Anton Caratan and Son - Executive Summary
ANTON CARATAN AND SON |
EXECUTIVE SUMMARY FOR AMMONIA REFRIGERATION SYSTEMS AND PROPANE FUELING OPERATION
1. Accidental Release Prevention and Emergency Response Policies:
We at Anton Caratan and Son 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 Handled:
Our facility's primary activities encompass cold storage of table grapes. We have 2 regulated substances present at our facility. These substances include Propane and Ammonia (anhydrous). Propane is used for fueling of company vehicles. Ammonia (anhydrous) is used for our cold storage refrigeration.
m inventory of Propane at our facility is 110880.00 lbs. while Ammonia (anhydrous) is present at our facility in a maximum quantity of 48500.00 lbs.
3. The Worst Case Release Scenarios and the Alternative Release Scenarios, including administrative controls and mitigation measures to limit the distances for each reported scenario:
To perform the required offsite consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations and the EPA's RMP Guidance for Ammonia Refrigeration 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 the new cold storage refrigeration facility. In this scenario 33500 lb. of Ammonia (anhydrous) is released. The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate
over 10 minutes. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 3.37 miles is obtained corresponding to a toxic endpoint of 0.14 mg/L.
One alternative release scenario for Ammonia (anhydrous) involves a release from the new cold storage refrigeration system. The scenario involves the release of 33500 lbs. of ammonia. The ammonia is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 130.76 minutes. The release is also assumed to be controlled by emergency shutdown system(s). These active mitigation systems have the effect of minimizing the quantity released. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (anhydrous) is 0.46 miles.
Another alternative release scenario for Ammonia (anhydrous) involves a release from the old cold storage refrigeration system. The scenario involves the release of 2813 lbs. o
f ammonia. The ammonia is assumed to be released to form a 1 cm deep pool from which evaporation takes place. The entire pool is estimated to have evaporated after 15 minutes. Passive mitigation controls such as enclosure(s) are taken into account to calculate the scenario, having the effect of minimizing the release by containing the ammonia. The release is also assumed to be controlled by response by onsite personnel. Under neutral weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia (anhydrous) is 0.19 miles.
The worst case release scenario submitted for Program 2 and 3 flammable substances as a class involves a catastrophic release from Propane. In this scenario 110880 lbs. of Propane is released. It is assumed that the entire quantity is released as a vapor, which finds an ignition source, with 10 percent of the released quantity participating in a vapor cloud explosion. Under worst case weather conditions, the calculated distance of 0.39
miles is obtained corresponding to an endpoint of 1 psi overpressure.
The alternative release scenario submitted for Program 2 and 3 flammable substances involves a release from Propane. The release is assumed to result in a Vapor Cloud Fire. The scenario involves the release of 108662 lbs. of Propane in 10 minutes. The release is also controlled by active mitigation measures that include response by onsite personnel. Under neutral weather conditions, the maximum distance to the flammable endpoint of Lower flammability limit is 0.14 miles.
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, 1967 Edition. The following sections briefly describe the elements of the release prevention program that is in place
at our stationary source.
Process Safety Information:
Anton Caratan and Son 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) and HAZOP. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval of every two years. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 02/24/1999.
For the purposes of safely conducting activities within our covered processes, Anton Caratan and Son 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.
Anton Caratan and Son 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 training is provided at least every year and more frequently as needed.
Anton Caratan and Son 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 Anton Caratan and Son to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 04/02/1999. Process operators, maintenance personnel or any other employee 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 Anton Caratan and Son. The most recent review was performed on 05/31/1996. These reviews are conducted to confirm that construction, equipment, operating and maintenance proced
ures are suitable for safe startup prior to placing equipment into operation.
Anton Caratan and Son conduct audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent compliance audit was conducted on 02/24/1999. 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.
Anton Caratan and Son promptly investigates 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.
Anton Caratan and Son truly believes that process safety management and accident prevention is a team effort. Compa
ny 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 facility's 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 performance of the contractor is carried out. Anton Caratan and Son has a strict policy of informing the contractors of known potential hazards related the contractor's 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:
Anton Caratan and Son has had an excellent record of preventing accidental releases over the last 5 years. Due to our
stringent release prevention policies, only one accidental release has occurred during this period.
There has been only one accidental release of a regulated substance from our facility within the last 5 years. This release took place on 06/22/1998 and involved 100 lbs. of Ammonia (anhydrous). No deaths or injuries occurred offsite as a result of this accident. Onsite, there were no deaths or injuries.
6. Emergency Response Plan:
Anton Caratan and Son 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 emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place wit
hin our processes that would require a modified emergency response.
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. Periodic safety inspections and ongoing employee training are some of the major steps we want to take to improve safety at our facility. These changes are expected to be implemented by 12/31/1999.