Delano Growers Grape Products - Executive Summary

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EXECUTIVE SUMMARY 
 
 
Accidental Release Prevention and Emergency Response Policies 
 
Delano Growers Grape Products utilizes aqua ammonia in the regeneration of their anion vessels in the ion exchange system at their facility near Delano, California.  It is Delano Growers Grape Products' policy to comply with all applicable governmental regulations.  Further, it is Delano Growers Grape Products' objective to be a responsible citizen of the community in all of its business activities. 
 
Description of the Stationary Source and Regulated Substances  
 
Delano Growers Grape Products owns and operates a grape juice concentrate production facility located at 32351 Bassett Avenue in Delano, California.  At Delano Growers Grape Products, grape juice is processed through ion exchange vessels (cation and/or anion vessels), depending on the specification of the finished grape juice concentrate product.   
 
The ion exchange beds must be regenerated periodically to maintain the ion exchange efficiencies 
.  The cation beds are regenerated with a dilute sulfuric acid solution while the anion beds are regenerated with a dilute ammonium hydroxide (aqua ammonia) solution.  A 30% solution of aqua ammonia is stored on-site in two 6,000 gallon tanks.  The maximum quantity of aqua ammonia that can be stored in one of the tanks is 47,000 pounds.  
 
For purposes of the offsite consequence analyses, the RMP regulations define the toxic endpoint for aqua ammonia as 0.14 mg/l (200 ppm).  This concentration has been established by the American Industrial Hygiene Association as the Emergency Response Planning Guideline Level 2 (ERPG-2).   
 
ERPG-2 is the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual's ability to take protective action. 
 
Worst-Case Release Scenario and Alternative Release Scenario 
 
The RMP 
regulations require the owner or operator of a stationary source to analyze the offsite impacts due to an accidental release of a regulated substance.  The offsite consequence analysis for a Program 2 process must analyze the worst-case release scenario and an alternative release scenario.  Since Delano Growers Grape Products' aqua ammonia storage and anion column regeneration process is considered a Program 2 process, both release scenarios were evaluated in the offsite consequence analysis. 
 
The offsite consequence analysis must include an estimate of the residential population within an area potentially affected by the accidental release scenario.  This area is defined as a circle with a radius equivalent to the distance the release would travel with concentrations at or above the endpoint.  The circle also defines the area in which potential environmental receptors must be identified. 
 
The worst case release is defined by the U.S. EPA as the total release of the contents of the si 
ngle largest vessel or pipe within 10 minutes.  An alternative release scenario is a release that is more likely to occur than the worst-case release scenario.  For Delano Growers Grape Products, the alternative release scenario was selected based on the results of the hazard review for the aqua ammonia storage and anion column regeneration process.  A delivery hose failure event (hose failure or sudden uncoupling) with a high discharge rate would potentially have the greatest offsite impact and, therefore, was chosen as the alternative release scenario.     
 
Delano Growers Grape Products has analyzed the offsite consequences of the worst-case and alternative release scenarios.  The aqua ammonia storage tanks have secondary containment dikes, which would greatly reduce the impact of a release.  The modeling performed as part of this offsite consequence analysis for the worst case release scenario includes a mitigation factor which takes into account the dikes around the tanks.    
 
For  
the worst-case release scenario, the release of 47,000 lbs. of ammonia over a 10 minute period, the plume would travel less than 0.1 mile at concentrations at or above the endpoint.  No residences are located within 0.1 mile of the aqua ammonia storage tanks.  Therefore, there would be no populations impacts from the worst case release scenario.  There were no sensitive receptors or environmental receptors within the worst case release scenario circle. 
 
In the alternative release scenario, a failure of the delivery hose was modeled as a release of liquid aqua ammonia.  For a release of 949 lb/min of aqua ammonia, the model calculated that the plume would travel 0.2 mile at concentrations at or above the endpoint.  No residences are located within 0.2 mile of the aqua ammonia storage tanks.  As such, there would be no population impacts from the alternative release scenario.  There were also no sensitive receptors or environmental receptors within the alternative release scenario circle 
.  
 
 
 
General Accidental Release Prevention Program and Chemical-Specific Prevention Steps 
 
A general accidental release prevention program has been developed at Delano Growers Grape Products to address the aqua ammonia storage and anion column regeneration process.  This program includes the following chemical-specific prevention steps: 
 
    Safety information, including the Material Safety Data Sheet for aqua  ammonia; the maximum intended inventory of the aqua ammonia storage tanks; safe upper and lower temperatures and pressures; equipment specifications; and the codes and standards used to design, build, and operate the process, has been compiled. 
 
    Compliance with federal and state regulations that address industry-specific safe design and industry-specific design codes and standards has been demonstrated.   
 
    A hazard review was performed and will be updated and revalidated at least every five years. 
 
    Written operating procedures have been developed and implemented, and are re 
viewed at least annually. 
 
    Each employee involved in operating the ammonia system has received initial training and refresher training at least every three years. 
 
    Written mechanical integrity procedures have been established and implemented. 
 
    Audit procedures have been developed and will be conducted at least every three years to evaluate compliance with the CalARP regulations. 
 
    Incident investigation procedures have been established. 
 
To ensure that the general accidental release prevention program and the chemical-specific prevention steps are implemented, Delano Growers Grape Products has assigned overall responsibility for the RMP elements to the Manager of Production and Research.  The Manager of Production and Research has the overall responsibility for the development, implementation, and integration of the RMP elements. 
 
 
 
Five-Year Accident History 
 
Delano Growers Grape Products has not had any accidental releases from the aqua ammonia storage and anion column regener 
ation process that have resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage in the last five years. 
 
Emergency Response Program 
 
Delano Growers Grape Products has established an emergency action plan and a chain of command to respond to emergencies and to notify emergency responders when there is a need for a response.  However, an emergency response program does not need to be developed for the facility since Delano Growers Grape Products employees will not respond to accidental releases of ammonia, the facility is included in the community emergency response plan, and appropriate mechanisms are in place to notify emergency responders. 
 
Planned Changes To Improve Safety 
 
Through the accidental release prevention program, Delano Growers Grape Products regularly evaluates the need for any changes to improve safety.  Currently, Delano Growers Grape Products does 
not currently have any changes planned to improve safety other than the above listed items.  
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