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. In October 2000, the facility added new freezer and cooler rooms which required additional evaporators (10), compressors (2), and condenser (1). 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 19,100 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) an d 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 calculated 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 met ers per second wind speed, and D stability. The reference table, Exhibit 4-5, 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 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 including 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 The initial Process Hazard Analysis study (including a HAZOP study and What-If Walkthrough) was performed on July 28, 1999 at Telco Food Products, Inc. There were several mitigation measures recommended at that time. The majority of those recommendations were completed by June 2000. Some of the mitigation measures implemented included the following items: * Conduct periodic tests on the ammonia detectors and calibrate per manufacturer's specifications every six months, with a calibration check done every two to three years. * Ensure that the ammonia detectors are equipped with a back up power supply (i.e. generator, batteries). * Obtain a 10 foot ladder for machine room. * Provide secondary plastic containment for 55 gallon waste oil drum for oil draining. * Include in Mechanical Integrity program a test of the level floats/switches in the Receivers. * Ensure lockout/tagout procedures are in place when cleaning the condenser. * Incorporate a check of the pH o f the water dilution tank into the Mechanical Integrity program to discover any ammonia releases. * Install an alarm light outside of the machine room to indicate an ammonia leak. * Install eye wash/safety shower outside of the machine room. * Install wind direction indicators visible from the exit routes, the road, and the assembly points. * Label important valves. * Ensure that the power to the exhaust fans in the machine room are de-energized at a shut off of 10,000 ppm. |