HMC Cold Storage - Executive Summary
Executive Summary for HMC Cold Storage RMP |
This report and Risk Management Plan was developed to comply with US EPA and Cal ARP
requirements. Resources used in the process was International Institute of Ammonia
Refrigeration Guidelines, RMP Pro 98 Software by Dyadem
and Cold Storage Technologies.
Report organization includes; Certification statement, Summary, Detailed Elements and Map of
1. Accidental Release Prevention and Emergency Response Policies
We at HMC Cold Storage are strongly committed to employee, public and environmental safety.
This commitment is demonstrated by our comprehensive accidental release prevention program
that covers areas such as design, installation, operating procedures, maintenance, and employee
training associated with the processes at our facility. It is our policy to implement appropriate
controls to prevent possible releases of regulated substances.
2. The Stationary Source and the Regulated Substances Ha
Our facilitys primary activities encompass Packing and storage of fresh produce. We have 1
regulated substance present at our facility above threshold quantities. Ammonia (anhydrous) is
used for Refrigeration.
3. 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
To evaluate the worst case scenarios, we have used the EPA's RMP Guidance for Ammonia
Refrigeration Reference Tables or Equations. For alternative release scenario analyses we have
employed the EPA's OCA Guidance Reference Tables or Equations. The following paragraphs
provide details of the chosen scenarios.
The worst case release scenario submitted for Program 2 and 3 toxic substances as a class
involves a catastrophic release from Ammonia Refrigeration. In this scenario 11000 lb. of
Ammonia (anhydrous) is released. The toxic liquid released is assumed to form a 1 cm de
pool from which evaporation takes place. The entire pool is estimated to evaporate over 10
minutes. The released quantity has been limited to 45% of the maximum capacity of the source
by physical limitations of available High Pressure Receiver capacity and a system of
administrative controls. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum
distance of 2.18 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L. Population
from census information within this radius is 4162, however the Plume Footprint would be
approximately 10% of this number.
The alternative release scenario for Ammonia (anhydrous) involves a release from Ammonia
Refrigeration. The scenario involves the release of 300.00 lb. of vapor from a compressor seal
failure. The release is stopped by manually isolating the compressor after 60 minutes. Under
neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of
Ammonia (anhydrous) is 0.06 miles.
This reaches the facility boundry and has a population of 1.
4. The General Accidental Release Prevention Program and the Chemical-
Specific Prevention Steps
Our facility has taken all the necessary steps to comply with the accidental release prevention
requirements set out under 40 CFR part 68 of the EPA. This facility was designed and
constructed in accordance with NFPA-58 Standard, 1998 Edition. The following sections
briefly describe the elements of the release prevention program that is in place at our stationary
Process Safety Information
HMC Cold Storage maintains a detailed record of safety information that describes the chemical
hazards, operating parameters and equipment designs associated with all processes.
Process Hazard Analysis
Our facility conducts comprehensive studies to ensure that hazards associated with our processes
are identified and controlled efficiently. The methodology used to carry out these analyses is
What If/Checklist (combined). T
he studies are undertaken by a team of qualified personnel with
expertise in engineering and process operations and are revalidated at a regular interval of5
years. Any findings related to the hazard analysis are addressed in a timely manner. The most
recent PHA/update was performed on 06/18/1999.
For the purposes of safely conducting activities within our covered processes, HMC Cold
Storage maintains written operating procedures. These procedures address various modes of
operation such as initial startup, normal operations, temporary operations, emergency shutdown,
emergency operations, normal shutdown and startup after a turnaround. The information is
regularly reviewed and is readily accessible to operators involved in the processes.
HMC Cold Storage has a comprehensive training program in place to ensure that employees who
are operating processes are competent in the operating procedures associated with these
processes. Refresher traini
ng is provided at least every 3 years and more frequently as needed.
HMC Cold Storage carries out highly documented maintenance checks on process equipment to
ensure proper operations. Process equipment examined by these checks includes among others;
pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown
systems, controls and pumps. Maintenance operations are carried out by qualified personnel
with previous training in maintenance practices. Furthermore, these personnel are offered
specialized training as needed. Any equipment deficiencies identified by the maintenance
checks are corrected in a safe and timely manner.
Management of Change
Written procedures are in place at HMC Cold Storage to manage changes in process chemicals,
technology, equipment and procedures. The most recent review/revision of maintenance
procedures was performed on 06/18/1999. Process operators, maintenance personnel or any
ee whose job tasks are affected by a modification in process conditions are
promptly made aware of and offered training to deal with the modification.
Pre-start up safety reviews related to new processes and to modifications in established processes
are conducted as a regular practice at HMC Cold Storage. The most recent review was
performed on 03/08/1999. These reviews are conducted to confirm that construction, equipment,
operating and maintenance procedures are suitable for safe startup prior to placing equipment
HMC Cold Storage conducts audits on a regular basis to determine whether the provisions set
out under the RMP rule are being implemented. The most recent comliance audit was conducted
on 06/18/1999. These audits are carried out at least every 3 years and any corrective actions
required as a result of the audits are undertaken in a safe and prompt manner.
HMC Cold Storage promptly inv
estigates any incident that has resulted in, or could reasonably
result in a catastrophic release of a regulated substance. These investigations are undertaken to
identify the situation leading to the incident as well as any corrective actions to prevent the
release from reoccurring. All reports are retained for a minimum of 5 years.
HMC Cold Storage truly believes that process safety management and accident prevention is a
team effort. Company employees are strongly encouraged to express their views concerning
accident prevention issues and to recommend improvements. In addition, our employees have
access to all information created as part of the facilitys implementation of the RMP rule,
including information resulting from process hazard analyses in particular.
On occasion, our company hires contractors to conduct specialized maintenance and construction
activities. Prior to selecting a contractor, a thorough evaluation of safety per
formance of the
contractor is carried out. HMC Cold Storage has a strict policy of informing the contractors of
known potential hazards related the contractors work and the processes. Contractors are also
informed of all the procedures for emergency response should an accidental release of a
regulated substance occur.
5. Five-year Accident History
HMC Cold Storage has had an excellent record of preventing accidental releases over the last 5
years. Due to our stringent release prevention policies, there has been no accidental release
during this period.
6. Emergency Response Plan
HMC Cold Storage carries a written emergency response plan to deal with accidental releases of
hazardous materials. The plan includes all aspects of emergency response including adequate
first aid and medical treatment, evacuations, notification of local emergency response agencies
and the public, as well as post-incident decontamination of affected areas.
To ensure proper functioning, our eme
rgency response equipment is regularly inspected and
serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place
within our processes that would require a modified emergency response.
County of Fresno is the Local Emergency Planning Committee (LEPC) with which our
emergency plan has been coordinated and verified.
7. Planned Changes to Improve Safety
Several developments and findings have resulted from the implementation of the various
elements of our accidental release prevention program. Implementation of the IIAR PSM/RMP
guidelines and improved isolation valve access are some of the major steps we want to take to
improve safety at our facility. These changes are expected to be implemented by the end of this