Jim Hronis & Sons - Executive Summary

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Accidental Release Prevention and Emergency Response Policies 
Jim Hronis & Sons utilizes anhydrous ammonia as the refrigerant in their cold  
storage facility near Delano, California.  As it is Jim Hronis & Sons' policy to  
comply with all applicable governmental regulations, the cold storage facility was  
designed and constructed in accordance with the Uniform Building and Uniform  
Mechanical Codes.   
Personnel from Jim Hronis & 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 Jim Hronis & 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 Jim Hronis & Sons and a chain of command to  
respond to emergencies has been established. 
Description of the Stationary Source and Regulated Substances  
Jim Hronis & Sons owns and operates a cold storage facility located at 32555  
Cecil Avenue.  Delano is the closest city to the Jim Hronis & Sons cold storage  
facility.  The rural plant was originally constructed during 1980 utilizing all new  
equipment at the time of construction.  Several expansions to the refrigeration  
system have been completed with the latest expansion scheduled for completion  
in late April of 2000.   
Anhydrous ammonia is used as the refrigerant that provides process cooling for  
the Jim Hronis & Sons cold storage facility.  After the April 2000 expansion is  
completed, the refrigeration system will consist of a suction accumulator with a  
liquid transfer system, five compress 
ors, two evaporative condensers, a high  
pressure receiver, 6 pre-cool rooms, 6 cold storage rooms, and the associated  
hallway/loadout dock areas.  Each of the pre-cooling rooms and cold storage  
rooms has at least one accumulator and several flooded evaporators.   
During normal operation, the anhydrous ammonia is distributed throughout 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 outdoor high pressure receiver is 19,428  
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 conc 
entration 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 Jim Hronis & 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 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 Jim Hronis & 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.  A leak  
from a valve packing was identified in the PHAs as having a medium probability  
of occurrence with a discharge rate high enough to cause an offsite impact, and  
therefore, was chosen as the alternative release scenario. 
Jim Hronis & Sons has analyzed the offsite consequences of the worst-case and  
alternative release scenarios.  For the worst-case release scenario, the release  
of 19,428 lbs. of ammonia over a 10 minute period outside of the engine room,  
the plume would travel 1.7 miles at concentrations at or above the endpoint.   
Using 1990 Census data, the population potentially affected within the worst- 
case release scenario circle is 81 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.  The public receptor 
s included  
several residences.  There were no environmental receptors within the worst  
case release scenario circle. 
In the alternative release scenario, a packing leak from an isolation valve located  
outdoors was modeled as a release of liquefied ammonia stored under pressure.   
For a release of 22 lb/min of anhydrous ammonia, the model calculated that the  
plume would travel less than 0.1 mile at concentrations at or above the endpoint.   
No residences are located within the 0.1 mile area around the Jim Hronis & Sons  
1 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 Jim Hronis & Sons to address the  
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, confined 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 saf 
ety 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 all 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, Jim Hronis & Sons has  
assigned overall responsibility for the RMP elements to one of the Partners.  The  
Partner has the overall responsibility for the development, implementation, and  
integration of the RMP elements. 
Five-Year Accident 
Jim Hronis & 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 years. 
Emergency Response Program 
Jim Hronis & Sons 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 Jim Hronis & 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 
Jim Hronis & 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, Jim Hronis & Sons does not have  
any changes planned to improve safety associated with the ammonia  
refrigeration system.
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