E. F. Oxnard, Inc. - Executive Summary |
1.0 EXECUTIVE SUMMARY The following Risk Management Program / Accidental Release Prevention Plan has been prepared for the E.F. Oxnard, Inc. (E.F. Oxnard) facility located at 550 Diaz Avenue in Oxnard (see Figure 1). This facility is engaged in energy production and distribution and operates two ammonia systems. This RMP has been prepared pursuant to Title 19, Division 2, Chapter 4.5 of the California Code of Regulations. This RMP covers two anhydrous ammonia systems. The first system is a selective catalytic oxidizer (SCR) unit that uses ammonia to control nitrogen oxide (NOx) emissions from the natural gas fired turbine and the HRSG duct. The ammonia for this system is stored in a 12,000 gallon tank and gravity fed to a vaporizer where it is conveyed to the SCR unit. The maximum quantity of anhydrous ammonia handled in this system is 10,500 gallons, or 54,220 pounds as specified in the facility PSM document. The second system is the Aqua Ammonia Absorption Refrigeration Plan t (AAARP). In this system, steam from the turbine is used to power a refrigeration cycle. The ammonia process piping of the AAARP is connected to the Boskovich Farms, Inc. (Boskovich) refrigeration system and runs independently from the SCR ammonia process. Although this system is physically located to the south on the neighboring Boskovich property, it is included in this RMP because E.F. Oxnard owns and operates the AAARP and leases the land on which the system is located from Boskovich. The AAARP system contains approximately 2,000 gallons (10,300 lb) of aqueous ammonia at various concentrations. Because more than 10,000 pounds of ammonia is used in a single process, this facility is subject to Program 3 requirements. 1.1 Accidental Release Prevention and Emergency Response Policies To prevent the accidental release of ammonia, E.F. Oxnard has developed the following: - Maintenance procedures to ensure that equipment is properly maintained and functioning properly. - Operat ing procedures to ensure that equipment is operated in a manner that minimizes the possibility of an ammonia release. - Employee training to ensure that operators know how to properly use the equipment and non-operators are aware of the dangers of ammonia and the necessary steps to take in the event of an ammonia release. - Fencing around the site to minimize the possibility of a third party damaging equipment or releasing ammonia. These programs are contained in Binder 3: PSM Plan. The general emergency response policy for the site when ammonia is released is to determine extent and nature of release, evacuate to an area upwind of the release (if necessary) and notify the appropriate personnel and authorities. A copy of the Hazardous Substance Contingency Plan and Emergency Action Plan is located in Binder 4: Five Plan Binder. A description of the ERP is contained in Section 6.0 Emergency Response Program in this document. 1.2 Stationary Source and Substance Handled As explained above, E.F. Oxnard operates ammonia systems for the SCR and AAARP systems. The systems contain approximately 54,220 lb and 10,300 lb of ammonia, respectively. 1.3 Accidental Release Scenarios The modeled scenarios include: Worst Case Scenario (WC): State-mandated worst case scenario per CCR Title 19, Division 2, Article 4, 10 minute release of largest vessel's contents. In this case, the largest single vessel is the SCR system tank. This scenario would result in off site impacts Mitigated Scenario (WC-M): Worst case scenario with mitigating structures taken into account. If the SCR tank were to rupture, the ammonia would not all be release as a gas. The liquid would be contained in the secondary containment and slowly evaporate. This scenario considers the entire contents of the vessel pooled in an 610 sq. ft. area (the size of the secondary containment). This scenario would result in off site impacts. Alternate Scenario 1 (A1): SCR system pressure relief valve (PRV) ac tivates for 10 minutes. Alternate Scenario 2 (A2): Because the facility has two processes, the state-mandated worst case scenario was also run for the largest vessel in the AAARP system. This scenario was chosen so that the maximum risk posed by each system could be compared based on equivalent analyses. Alternate Scenario 3 (A3): Small leak from a pump seal in high pressure anhydrous portion of AAARP equipment. In order to reduce the severity of an accidental release, the following administrative controls and mitigation measures are in place at E.F. Oxnard: - Maintenance procedures to ensure that equipment is properly maintained and functioning properly. - Operating procedures to ensure that equipment is operated in a manner that minimizes the possibility of an ammonia release. - Employee training to ensure that operators know how to properly use the equipment and non-operators are aware of the dangers of ammonia and the necessary steps to take in the event of an ammonia release. - Fencing around the site to minimize the possibility of a third party damaging equipment or releasing ammonia. - Ammonia sensors to detect ammonia releases. Details regarding the Offsite Consequence Analysis for the worst case and alternative release scenarios can be found in Section 3.0 of this document. 1.4 General Accidental Release Prevention Program Components and Substance Specific Prevention Steps The following components are contained in the following sections of this Risk Management Plan document: - Registration - Offsite Consequence Analysis - Five-year Accident History - Program Specific Component - Emergency Response Program - Certification - Update Procedure In order to further mitigate the effects of an ammonia release, the following risk management components are in place: - Maintenance and standard operating procedures for the ammonia systems. - The site is prevented from being accessed by trespassers with the use of fencing and 24-hour staffing. - Emergency Response Plan. - Training for employees. - Incident investigation documentation and procedures. - Automatic system shutdowns. - Windsock to detect the direction of wind. - Ammonia sensors at various locations at the facility. 1.5 Five-year Accident History E.F. Oxnard has had one incident in the past five years from the ammonia system that resulted in off site injuries that required medical attention. It is estimated that approximately 10 gallons (51.5 lb) of aqueous ammonia vapor was released through a pressure safety valve. This incident is discussed in Section 4.0. 1.6 Emergency Response Plan Components The Emergency Response Plan (ERP) for the E.F. Oxnard facility, titled "Hazardous Substances Control Plan," has been prepared and contains information for responding to an ammonia release. The general emergency response policy for the site when ammonia is released is to evacuate to an area upwind of the release (if necessary) and notify the appropriate p ersonnel and authorities. 1.7 Planned Changes to Improve Safety In the original process hazard analysis (PHA) there were several recommendations made to improve safety at the facility. These changes are summarized in Section 5 of this document. The original recommendations have been implemented and there are no new planned changes to improve safety at this time. The facility was constructed according to Uniform Building Code (UBC) Level 4 Seismic design criteria. Current guidance from the CalARP Program Seismic Guidance Committee dated September 1998 and approved by the Region 1 Local Emergency Planning Committee (LEPC) on January 1, 1999 indicates that more stringent requirements of newer UBC versions may apply. To ensure adequate seismic safeguards are in place at the facility, a seismic study will be conducted within the next year. |