Jakov P. Dulcich & Sons Cold Storage - Executive Summary

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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  
flooded evaporators.   
During normal operation, the anhydrous ammonia is distributed thr 
oughout the  
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 
Offsite conse 
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  
Prevention Steps 
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.
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