NADCO - Executive Summary

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Executive Summary for NADCO 
 
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. 
 
 
1.    Accidental Release Prevention and Emergency Response Policies 
We at NADCO 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 facilitys primary activities encompass Packing and storage of grapes and non-citrus tree  
fruit.  We have 1 Federal and State re 
gulated substance present at our facility above threshold  
quantities.  Two additional regulated substances below State and Federal thressholds not  
included are Sulfur Dioxide and Sulfuric Acid. Regulated substance included is Ammonia  
(anhydrous) 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 perform the required offsite consequence analysis for our facility, we have used 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 Ammonia Refrigeration.  In this scenario 17988.8 lb. of  
Ammonia (anhydrous) is released.  The toxic liquid released is assumed to form a 1 cm deep  
pool from which evaporat 
ion takes place.  The entire pool is estimated to evaporate over 10  
minutes.  The released quantity is the maximum capacity of the source.  At Class F atmospheric  
stability and 1.5 m/s windspeed, the maximum distance of 2.52 miles is obtained corresponding  
to a toxic endpoint of 0.14 mg/L. 
 
The alternative release scenario for Ammonia (anhydrous) involves a vapor release from the  
High Pressure Receiver Safety Relief Valve.  The scenario involves the release of 4500.00 lb.  
The leak would stopped in 60 minutes by manual activation of the standby SRV.  Under neutral  
weather conditions, the maximum distance to the toxic endpoint of 0.14 mg/L of Ammonia  
(anhydrous) is 0.19 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 and California Accidental Release  
Prevention Program.  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 
NADCO 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).  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 5  
years.  Any findings related to the hazard analysis are addressed in a timely manner.  The most  
recent PHA/update was performed on 06/12/1999. 
 
Operating Procedures 

or the purposes of safely conducting activities within our covered processes, NADCO  
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 
NADCO 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 3 years and more frequently as needed. 
 
Mechanical Integrity 
NADCO 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 NADCO to manage changes in process chemicals, technology,  
equipment and procedures.  The most recent review/revision of maintenance procedures was  
performed on 05/14/1999.  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-startup Reviews 
Pre-start up safety reviews related to new processes and to modifications in established processes  
are conducted as a regular practice at NADCO.  The most recent review was performed on  
05/14/1999 
.  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 
NADCO 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  
05/14/1999.  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 
NADCO 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. 
 
Employee Participation 
NADCO 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 performance of the  
contractor is carried out.  NADCO 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 
NADCO 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 
NADCO 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  
within our processes that would require a modified emergency response. 
 
Tulare County Envir. Health 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 res 
ulted from the implementation of the various  
elements of our accidental release prevention program. Replacing Safety Releif Valves and  
Implementation of the International Institute of Ammonia Refrigeration PSM and RMP  
guidelines are some of the major steps we have taken to improve safety at our facility.   
Additional changes resulting from the recent PHA will be implemented in the next 12 months.
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