Verdelli Farms Inc. - Executive Summary |
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RMP EXECUTIVE SUMMARY A. Accidental Release Prevention and Emergency Response Policies Verdelli Farms recognizes management's responsibility in protecting its employees, the public, the environment, equipment, and property. The safety and health of all personnel are very important. The control of accidents has been and will continue to be a basic responsibility of all personnel at the Harrisburg facility. To accomplish the company's goal in preventing accidents, the facility has established a Plant Safety Program. The objectives of the Plant Safety Program are to: maximize safety performance, eliminate human suffering resulting from injuries and accidents and reduce losses associated with damage of property. One of the activities associated with the Plant Safety Program has been 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 Man agement of Highly Hazardous Chemicals, 29 CFR 1910.119), and EPA's Risk Management Program (RM program) regulation (Risk Management Programs for Chemical Accidental Release Prevention, 40 CFR Part 68). Mr. Cliff Charles, Plant Operations Manager, is responsible for implementation of the Risk Management Program. The purpose of the accidental release prevention and emergency response programs is to prevent the occurrence, and minimize the consequences of significant releases of toxic substances as well as fires, explosions, and other types of catastrophic accidents. Overall, these programs help prevent accidental fatalities, injuries and illnesses environmental impacts and physical property damage. The accidental release prevention and emergency response programs help prevent accidents because they focus on the rules, procedures, and practices which govern individual processes, activities, or pieces of equipment. These rules are detailed and improved as necessary. They are also com municated to and accepted by all employees at the facility. B. Stationary Source and Regulated Substances Handled Verdelli Farms operates an ammonia refrigeration system at the Harrisburg facility. This system is used for providing cooling capabilities during storage and processing of farm produce. The amount of anhydrous ammonia (CAS #7662-41-7) contained in the system is in excess of 10,000 pounds, with maximum inventory approximating to 10,050 pounds. Since ammonia releases from the system could pose a risk of offsite public and/or environmental impact and the system is regulated under the OSHA PSM standard (29 CFR 1910.119), the system is subject to the Program 3 requirements of the EPA's RM program regulation. C. Summary of Worst-Case and Alternative Release Scenarios The worst-case release scenario at the Verdelli Farms facility involves the release of 10,050 pounds of ammonia over a 10 minute period due to the failure of the high pressure receiver. This quantity r epresents the entire inventory of the overall ammonia refrigeration system. The high pressure receiver could only contain this quantity if a complete system pump-down is performed for shutdown purposes. The probability of such a pump-down occurring, however, is very low. Under worst-case weather conditions, ammonia could travel 1.2 miles before dispersing enough to no longer pose a hazard to the public. This distance has been calculated based on the method provided in EPA's Risk Management Program (40 CFR 68) Guidance for Ammonia Refrigeration. The worst-case release scenario is unlikely for the following reasons: The worst-case weather conditions which were used for this scenario are not typical; Industry standards were followed for the manufacture and quality control of the receiver; The receiver is enclosed in a building that would help to contain such a release; Ammonia is not corrosive in this service and the vessel is relatively new; Pressure safety valves lim it operating pressure in the vessel; There is an accident prevention program in place at the facility including the mechanical integrity program for regular maintenance, inspection and testing and replacement of equipment, if necessary; Ammonia detectors are installed in the system to warn of leaks; Alarms and auto-dialing system is in place to warn operating personnel of process upsets; The facility has a training program designed to ensure that the system is operated by qualified personnel; and, The facility emergency response procedures enable trained personnel to respond quickly to isolate any potential releases. The alternative release scenario for the facility is relief of the pressure safety valve serving the high pressure receiver resulting in a ten-minute release from the vent to the atmosphere. Relief from this pressure safety valve was chosen as the alternative release scenario because this relief valve has the highest capacity of relief and it is a potentia lly direct route of release to the atmosphere. Under alternative release weather conditions, ammonia could travel 0.1 miles before dispersing enough to no longer pose a hazard to the public. This distance has been calculated based on the method provided in EPA's Risk Management Program (40 CFR 68) Guidance for Ammonia Refrigeration. The alternative release scenario is unlikely for the following reasons: High pressure alarms are installed in the refrigeration system; Automatic shutdowns and emergency shutdowns are associated with the system; An ammonia sensor is installed in the relief header; An auto-dialing system is in place to warn operating personnel of process upsets; A mechanical integrity program is in place for regular maintenance, inspection and testing, and replacement of equipment, if necessary; The facility emergency response procedures enable trained personnel to respond quickly to isolate any potential releases. D. Description of the Accidental Re lease 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 to be involved when a process hazard analysis is conducted. The program also ensures that all employees have complete access to the program. Process Safety Information: Written information has been collected which enables the employees to identify and understand the potential hazards in the system. The written information includes the ammonia MSDS and a description of the design of the ammonia refrigeration system. Process Hazard Analysis: Formal studies using the What-If/Checklist Technique have been conducted to examine the system and identify potential hazards. Any recommendations are resolved to improve facility safety. Operating Procedures: Written, detailed procedures have been developed which describe the steps which should be followed to safely operat e the ammonia refrigeration system. Training: A training program has been developed which ensures that employees are trained on all aspects of the system and on the duties which they should perform to ensure the safe operation of the ammonia refrigeration system. Contractors: All contractors are screened and evaluated before they perform work on or near the ammonia refrigeration system. The contractors are also periodically evaluated to ensure that they perform work by following safe work practices. Pre-Startup Safety Review: A pre-startup safety review is required for all new ammonia projects to verify that all safety programs are in place, training has been performed, and construction has been completed according to design standards before the project is put into use. They are also performed when there is a change in the process safety information Mechanical Integrity: This program ensures that the ammonia refrigeration systems are built and maintained using pr eventive maintenance procedures to minimize unexpected breakdowns or failures. Hot Work Permit: These procedures ensure that a signed permit is obtained prior to any cutting, welding, or burning. Management of Change: Procedures are designed to ensure that all changes made to the ammonia refrigeration system are properly reviewed. Incident Investigation: Procedures ensure that any incidents (and near misses) are investigated, reviewed, and documented using an investigation team. Any recommendations are resolved to improve the safety of the facility. Compliance Audits: There are procedures to conduct regular audits of the RM prevention program to ensure that the program is in place and working properly. Any recommendations from audits are resolved to improve the RM program. E. Five-Year Accident History There have been no accidental releases that have resulted in any onsite or offsite impacts within the last five years at the Harrisburg facility. F. Descript ion of the Emergency Response Program An emergency response program has been implemented at the Verdelli Farms facility. This program contains procedures describing how the facility will respond to ammonia spills and other emergencies, including evacuation procedures. The program has been coordinated with the Dauphin County Local Emergency Planning Committee (LEPC). The emergency response program consists of the following elements: Organization Plan and Responsibilities Communications Procedures Detailed Action Plans First Aid Procedures Emergency Medical Treatment Procedures Evacuation Plans Description of Outside Assistance Available Site Re-Entry Procedures Training Programs and Drills Revalidation and review procedures G. Planned Changes to Improve Safety The following changes are planned to improve safety conditions and further strengthen the ongoing safety efforts at the Verdelli Farms facility: perform annual air quality testing of the production area provide enhanced forklift operation training enhance the basic plant housekeeping program provide training of Basic Ammonia Refrigeration to selected members of maintenance staff |