Citrus Processor Process Safety Management and Risk Management Plan
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A citrus processor operates two ammonia refrigeration systems to provide cooling to perishable storage and manufacturing areas. These processes contain more than 10,000 pounds (lbs) of anhydrous ammonia which is an effective refrigerant. 

Processes that contain more than 10,000 lbs of anhydrous ammonia are subject to the Occupational Safety and Health Administration's (OSHA) 29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals (the PSM Standard) and the Environmental Protection Agency's (EPA) 40 CFR Part 68, Chemical Accident Provisions (the RMP Rule) due to its toxicity. These rules require that subject facilities implement a program and procedures aimed at preventing accidental releases of subject chemicals. 

A number of periodic actions such as audits, which must be conducted at least every three years; a process hazard analyses (PHA) which must be completed initially, then updated or revalidated at least once every five years; and RMP Submittals which must be updated and submitted to the EPA at least every five years, are required.

The facility previously implemented a PSM Program which also serves at their RMP Prevention Program and their PHAs were due for revalidation. The primary objective of a PHA revalidation is to review the process as it is currently configured and operated and identify hazards that have been introduced since the previous PHA.  In addition, the facility wanted to improve the quality and content of their PHAs and perform a more robust analysis. 

Geosyntec led a team of facility employees through a revalidation of both refrigeration processes using the What-If and Checklist PHA methods.  The What-If technique requires the development of What-If questions by brainstorming to identify potential hazards in the process.  The What-If technique is widely used for refrigeration processes.  In addition, Geosyntec also used checklists to address Siting and Human Factors  more thoroughly.  Siting and Human Factors are required subjects for PHAs conducted on processes subject to PSM/RMP.  The Geosyntec PHA Leader used PHAPro® software to record the PHA notes and, along with PHA team input,  applied a risk ranking technique to scenarios with potentially hazardous or disruptive conseqences; the risk ranking technique considers severity of a scenario along with likelihood  of the scenario given protections to assign a risk rank index which may be used to prioritize action items resulting from the PHA.

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Project Summary

  • Location: Southeast U.S.
  • Client: Confidential Citrus Processor
  • Project Practice Areas: Environmental Management
  • Type of Facility: Citrus processing
  • Services Provided: Led Process Hazard Analysis (PHA) revalidations for two ammonia processes using the What-If/Checklist methodologies
  • Type of Work: Process safety management
  • Governing Regulation: OSHA