Jakov P. Dulcich & Sons Cold Storage - Executive Summary
EXECUTIVE SUMMARY |
Accidental Release Prevention and Emergency Response Policies
Jakov P. Dulcich & Sons utilizes anhydrous ammonia as the refrigerant in their
cold storage facility near McFarland, California. As it is Jakov P. Dulcich & Sons'
policy to comply with all applicable governmental regulations, the cold storage
facility was designed and constructed during 1995-96 to the 1991 Uniform
Building Code/Uniform Mechanical Code. Jakov P. Dulcich & Sons 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 condition.
While it is Jakov P. Dulcich & Sons' objective to be a responsible citizen of the
community in all of its business activities
, the limited staff at the cold storage
facility precludes emergency response operations. As such, an emergency
action plan has been prepared for Jakov P. Dulcich & Sons and a chain of
command to respond to emergencies has been established.
Description of the Stationary Source and Regulated Substances
Jakov P. Dulcich & Sons owns and operates a cold storage facility located at
31956 Peterson Road. McFarland is the closest city to the Jakov P. Dulcich &
Sons Cold Storage facility. The rural plant was constructed during 1995-96
utilizing all new equipment at the time of construction.
Anhydrous ammonia is used as the refrigerant that provides process cooling for
the Jakov P. Dulcich & Sons 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
During normal operation, the anhydrous ammonia is distributed thr
refrigeration system. 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
quence 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 Jakov P. Dulcich & Sons' ammonia-based refrigeration system 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 i
s 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 Jakov P. Dulcich & Sons, 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. Although not likely to occur, a release from a pressure relief valve was
chosen as the alternative release scenario.
Jakov P. Dulcich & Sons has analyzed the offsite consequenc
es 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 233 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 release from a pressure relief valve was
modeled as ammonia vapor stored under pressure. For a release of 158.7 lb/min
of anhydrous ammonia to the atmosphere, the model calculated that the plume
would travel 0.1 mile at concentrations at or above the endpoint. No residences
are located within the 0.1 mile area aro
und the Jakov P. Dulcich & Sons 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 Jakov P. Dulcich & Sons 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 procedures will be reviewed at least annually.
? Safe work practices, such as lockout/tagout, confin
ed 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 employee
participation has been developed and implemented.
? Hot work permits will be issued for al
l 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, Jakov P. Dulcich & Sons
has assigned overall responsibility for the RMP elements to a partner in the firm.
The partner has the overall responsibility for the development, implementation,
and integration of the RMP elements.
Five-Year Accident History
Jakov P. Dulcich & Sons 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
Jakov P. Dulcich & Sons has established an emergency action plan and a chain
of command to respond to emergencies and to no
tify 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 Jakov P. Dulcich &
Sons 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
Jakov P. Dulcich & Sons 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, Jakov P. Dulcich &
Sons does not have any changes planned to improve safety associated with the
ammonia refrigeration system.