Marinovich Cold Storage - Executive Summary |
|
EXECUTIVE SUMMARY Accidental Release Prevention and Emergency Response Policies Marinovich Cold Storage, Inc. utilizes anhydrous ammonia as the refrigerant in their cold storage facility in Pajaro, California (near Watsonville). It is Marinovich Cold Storage, Inc.'s policy to comply with all applicable governmental regulations. Further, it is Marinovich Cold Storage, Inc.'s objective to be a responsible citizen of the community in all of its business activities. Marinovich Cold Storage, Inc. emphasizes safe and environmentally sound operating practices and procedures through their employee training programs. In addition to job specific training, operators and maintenance personnel receive training in accident prevention, safety, and first aid. Additionally, an emergency action plan has been prepared for Marinovich Cold Storage, Inc. and a chain of command to respond to emergencies has been established. Marinovich Cold Storage, Inc. has developed a detailed Compliance Audit Checklist which is used to evaluate compliance with Process Safety Management (PSM) and 40 CFR Part 68 (RMP regulations). At least every three years, Marinovich Cold Storage, Inc. audits these programs and any findings of noncompliance are documented and responded to and the deficiencies are corrected. Description of the Stationary Source and Regulated Substances Marinovich Cold Storage, Inc. owns and operates a cold storage facility located at 303A Salinas Road in Pajaro, California. There are two refrigeration systems currently at the facility, the original (or main) refrigeration system and a second system based in engine room #2. The original refrigeration system was installed in 1946. The second refrigeration system (based in engine room #2) was installed in 1970. Both refrigeration systems have been upgraded and modernized several times over the years. In both of the refrigeration systems at Marinovich Cold Storage, Inc., anhydrous ammonia is used as t he refrigerant that provides process cooling for the cold storage facilities. Although the systems normally operate independently, it is possible to shut down engine room #2 and operate the cold storage rooms serviced by engine room #2 from the main refrigeration system. During normal operation, the anhydrous ammonia is distributed throughout the refrigeration system. However, during major maintenance activities, portions of the 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 in the original (main) refrigeration system is 4,930 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 tools 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 Marinovich Cold Storage, Inc.'s ammonia-based refrigeration systems are considered Program 3 processes, 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 endpoint. The circle also defines the area in which potential environmental receptors must be identified. The worst case release is defined by the U.S. EPA as 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 Marinovich Cold Storage, Inc., 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 failure of one of the pump seals was identified in the PHA as having a medium probability of occurrence with a possible high discharge rate, and therefore, was chosen as the alternative release scenario. Marinovich Cold Storage, Inc. has analyzed the offsite consequences of the worst-case and alternative release scenarios. For the worst-case release scenario, the release of 4,930 lbs. of ammonia over a 10 minute period within the engine room, the plume would travel 0.6 miles at concentrations at or above the endpoint. Using 1990 Census data, the population potentially affected within the worst-case release scenario circle is 899 persons. Sensitive receptor information is provided in the RMP*Submit forms. There were no environmental receptors within the worst case release scenario circle. In the alternative release scenario, the failure of a pump seal was modeled as a release of liquefied ammonia stored under pressure. For a release of 350 pounds of ammonia at a rate of 7.3 lb/min of anhydrous ammonia within a building, the model calculated that the plume would travel 0.1 mile at concentrations at or above the endpoint. Using 1990 Census data, the population potentially affected within this alternative release scenario circle is 62 persons. There were no environmental receptors within the alternative release scenario circle. All of the refrigeration equipment involved in the above described release scenarios is physically located within buildings. As such, the results of the dispersion modeling performed as part of this offsite consequence analysis incorporate a mitigation factor which assumes that the release is within an enclosed space, in direct contact with the outside air. General Accidental Release Preven tion Program and Chemical-Specific Prevention Steps A PSM program, which meets the requirements of the general accidental release prevention program, has been developed at Marinovich Cold Storage, Inc. 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 has been compiled. An initial Process Hazard Analysis (PHA) was performed and will be updated and revalidated at least every five years. Written operating procedures have been developed and implemented, and are 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 have been developed and implemented. Each employee involved in operating the ammonia system has received in itial training and refresher training at least every three years. Written mechanical integrity procedures have been established and implemented. A Management of Change (MOC) program has been developed and implemented to address all proposed changes to the ammonia system. Pre-startup safety reviews are performed when a modification is made to the ammonia system that is significant enough to require a change in the process safety information. Audits are 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 employee participation has been developed and implemented. Hot work permits are issued for all hot work operations conducted on or near the ammonia system. A Contractor Safety Policy has been developed and implemented. To ensure that the general accidental release prevention program and the chemical-specifi c prevention steps are implemented at Marinovich Cold Storage, Inc., the owner has accepted the overall responsibility for the RMP. The owner has the overall responsibility for the development, implementation, and integration of the RMP elements. Five-Year Accident History Marinovich Cold Storage, Inc. 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 years. Emergency Response Program Marinovich Cold Storage, Inc. 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 Marinovich Cold Storage, Inc. employees will not respond to accidental rel eases 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 Based on the PHAs performed in October, 1994, the following changes were recommended and were implemented by February, 1999. 1) Installation of a flow switch in the cooling water line to the compressors that shuts off the compressors in the engine room if cooling water is lost. 2) Installation of seismic bracing for the ammonia refrigeration equipment. In addition to the safety improvements based on the October 1994 PHA, Marinovich Cold Storage, Inc. has installed ammonia detection systems in both engine rooms. These detectors will operate newly installed electric solenoid king valves on the high pressure receivers. The electric solenoid king valves can also be activated with manual switches located outside of the engine rooms. Marinovich Cold Storage, Inc. is also in the process of installing an ammonia diffusion system for the refrigeration system. The installation of the diffusion system will be completed in early 2000. Through the accidental release prevention program, Marinovich Cold Storage, Inc. regularly evaluates the need for any changes to improve safety. Currently, Marinovich Cold Storage, Inc. does not have any additional changes planned to improve safety other than the above listed items. |