HMC Cold Storage - Executive Summary |
|
Executive Summary for HMC Cold Storage RMP Introduction 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 Potential Impact. 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 ndled 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 ep 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 source. 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. Operating Procedures 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. Training 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. Mechanical Integrity 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 other employ 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-startup Reviews 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 into operation. Compliance Audits 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. Incident Investigation 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. Employee Participation 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. Contractors 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 year. |