Tri-Marine Fish Company - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The Tri-Marine Fish Company facility has an emergency action plan in effect. The Emergency Action Plan (Plan) is detailed in the Emergency Planning and Response section of this PSM/RMP document. This Plan was designed to meet the following objectives: 1.) To save lives. 2.) To minimize and avoid injuries. 3.) To protect the environment. 4.) To minimize property damage. Tri-Marine Fish Company maintains a safety committee whose members are the designated emergency coordinators for the facility. The Plan provides the response organization and notification procedures, evacuation routes, ammonia health hazards, and mitigation procedures which will be implemented to respond effectively to emergency situations that may arise at the facility. This Plan is reviewed and updated at least once per year. This Plan was reviewed and updated to ensure compliance with the PSM and RMP regulations, as well as to incorporat e facility changes. STATIONARY SOURCE AND REGULATED SUBSTANCE The Tri-Marine Fish Company facility is located at 220 Cannery Street, San Pedro, California 90731. The plant is located about 1.1 kilometers (0.7 miles) south of Vincent Thomas Bridge in Terminal Island. The immediate area is primarily industrial with commercial and residential areas to the west across Los Angeles Main Channel. The facility uses approximately 20,000 pounds (3,600 gallons) of ammonia as a refrigerant within closed system. The system, consisting of piping, valves, and equipment, cycles ammonia through various physical states (high pressure liquid, low pressure liquid, low pressure vapor, high pressure vapor, then back to high pressure liquid) in order to provide refrigeration for product and process equipment. The refrigeration cycle begins with the transfer of high pressure liquid ammonia from the Thermosyphon Receiver (TSY-1) to the High Pressure Receiver (HP-1). High pressure liquid ammonia is tran sferred from HP-1 to the Intercooler (IC-1), the Brine Chiller (CH-1), and a liquid subcooler which constitutes the Single Stage (C5) compressor assembly. Ammonia is returned from CH-1 to IC-1. IC-1 supplies liquid ammonia to the Liquid Recirculator #1 (RC-1). IC-1 also transfers liquid back to HP-1 through the use of a Liquid Transfer System (LR-2). RC-1 supplies liquid ammonia to five Blast Freezers Evaporators (PC1 - PC5) and a mixture of partially vaporized ammonia is sent back to RC-1. RC-1 also transfers ammonia back to HP-1 through the use of a Liquid Transfer System (LR-1). Liquid ammonia is supplied to the Liquid Recirculator #2 (RC-2) from C5's liquid subcooler. RC-2 supplies liquid ammonia to Freezer #1 Evaporators (PC6 - PC9) and Freezer #2 Evaporators (PC-10 - PC12) . A partially vaporized mixture is then sent back to RC-2. Hot gas from the compressors is used as a defrost for all evaporators (PC1 - PC12). Vapor is pulled from the recirculators, RC-1 and RC-2 to t he five compressors. Discharge from two Booster compressors (C3 and C4) is returned to IC-1, whereas, the discharge from the High Stage and Single Stage compressors (C1, C2, and C5 respectively) is sent to the two Condensers (EC-1 and EC-2). A thermosyphon supply and return from TSY-1 is sent to the compressors for oil cooling. High discharge vapor is condensed to a high pressure liquid through EC-1 and EC-2 and returned to TSY-1. An auto purger periodically purges the system of non-condensibles collected in the high pressure receiver and the condensers. The system also has a dilution tank (into which the relief header vents), which is kept full of water. HAZARD ASSESSMENT SUMMARY Worst Case Release Result Summary Scenario Description: Release of the maximum quantity of ammonia that is stored in the largest vessel - 15,856 pounds in 10 minutes. The largest vessel, high pressure receiver, is located inside the engine room, therefore, passive mitigation measures were used to cal culate the release rate. The most pessimistic meteorological conditions were used: 1.5 meters/second wind speed, and F stability. The facility is located in an urban setting. The reference table 4-4 from the EPA's RMP Guidance for Ammonia Refrigeration, Nov 1998 was used to find the distance for the worst case release scenario to 200 ppm. This potential scenario reaches off-site and may affect public receptors. No environmental receptors were affected by this potential scenario. Alternative Release Result Summary Scenario Description: A release of ammonia from resulting from a 1/4 inch diameter hole in a pipe. The release rate of ammonia due to the pressure of the tank is 134 pounds per minute. The meteorological conditions used were 3 meters per second wind speed, and D stability. Exhibit 4-5 from the EPA's RMP Guidance for Ammonia Refrigeration was used to determine the distance to the toxic endpoint of 200 ppm for urban topography. This release reaches off-site and may af fect population receptors. No Environmental receptors were affected by the potential release scenario. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS The Tri-Marine Fish Company facility including the ammonia refrigeration system was designed and constructed in accordance with the 1994 Uniform Mechanical Code which specifically outlines requirements for the safe operation of ammonia refrigeration systems. These safety features include ammonia sensors and automatic shut down buttons both located throughout the facility. FIVE YEAR ACCIDENT HISTORY The refrigeration system at the facility is new as of September 1999; therefore there is no accident to report. EMERGENCY RESPONSE PROGRAM The Tri-Marine Fish Company has an emergency action plan in effect at the facility. The Emergency Action Plan (Plan) is detailed in the Emergency Planning and Response section of this PSM/RMP document. This Plan was designed to meet the following objectives: 1.) To save lives. 2.) To minimize and avoid injuries. 3.) To protect the environment. 4.) To minimize property damage. Tri-Marine Fish Company maintains a safety committee whose members are the designated emergency coordinators for the facility. The Plan provides the response organization and notification procedures, evacuation routes, ammonia health hazards, and mitigation procedures which will be implemented to respond effectively to emergency situations that may arise at the facility. This Plan is reviewed and updated at least once per year. This Plan was reviewed and updated to ensure compliance with the PSM and RMP regulations, as well as to incorporate facility changes due to the renovation of the facility. In case of an ammonia emergency, Tri-Marine Fish Company plans to evacuate all employees and alert the local emergency responders (fire department). The primary evacuation assembly area is the southern loading dock. Tri-Marine Fish Company plans to coordinate emer gency response efforts with the fire department on a periodic and ongoing basis. PLANNED CHANGES TO IMPROVE SAFETY The Process Hazard Analysis study conducted on October 22, 1998 and September 2, 1999 provided mitigation measures to improve safety at the Tri-Marine Fish Company facility located at 220 Cannery Street in San Pedro, California. All recommendations are scheduled to be complete by December 1, 1999. R01 Ensure that there are audible and visual alarms at engine room doors to alert employees upon ammonia detection. To be completed prior to startup (estimated 9/13/99). R02 Coordinate the emergency response program with both maintenance contractor and the local emergency responder (i.e. fire department). COMPLETE R03 Establish procedure to replace/recertify all relief valves every five years or any time a valve vents. COMPLETE R04 Ensure that there are eye wash/safety shower stations that can be reached easily from all typical maintenance locations. To be completed pr ior to startup (estimated 9/13/99). R05 Develop an emergency response plan that includes the response actions for employees. Include a method to account for all individuals on site. R06 Ensure that all operators are properly trained. Provide the operators with eye protection when they are working on the ammonia system. R07 Establish a program to ensure that all employees are aware of the presence of and the hazards associated with ammonia. R08 Establish a procedure to manually test high level switches on the intercooler and recirculator vessels at least once a year. R09 Ensure that the operators follow the oil draining procedures. R10 Examine the feasibility of installing a back up power supply on the ammonia sensors during power failure. R11 Follow manufacturers' recommendations regarding maintenance on all equipment including recirculating pumps, compressors, condensers, and ammonia sensors. COMPLETE R12 Establish a periodic check on the low level shut down switches for th e pumps. COMPLETE R13 Ensure that at least two people are present for maintenance/repairs performed on the refrigeration system on the facility roof. Periodic pipe walks on the roof need only be completed by one person with a radio. To be completed prior to startup (estimated 9/13/99). R14 Ensure that annual checks are performed on compressor safety shut offs. COMPLETE R15 Establish a procedure to complete daily log sheet that records system parameters in the engine room. To be completed prior to startup (estimated 9/13/99). R16 Establish a water treatment plan for condensers. Consider subcontracting this service. R17 Post ammonia sign and NFPA Ammonia Chemical Hazard Classification label outside the engine room. To be completed prior to startup (estimated 9/13/99). R18 Block the alley between the main building and the engine room with a fence to protect the facility. R19 Ensure that two entrances to the engine room remain open during maintenance. To be completed prior t o startup (estimated 9/13/99). R20 Establish a maintenance procedure to ensure the safety of an operator working in the engine room. R21 Consider using an outside alarm company to notify managers in case of an after working hour emergency. R22 Post floor plans and/or work place maps with evacuation instructions. R23 Assign responsibility for roll call during evacuation. Ensure that the manager under stand that they will be required to account for the whereabouts of operators and employees on site during an evacuation. R24 Conduct an emergency evacuation drill at the facility at least once a year and document the results DATA ELEMENT NOTES: Item numbers 7.8a, 7.10a, 7.10b, 7.11a, 7.11b, and 7.15 have been intentionally left blank since this is a new facility. These programs (Management of Change, Compliance Audits, Incident Investigation, and Contractor Safety) have been developed for this facility and will be implemented when required. |