Telco Food Products, Inc. - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES Telco Food Products, Inc. (Telco) facility has an emergency response plan in effect. The Emergency Action Plan (Plan) is detailed in the Emergency Response section of the PSM/RMP document as well as the Business Plan. 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. The Plan provides the response organization and notification procedures, evacuation assembly areas, ammonia health hazards, and mitigation procedures which will be implemented to respond effectively to emergency situations that may arise at the facility. This Plan was reviewed and updated at least once per year. STATIONARY SOURCE AND REGULATED SUBSTANCE The Telco facility was designed and constructed in accordance with all applicable federal, state, and local regulations. The facility is located at 2111 West Valley Blvd., Colto n, CA 92324 and began operation in 1999. The area immediately surrounding the facility is comprised of commercial areas and vacant fields with residences to the north. The facility is situated approximately 0.3 miles north of Interstate 10. Ammonia is used as the refrigerant in the industrial refrigeration system that provides cold storage for food products. The ammonia refrigeration system uses 14,200 pounds of ammonia within a closed system for the purpose of manufacturing bakery products. The system cycles ammonia through various physical states in order to provide cooling in the bakery production processes and cold storage rooms. HAZARD ASSESSMENT SUMMARY Worst Case Release Result Summary Scenario Description: The Low Pressure Receiver #1 (LPR-1) is the largest vessel in the system (with a capacity of 11,900 pounds of ammonia) and is assumed to be completely full for the worst case scenario, with the vessel contents released in a 10 minute time span. The release rate was c alculated to be 654 pounds per minute, after passive mitigation effects due to the enclosure of the vessel in the Machine Room were taken into account. The most pessimistic meteorological conditions were used: 1.5 meters/second wind speed, and F stability. The reference table, Exhibit 4-4, from the EPA's Risk Management Program Guidance for Ammonia Refrigeration was used to determine the distance to the toxic endpoint of 200 ppm for a release of 700 pounds per minute. This release reaches offsite and may affect public receptors. No environmental receptors were affected by this potential release. Alternative Release Result Summary Scenario Description: A release of ammonia gas from a 1/4 inch diameter leak. The release rate of ammonia due to the pressure of the tank is 126 pounds per minute. The meteorological conditions used were 3 meters per second wind speed, and D stability. The reference table, Exhibit 4-5, from the EPA's Risk Management Program Guidance for Ammonia Refriger ation was used to determine the distance to the toxic endpoint of 200 ppm for a release of 150 pounds per minute. This release reaches offsite and may affect public receptors. No environmental receptors were affected by this potential release. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS A sensor within the machine room will alarm at 125 ppm. A signal is sent to the central computer and is logged within alarm history and will wait for operator response, otherwise, if time occurs, operators are paged. An initial shutdown occurs at 250 ppm which does the following: (1) Shut down of solenoid valves in order to isolate the ammonia, (2) The purge ventilation fan is turned on with a manual reset required, (3) scrubbing system pumps and fans are turned on with a manual reset required, and (4) Signal is sent to notify operator (refrigeration contractor). A final shutdown occurs at 10,000 ppm which de-energizes all of the equipment in the machine room inc luding the compressors. The facility is equipped with an automatic shut off button located outside of the Machine room. If a release were to occur, operators can activate this prevention measure. The majority of the ammonia equipment is located in the Machine Room. FIVE YEAR ACCIDENT HISTORY There is no accident history at this facility within the past five years. EMERGENCY RESPONSE PROGRAM Telco has an emergency response plan in effect at the facility. If a release of ammonia were to occur, Telco will determine the extent of the emergency. The alarms are tied into the ammonia sensors and will automatically alarm. Telco management will determine if an evacuation is necessary. They will call 911 in order to reach the San Bernardino County Fire Department HazMat team who will respond to the ammonia release. PLANNED CHANGES TO IMPROVE SAFETY Below is a summary of the recommendations resulting from the Process Hazard Analysis study (including a HAZOP study and What-If Wa lkthrough) performed on July 28, 1999 at Telco Food Products, Inc. R01 Conduct periodic tests on the ammonia detectors and calibrate per manufacturer's specifications. Note: Following the PHA, it was found that Key Mechanical tests the Manning ammonia sensors every six months, with a calibration check done every two to three years. R02 Ensure that the ammonia detectors are equipped with a back up power supply (i.e. generator, batteries). R03 Obtain a 10 foot ladder for machine room. R04 Test ammonia detector shut down levels per industry standards. R05 Consider making the High Level Alarm and Shut Down occur at separate levels. R06 Provide secondary plastic containment for 55 gallon waste oil drum for oil draining. R07 Include in Mechanical Integrity program a test of the level floats/switches in the Receivers. R08 Ensure lockout/tagout procedures are in place when cleaning the condenser. R09 Incorporate a check of the pH of the water dilution tank into the Mechan ical Integrity program to discover any ammonia releases. R10 Install a second computer in distribution office in order to read and dial in to the refrigeration system computer. R11 Have operator notify front office when activities are performed on the roof. R12 Install an alarm light outside of the machine room to indicate an ammonia leak. R13 Install eye wash/safety shower outside of the machine room. R14 Provide truck delivery drivers and all people who check in a card which states that there is ammonia present at Telco and where to evacuate to in case of emergency. R15 Ensure that 911 on cell phones reaches Fire Department. If not, program the local Fire Department telephone number into all Incident Commander telephones. R16 Include Incident Commander cell phone numbers in Emergency Plan. R17 Install wind socks which are visible from the exit routes, the road, and the assembly points. R18 Investigate the location of manholes as these may serve as sewer vents in the event of an ammonia release. R19 Label important valves. R20 Ensure that the power to the exhaust fans in the machine room are de-energized at a shut off of 10,000 ppm. |