Jody Cold Storage - Executive Summary
Jody Cold Storage |
EPA RMP Facility ID #: 1000-0012-0326
Jody Cold Storage is a fresh fruit packing and storage facility. The facility is located in Dinuba, California, a rural section of Tulare County. The facility occupies approximately five acres and is boarded on all sides by vineyards and/or fruit tree orchards. Jody's business is seasonal, with increased activity during the growing season, generally from mid-April to mid-November.
Jody's facility includes a refrigeration system which is required to maintain proper storage temperature. The refrigeration system utilizes anhydrous ammonia as its refrigerant. Anhydrous ammonia is widely regarded as the most efficent refrigerant on the market. Anhyrdous ammonia is however a toxic material, and is subject to both California State and Federal accident prevention regulations. These regulations require the development and implementation of a Risk Management Program (RMP).
Jody Cold Storag
e is committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accident release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training.
State and Federal accident prevention regulations require that Jody Cold Storage complete an analysis of the potential affects of hypothetical accidental release scenarios, including a worst-case scenario and an alternative release scenario.
As defined by the USEPA, the worst-case scenario must assume failure of the largest vessel in the refrigeration system. EPA also requires us to assume that any design safety systems fail to operate. In fact, the worst-case scenario requires us to assume that several highly unlikely event occur simultaneously, such as:
- Catastrophic failure of a storage vessel
- Failure of all automated safety and alarm systems
- Failure of our trained and experienced operators to
respond appropriately; and,
- The event occurs during least likely stagnant meterological conditions.
Jody Cold Storage utilized guidance provided by the USEPA, specific to the ammonia refrigeration industry, in completing its hazard assessment. This worst-case scenario assumes failure of the high pressure receiver, resulting in the loss of containment of 16,000 pounds of ammonia. This scenario does account for containment due to the fact that the receiver is located in a machinery room, which would help to reduce the release rate to the atmosphere. The worst-case scenario does impact the surrounding area.
USEPA also requires an evaluation of an alternative release scenario, considered an event more likely than the worst-case scenario. The alternative release scenario considered overpressurization of a compressor and release of ammonia vapor through a pressure relief valve to the atmosphere. The alternative release scenario assumes a release of 690 pounds over a four minute pe
riod. The alternative release scenario also has an impact on the surrounding area.
Jody Cold Storage has not had any significant releases or accidents associated with the ammonia refrigeration system during the five year review period. A significant release includes incidents resulting in off-site injuries, environmental impact, or evacuations, or on-site injuries or significant property damage.
RISK MANAGEMENT PROGRAM
Jody Cold Storage has developed programs to comply with required environmental, health, and safety standards. Jody has adopted a systematic, proactive approach to preventing accidental releases of ammonia through its Risk Management Program.
Jody's Risk Management Program includes programs and procedures addressing the following areas:
- Employee Participation
- Process Safety Information
- Process Hazard Analysis
- Standard Operating Procedures
- Preventive Maintenance Program
- Operator Training
- Accident Investigation Program
Management of Change
- Pre-Startup Review
- Hot Work Permit Program
- Contractor Safety
- Compliance Audits
In addition to our management programs, the refrigeration system includes controls, alarms, and safety interlocks designed to monitor and automatically shutdown the system under emergency situations.
EMERGENCY ACTION PLAN
Jody has a written emergency action plan in the event an ammonia release, and to address other emergencies. Jody has established a relationship with the Tulare County Fire Department, the first responding agency in the event of an emergency. Fire Officials have toured the facility and familiarized themselves with our emergency systems. Jody has also arranged for 24-hour service and response from a trained and qualified ammonia refrigeration contractor in the event of a system emergency.
PLANNED CHANGES TO IMPROVE SAFETY
A detailed process hazard analysis of the ammonia refrigeration system was conducted in August 1999. The process hazard an
alysis identified 35 recommendations designed to reduce the possibility of an ammonia incident or to mitigate the consequences of an ammonia incident. Jody is committed to resolving each of these recommendations by September 2000.
Please contact Joe Peacock, Safety Coordinator for additional information regarding this submission.