E. F. Oxnard, Inc. - Executive Summary

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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.
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