Gills Onions - Executive Summary |
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1.0 EXECUTIVE SUMMARY 1.1 Accidental Release Prevention and Emergency Response Policies Gills Onions has a policy to protect its employees, environment, property, and the general public from any harm that may occur as a result of its operations. To achieve this end, Gills Onions strives to operate its facilities in compliance with applicable federal, state, and local safety, health, and environmental regulations. Gills Onions emergency response policies are implemented to comply with the overall company policy of providing its workers with a safe workplace and minimizing risk to the public. The safety of emergency and non-affected personnel must have priority; therefore, all procedures must be carried out in the appropriate manner. Only then can safely executed rescue and medical activities be considered. Another priority is protection of the environment. Only after life, safety, and environmental concerns are addressed will the focus shift to the secondary issues of proper ty conservation and business recovery. 1.2 Facility Description Oxnard is located on the southern margin of the Oxnard Plain, approximately 5 miles inland from the Pacific Ocean and approximately 50 miles west of Los Angeles, California. The elevation of the facility is approximately 35 feet above sea level. The nearest earthquake faults are the Pitas Point-Ventura Fault, approximately 8 miles to the northwest and the Anacapa (Dume) Fault, approximately 16 miles to the southwest located in the Pacific Ocean. The Anacapa (Dume) Fault produced a 5.9 magnitude earthquake in 1973. The facility is located in a limited industrial (M-2) zone at 1051 South Pacific Avenue. The facility covers approximately 14 acres and is bounded on the north by Mountain View Avenue, on the east by Pacific Avenue and on the south by Wooley Road. The Ventura County Railway Spur runs along the western property line which is shared with other light industrial facilities to the west. The nearest major hig hway is State Route 1, the Pacific Coast Highway, approximately 0.5-miles to the west. A map of the area is shown in Figure 1-1. The nearest residential area, East Ash Street, is approximately 0.5-miles to the southwest. The next nearest residential area, La Puerta Street in La Colonia neighborhood, is approximately 0.65 miles to the northeast. The Oxnard Community Center Complex is approximately 1.25-miles to the west and the Center Point Mall is approximately 1.1 miles to the southwest. These are considered public receptors under the RMP regulation. The nearest environmental receptor is a Natural Preserve approximately 6 miles northwest of the facility. The Natural Preserve is located just north of McGrath State Beach on the Santa Clara River outlet to the Pacific Ocean. The facility is designed to process and store onions. Processing includes washing, peeling, dicing, and packaging onions. The cold storage room, shipping dock, and receiving vestibule are designed to store o nions at 340F by means of the ammonia refrigeration system. A block flow diagram of the refrigeration system is contained in Appendix A along with applicable piping and instrument diagrams (P&IDs). The refrigeration system is designed to cool indoor air in processing rooms to approximately 40-500F, to 340F in cold storage, and to chill process water to below 400F. Major process steps include the following: a) compression; b) condensers; c) high pressure receiver; d) pumping units; e) evaporators, air handling units, and water chillers f) diffuser (emergency only). The entire system has the capacity to hold 20,000 pounds of anhydrous ammonia in a closed loop system. 1.3 Regulated Substances Anhydrous ammonia (CAS 7664-41-7) under pressure: 20,000 pounds in a closed-loop refrigeration process at pressure and temperature ranges of 38 to 154 psig and +24 to 1600F in both vapor and liquid states (depending on process step). 1.4 Summary of Offsite Consequence Analysis Results The Offsite Consequence Analysis (OCA) first assumes a "worst-case" catastrophic (instantaneous) release of all ammonia stored within the refrigeration system having a maximum capacity of 20,000 pounds. Similarly, the OCA assumes an "alternate-case" throttled (line break) release of all ammonia stored in the high pressure receiver over a period of 10 minutes. The OCA worst-case was performed with the EPA-approved "Areal Locations of Hazardous Atmospheres" (ALOHA) dense gas dispersion model. For a "worst-case" release, the estimated distance to the toxic-endpoint (200 ppm) is approximately 1.6 miles. The OCA alternate-case was performed with the RMP*Comp version 1.06 consequence analysis program. For the "alternate-case" toxic release, the estimated toxic-endpoint (200 ppm) distance is approximately 0.2 miles. The nearest public receptor is about 100 feet away. There are no designated environmental receptors nearby. 1.5 Five-Year Accident History Since the facility is new construction, there are no prior incidents. 1.6 Prevention Program Gills Onions has developed a Process Safety Management (PSM) Program pursuant to Occupational Safety and Health Administration (OSHA) guidelines (i.e., 8 CCR '5189) for the refrigeration process handling ammonia. The PSM program is designed to ensure safety for employees and minimize the risk of accidental releases and injuries. Gills Onions implemented the PSM program on June 18, 1999 The PSM program's process safety information includes detailed description of ammonia hazards, process hazards, and prevention steps. Chemical-specific prevention steps include: - Nine (9) ammonia detectors - Alarms: horns and beacon lights - Emergency control panel linked to independent alarm systems controller to notify local emergency crews (i.e., fire department, police, etc.) - Emergency shut-down switches - Relief valves to header leading to ammonia diffuser tank 1.7 Emergency Response Program Summary Gills Onions has developed written emergency response procedures to address all elements that may be encountered during planning, responding or follow-up to an emergency at the Pacific Avenue facility. Application of the emergency response procedures ensures compliance with OSHA Standard 29 CFR 1910.38 (Emergency Response Plans) and the emergency response element of the Risk Management Plan. The basic concept of Gills Onions emergency procedures are to provide a comprehensive approach for managing emergencies. The four elements of this approach are prevention, preparedness, response, and recovery. The ERP is designed to be applicable to any type of emergency that may affect Gills Onions and based on the concept that the elements of emergency response are similar, regardless of the hazard. The ERP comprises the following sections: 1. Agency Interface and Response Planning; 2. Public and Agency Notification; 3. Emergency Medical Care; 4. Emergency Response Actions; 5. Emergency Equipment; 6. Emerge ncy Response Training; 7. Incident Command System; and 8. Plan Review and Update. Gills Onions emergency response procedures serve as a guide for emergency control staff, company personnel, emergency assistance groups and law enforcement agencies that may be called upon to participate in controlling an emergency within the facility and surrounding areas. These procedures include employee notification of emergencies and evacuation procedures for all emergency situations. Gills Onions has designated Roger Rosales, Plant Manager has the Emergency Control Officer (ECO). As ECO, Mr. Rosales will coordinate with the City of Oxnard Fire Department/CUPA for emergency response planning. Steve Elkinton is the City of Oxnard Fire Department/CUPA Officer responsible for community emergency response planning. 1.8 Planned Changes to Improve Safety The Process Safety Management (PSM) program developed pursuant to OSHA Guidelines will help to ensure safe practices are followed and minimize the risk of accidents and injuries. The PSM program will begin on June 18, 1999. One of the crucial elements of the PSM program is the ongoing efforts of the Safety Committee who will oversee the entire PSM program. Recommendations made at the HazOp have already been implemented (i.e., second emergency shut-off switch, different ammonia detector settings, etc.), while others will be implemented before August 6, 1999. |