a reputable company meeting the guidelines spelled out in the Company's Process Safety Management's Contractors Requirements as well as requirements for chemical suppliers. * The facility has a training program that insures only qualifie d personnel operate the system * The facility utilizes a preventive maintenance program that includes the tracking and handling of the cylinder vessels * The facility requires that all PSM elements as well as company maintenance polices be followed * The facility has trained emergency response personnel and procedures on site to respond quickly to isolate any potential releases. * The facility maintains equipment to support the emergency response teams to address vessel repair specific to chlorine in the event of one ton cylinder leaks. * Only trained and authorized personnel have access to the Chlorine system * The containers and their valves are protected from traffic by there orientation in the facility * Guards are used during positioning and movement of the containers * Specific equipment covered by the maintenance programs is dedicated to chlorine use only * Special training covering this system and its process is used before authorizing operators and personnel involved in the ch lorine system * House keeping and maintenance practices keep area clear of debris * Tubing, piping, and valves are covered by the preventive maintenance program and are of design specifications used through out the chlorine industry. * A log of the operation of the system is kept and maintained by shift The first modeled alternate release scenarios at the facility involves the release of 16.3 pounds per minute of chlorine over a 60 minute period due to a leak of the vapor valve on the one ton container. The second modeled release scenario involves 125 pounds per minute of chlorine for 16 minutes due to a leak at the liquid valve dumping all 2000 pounds. (These scenarios are unlikely for the reasons discussed above) D: Description of Accidental Release Prevention Program The prevention program consists of the following elements: * Employee Participation: This program involves the employees in establishing and implementing the program. Employees are also involved when a process ha zard analysis is conducted. The program also ensures that the employees have complete access to the program on company property. * Process Safety Information: Written information has been collected which enables the employees to identify and understand the potential hazards in each system. This written information includes the MSDS program as well as a description of the design of each system. A library located in the Engineering office and available to all employees on company property, is maintained with standards, guidelines, generic information about the chemistry of the systems, and the thermodynamic properties of each process. * Process Hazards Analysis: Formal analysis using the What-If/Checklist technique was conducted at the startup of the system to identify potential hazards. Each Management of Change and at regularly scheduled intervals Process Hazard Analysis is conducted and recommendations are reviewed. * Operating Procedures: Written, detailed operating procedures have been developed which describe the steps which should be followed to safely operate the two systems. Each Management of Change and any operation not previously anticipated has a new operating procedure written for the action required. * Training: A scheduled training program has been developed which ensures that all employees that can reasonably be expected to interact with either or both of these systems are trained on all aspects of the systems and on the duties which they should perform. This is to ensure that both of the process systems are operated and maintained safely. Only fully trained and Company authorized personnel shall maintain and/or operate these systems. * Contractors: All contractors are screened and evaluated before they perform work on or near the ammonia or chlorine systems. The contractors are also periodically evaluated to ensure that they perform work by following safe working practices. * Pre-Startup Safety Review: A Pre-Startup safety review is completed for al l new ammonia and chlorine projects to verify that all safety programs are in place, training has been completed, and construction has been completed according to design standards and guidelines, before the project is placed into use. * Mechanical Integrity: This element ensures that the systems are built and maintained using excepted preventive maintenance procedures to minimize unexpected breakdowns or failures. This program is performed on a rigid schedule. * Hot Work Permit: These procedures ensure that a signed permit issued by a Company authorized supervisor is obtained prior to any cutting, welding, or burning. * Management of Change: These procedures are designed to ensure that all changes made to the systems are properly reviewed. * Incident Investigation: The procedures ensure that any incident (and near misses) are investigated, reviewed, and documented using an investigation team. * Compliance Audit: There are scheduled procedures to conduct regular audits of the program t o ensure that the program is in place and working properly. E: Five-year Accident History No ammonia or chlorine incidents were identified for the facility in the previous year and a half that this facility has been operating. F: Description of the Emergency Response Program An Emergency response program has been implemented at the facility. The program contains procedures describing how the facility will respond to ammonia or chlorine spill and other emergencies, including evacuation procedures. The program has been coordinated with the Fire Department. The emergency response program consists of the following elements: * Organization Plan and Responsibilities * Communication Procedures * Detailed action plans * Fire assistance Procedures * Emergency Medical Treatment Procedures * Evacuation Plans * Description of outside assistance available * Site Re-Entry Procedures * Training Program and Drills * Risk Management Plan * Process Safety Management Plan G: Planned Changes to Improve Safety The facility plans to fully implement the RMP Program and to make appropriate improvements as necessary. Sources of Guidance Summary: Methodology used to assembly the Offsite Consequence Analysis, and related elements required assisting in the completion of the Risk Management Plan and its program. About RMP*Comp RMP*Comp is a public domain modeling software program provided through the Environmental Protection Agency (developed by NOAA) for the express purpose of modeling offsite consequence analysis required for the Risk Management Plan. This software was chosen for this plan as it prescribes the exact limitations and parameters as set forth in the RMP Rule, limiting the input error possibilities. Other software is available as are release tables supplied by the EPA/CEPPO. RMP*Comp(r) is limited in its applications as consideration for release elevation, liquid pulsation, and phase flows and as well as simplified Bernoulli assumptions are used. In the chlorin e model, limits are placed on liquid release under pressure in the alternate scenarios. Therefore, other methods were used in the chlorine models. In the ammonia this leads to conservative estimates, which is allowed and suggested by the governing authority (as this is what the EPA uses). This has lead the author of this program to use RMP*Comp(r) as the primary model developer for ammonia, but limit it's use as a chlorine model developer as the endpoints are to liberal when compared to those developed by experts in the chlorine field. In the cases of significant discrepancies other modeling programs were used and compared against the results of RMP*Comp(r) and the highest value were plotted on the OCA maps. About Landview and Census data: LandView is a government-developed mapping and a database-linking program and is commercially available. It draws data from the Bureau of Census, the USGS, the NRC, the DOT, and FEMA as well as the EPA, and will calculate the population in the Of fsite Impact zone as identified by the RMP*Comp program. LandView will also superimpose the OCA zone on a printable Marplot(c) map and locate the facility modeled by longitude and latitude as required in the RMP Plan. LandView (did not show the newer roads (i.e. Benjamin Drive) in the Prime Ohio Business Park. The author of this program using the City of Springfield's Engineering Departments Street and sewer plans inserted these roads. This document and the Risk Management Plan assume that this method was reasonably accurate. Other sources and guidance's: The RISK MANAGEMENT PROGRAM GUIDANCE FOR AMMONIA REFRIGERATION (40CFR PART 68) Published by the Environmental Protection Agency was also used in the preparation of these documents. As these processes are considered level Program 3 of the Risk Management Plan and are also covered by OSHA's Process Safety Management Programs and in keeping with the EPA's intent of paralleling the same in all level Program 3 facilities, the cor e of the Risk Management Plan is based on this facility's PSM. The guidance and format used to assist in this facility's development of it's PSM Program and RM Plan's core elements the GUIDE TO THE IMPLEMENTATION OF PROCESS SAFETY MANAGEMENT (PSM) FOR AMMONIA REFRIGERATION Published by International Institute of Ammonia Refrigeration, was used. Also cited by the Risk Management Plan, especially in the chlorine modeling, was the GENERIC RISK MANAGEMENT PLAN FOR CHLORINE PACKAGING PLANTS AND SODIUM HYPOCLORITE PRODUCTION FACILITIES (a.k.a. Pamphlet #162) published by the Chlorine Institute. After discussion with experts on chlorine air dispersion modeling, it was decided that the more conservative values from this document would be used in the OCA models. The basic structure of this section of the Risk Management Plan is taken directly from the Code of Federal Regulations Title 40 part 68 and its interpretations as outline in the above sited texts and other sources. In 40 CFR 68.22 t he requirements are spelled out for the dispersion modeling of the worst case and alternative scenarios. The toxic end points (EPRG-2) are required as the level set by the American Industrial Hygiene Association (AIHA). This is "the maximum airborne concentration in which it is believed that almost all individuals could be exposed for up to one hour without developing serious irreversible health effects or other symptoms that could impair an individuals ability to take protective action." 40CFR 68 also requires that all worst case air dispersion models use the prescribed wind speed and atmospheric stability class, the largest expected storage vessel (or the largest expected pipe or container; which ever has the greatest off-site impact), ambient humidity/temperature, and that a ground level release event is modeled. Passive mitigation can be used if it meets all the requirements and can not be defeated. As these requirements are lengthy I will not address then here, but suffice it th at these did not apply the enclosure (in the opinion of the author) for either ammonia or chlorine in any of the scenarios used at this facility. Different values are prescribed to the alternate scenarios as described by the Risk Management Plan Rule that include a more favorable weather pattern and lower leak rates. The above listed guidance was used through out the compilation of these models and their plots. Footnote 1: See specific OCA models for actual details and review RMP guidance summary for the details of model development. |