Camp Frio Cold Storage - Executive Summary
EXECUTIVE SUMMARY |
Accidental Release Prevention and Emergency Response Policies
The Camp Frio Cold Storage facility utilizes anhydrous ammonia as the
refrigerant in their cold storage facility located northeast of Shafter, California. As
it is Camp Frio Inc.'s policy to comply with all applicable governmental
regulations, the cold storage facility was designed and constructed in 1997 to the
1991 Uniform Building Code/Uniform Mechanical Code. Personnel at Camp Frio
Cold Storage monitor the daily operation of the refrigeration system. All service,
maintenance, and repairs to the ammonia refrigeration system are contracted to
a qualified licensed refrigeration contractor specializing in ammonia refrigeration.
Utilizing an experienced qualified contractor to perform routine service,
maintenance, and repairs ensures that the equipment is in excellent operating
While it is Camp Frio Inc.'s objective to be a responsible citizen of the community
in all of its busi
ness activities, the limited staff at the cold storage facility
precludes emergency response operations. As such, an emergency action plan
has been prepared for Camp Frio Cold Storage and a chain of command to
respond to emergencies has been established.
Description of the Stationary Source and Regulated Substances
Camp Frio Inc. owns and operates a cold storage facility located at 31792
Merced Avenue. Shafter is the closest city to the Camp Frio Cold Storage
facility. The rural plant was constructed in 1997 utilizing all new equipment at the
time of construction.
Anhydrous ammonia is used as the refrigerant that provides process cooling for
the Camp Frio Cold Storage facility. The refrigeration system consists of a
suction accumulator with a liquid transfer system, three compressors, an
evaporative condenser, a high pressure receiver, and several flooded
During normal operation, the anhydrous ammonia is distributed throughout the
m. However, during major maintenance activities, the entire
refrigeration system can be "pumped down" to evacuate the ammonia from the
system and store it in the high pressure receiver. The maximum quantity of
ammonia that can be stored in the high pressure receiver is 15,390 pounds.
For purposes of the offsite consequence analyses, the RMP regulations define
the toxic endpoint for anhydrous ammonia as 0.14 mg/l (200 ppm). This
concentration has been established by the American Industrial Hygiene
Association as the Emergency Response Planning Guideline Level 2 (ERPG-2).
ERPG-2 is the maximum airborne concentration below which it is believed that
nearly all individuals could be exposed for up to one hour without experiencing or
developing irreversible or other serious health effects or symptoms which could
impair an individual's ability to take protective action.
Worst-Case Release Scenario and Alternative Release Scenario
Offsite consequence analyses are used as tool
s to assist in emergency response
planning. The RMP regulations require the owner or operator of a stationary
source to analyze the offsite impacts due to an accidental release of a regulated
substance. The offsite consequence analysis for a Program 3 process must
analyze the worst-case release scenario and an alternative release scenario.
Since the ammonia-based refrigeration system at Camp Frio Cold Storage is
considered a Program 3 process, both release scenarios were evaluated in the
offsite consequence analysis.
The offsite consequence analysis must include an estimate of the residential
population within an area potentially affected by the accidental release scenario.
This area is defined as a circle with a radius equivalent to the distance the
release would travel with concentrations at or above the toxic endpoint. The
circle also defines the area in which potential environmental receptors must be
The worst case release is defined by the U.S. EPA a
s the total release of the
contents of the single largest vessel or pipe within 10 minutes. For liquefied
gases stored under pressure, the entire contents of the vessel or pipe are
assumed to be released as a vapor. A total vapor release is highly unlikely.
However, this standardized worst case scenario was developed for emergency
response agencies to use for planning purposes.
An alternative release scenario is a release that is more likely to occur than the
worst-case release scenario. For Camp Frio Cold Storage, the alternative
release scenario was selected based on the results of the Process Hazard
Analysis (PHA) for the ammonia-based refrigeration system. A credible release
event with a high discharge rate would potentially have the greatest offsite
impact. A leak from a valve packing was identified in the PHAs as having a
medium probability of occurrence with a discharge rate high enough to cause an
offsite impact, and therefore, was chosen as the alternative re
Camp Frio Cold Storage has analyzed the offsite consequences of the worst-
case and alternative release scenarios. For the worst-case release scenario, the
release of 15,390 lbs. of ammonia over a 10 minute period outside of the engine
room, the plume would travel 1.5 miles at concentrations at or above the
endpoint. Using 1990 Census data, the population potentially affected within the
worst-case release scenario circle is 75 persons. Due to the rural location of this
facility, the population potentially affected by this worst case release is
substantially overstated by the 1990 Census data. There were no environmental
receptors within the worst case release scenario circle.
In the alternative release scenario, a packing leak from an isolation valve located
outdoors was modeled as a release of liquefied ammonia stored under pressure.
For a release of 22 lb/min of anhydrous ammonia, the model calculated that the
plume would travel less than 0.1 mile at
concentrations at or above the endpoint.
No residences are located within the 0.1 mile area around the Camp Frio Cold
Storage facility. As such, there would be no population impacts from the
alternative release scenario. There were also no sensitive receptors or
environmental receptors within the alternative release scenario circle.
General Accidental Release Prevention Program and Chemical-Specific
A PSM program, which meets the requirements of the general accidental release
prevention program, is being implemented by Camp Frio Cold Storage to
address the anhydrous ammonia system. The PSM program includes the
following chemical-specific prevention steps:
Written process safety information, including information pertaining to the
hazards of ammonia, the technology of the process, and the equipment in
the process is being compiled.
Process Hazard Analyses (PHA) will be updated and revalidated at least
every five years.
Written operating proced
ures will be reviewed at least annually.
Safe work practices, such as lockout/tagout, confined space entry,
opening process equipment or piping, and control over entrance into the
facility are implemented as needed.
If employees are involved in operating the ammonia system, they will
receive initial training and refresher training at least every three years.
Written mechanical integrity procedures have been established and
A Management of Change (MOC) program has been developed and
implemented to address all proposed changes to the ammonia system.
Pre-startup safety reviews will be performed when a modification is made
to the ammonia system that is significant enough to require a change in
the process safety information.
Audits will be conducted at least every three years to evaluate compliance
with the CalARP regulations.
Incident investigation procedures have been established.
A written plan of action regarding the implementation of employ
participation has been developed and implemented.
Hot work permits will be issued for all hot work operations conducted on or
near the ammonia system, as needed.
A Contractor Safety Policy has been developed and implemented.
To ensure that the general accidental release prevention program and the
chemical-specific prevention steps are implemented, Camp Frio Cold Storage
has assigned overall responsibility for the RMP elements to the Cold Storage
Manager. The Cold Storage Manager has the overall responsibility for the
development, implementation, and integration of the RMP elements.
Five-Year Accident History
Camp Frio Cold Storage has not had any accidental releases from the ammonia-
based refrigeration system that have resulted in deaths, injuries, or significant
property damage on site, or known offsite deaths, injuries, evacuations,
sheltering in place, property damage, or environmental damage in the last five
Emergency Response Program
Camp Frio Cold
Storage has established an emergency action plan and a chain
of command to respond to emergencies and to notify emergency responders
when there is a need for a response. However, an emergency response
program does not need to be developed for the facility since Camp Frio Cold
Storage employees will not respond to accidental releases of ammonia, the
facility is included in the community emergency response plan, and appropriate
mechanisms are in place to notify emergency responders.
Planned Changes To Improve Safety
Camp Frio Cold Storage relies on the expertise of qualified ammonia refrigeration
contractors to regularly evaluate the need for any changes to the refrigeration
equipment and to improve safety. Currently, Camp Frio Cold Storage does not
have any changes planned to improve safety associated with the ammonia