Los Angeles Cold Storage Company - Executive Summary |
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A California Accidental Release Prevention Program (CaIARP) has been developed and a Risk Management Plan has been prepared for use and storage of anhydrous Ammonia in the Los Angeles Cold Storage facility Refrigeration system. The CaIARP and RMP meet and address the requirements of Title 40 Code of Federal Regulations Part 68 and California Code of Regulations Heath and Safety Code (HSC) Title 19 Article 1 of Chapter 4.5 (CaIARP) Sections 25531 through 25543.3. This Executive Summary briefly describes the following elements: The accidental release prevention and emergency response policies at the stationary source The stationary source and regulated substances handled The worst-case release scenario(s) and the alternative release scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario The general accidental release prevention program and chemical-specific prevention steps The five-year accident history; The emergency r esponse program; and Planned changes to improve safety. To address concerns of an accidental release prevention and emergency response all plant and field personnel are trained in ammonia emergency response procedures and use of appropriate protective equipment. Refresher training and emergency response drills are conducted on a periodic basis to ensure personnel are equipped, trained, prepared, and practiced in responding to ammonia emergencies. As a result of information gathered during preparation of this CaIARP, Los Angeles Cold Storage Company (LACS) is committing additional resources to further increase employee awareness and equipment reliability and to establish operator training and preventive maintenance programs. As a demonstration of the LACS's high degree of commitment to public safety and service, LACS is taking action to decrease the risk of ammonia exposure to the public by implementing recommendations made during the Process Hazards Analysis and Off-site Consequenc e Analysis. Anhydrous ammonia is used as a refrigerant in the LACS facility refrigeration system. The liquid is circulated as needed to the evaporators where heat is absorbed and removed from the medium. The anhydrous ammonia refrigeration system is a closed loop industrial refrigeration system. The ammonia is not used or mixed in any manner with other chemical processes. A "Worst-Case Scenario Offsite Consequence Analysis" and an "Alternative Scenario Offsite Consequence Analysis were performed identifying the public and environmental receptors within the toxic endpoint concentration radius of 200 PPM. The results are mitigated by the fact that all the vessels and majority of the piping are inside the LACS facility's building. The mitigating measures (i.e., vessel inside facility,etc.) existing at the facility are incorporated into the computer Heavy gas modeling (Aloha) of the 'Worst-Case Scenario Offsite Consequence Analysis as is permitted in the new EPA release "Risk Managemen t Program Guidance for Ammonia Refrigeration" 40 CFR part 68. The Alternative Scenario Offsite Consequence Analysis used here does not incorporate mitigating effects and uses the Gaussian dispersion model. There are a multitude of engineering and Administrative Safeguards (i.e., high level cutouts, vessel size, and system operation) that were used to determine worst case and alternative release amounts possible. Emergency response is discussed in Section 5 of this RMP. LACS has a detailed Emergency Response Plan (ERP) for their facility (Located in the Program Element Binder Section 12). The purpose of this plan is to provide the means for rapidly determining the appropriate response for any emergency that may develop at the facility such as an accidental release of anhydrous ammonia. LACS conducts scheduled drills of the emergency response plan. Addressing the five-year accident history is not an issue, since the facility has had no reportable accidents within the last 5 years. To prevent and/or minimize any potential future release of anhydrous ammonia, LACS is implementing a detailed Process Safety Management program (Preventative Program 3). The Preventative Program 3 provides extensive maintenance and operator/mechanic training to ensure the new system's mechanical integrity is maintained for the life of the covered process. Program 3 also incorporates administrative controls when modifications are made to the covered process (ammonia refrigeration system), so the training and preventative programs are updated as the system expands and changes. LACS will address and incorporate into processes and procedures any recommendations resulting from the Process Hazard Analysis, Offsite Consequences, incident investigations and program audits. The flexibility of the program will allow LACS to respond effectively to prevent or minimize any potential of exposing LACS employees, the surrounding public, and /or the environment to a release of anhydrous ammonia. |