Jim Hronis & Sons - Executive Summary |
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EXECUTIVE SUMMARY 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 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 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 identified. 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 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, 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 implemented. ? 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 History 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. |