Lucich Farms Cold Storage - Executive Summary |
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EXECUTIVE SUMMARY Accidental Release Prevention and Emergency Response Policies Lucich Farms utilizes anhydrous ammonia in the refrigeration system at their cold storage facility east of Shafter, California. As it is Lucich Farms' 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. Conformance with these code requirements ensures that the building and refrigeration system meet specific design and installation requirements that reduce the risk of accidental releases. Personnel from Lucich Farms monitor the daily operation of the refrigeration system. All major 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 major service, maintenance, and repairs ensures that the equipment is in excellent operating condition. While it is Lucich Farms' 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 Lucich Farms and a chain of command to respond to emergencies has been established. Description of the Stationary Source and Regulated Substances Lucich Farms owns and operates a cold storage facility located at 17808 Zerker Road. Shafter is the closest city to the Lucich Farms Cold Storage facility. The cold storage facility was constructed in 2000 utilizing all new equipment at the time of construction. Anhydrous ammonia is used as the refrigerant that provides process cooling for the Lucich Farms Cold Storage facility. The refrigeration system consists of a suction accumulator with a liquid transfer system, three compressors, two evaporative condense rs, a high pressure receiver, a glycol chiller, a large pre- cooler room, four cold storage rooms, and the associated hallway, staging and shipping areas. Roof mounted accumulators supply liquid ammonia to the flooded evaporators in the pre-cooler room, cold storage rooms, and the hallway, staging and shipping areas. Refrigerated glycol is circulated from the engine room glycol chiller to the evaporator in the electrical room for space cooling. 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 high pressure receiver is approximately 21,000 pounds. Worst-Case Release Scenario and Alternative Release Scenario Offsite consequence analyses are used as tools to assist in emergency respons e 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 Lucich Farms' 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 endpoint. The circle also defines the area in which potential environmental receptors must be identified. For purposes of the offsite consequence analyses, the RMP regulations define the toxic endpoint for anhy drous ammonia as 0.14 mg/l (200 ppm). 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 Lucich Farms, 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 PHA as having a medium probability of occurrence with a discharge rate high en ough to cause an offsite consequence, and therefore, was chosen as the alternative release scenario. Lucich Farms has analyzed the offsite consequences of the worst-case and alternative release scenarios. For the worst-case release scenario, the release of 21,000 lbs. of ammonia over a 10 minutes period, 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 96 persons. Due to the rural location of this facility, the population potentially affected by this worst case release may be 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 packing leak from an isolation valve located outdoors was modeled as a release of liquefied ammonia stored under pressure. For a release of 12 lb/min of anhydrous ammonia, the model calc ulated 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 Lucich Farms facility. As such, there would be no population impacts from the alternative release scenario. There were also no 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, has been developed at Lucich Farms 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 has been compiled. ? An initial Process Hazard Analysis (PHA) was performed and will be updated and revalidated at least eve ry five years. ? Written operating procedures have been developed and implemented, and are 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 have been developed and implemented. ? Each employee involved in operating the ammonia system has received initial training and will receive 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 safety reviews are performed when a modification is made to the ammonia system that is significant enough to require a change in the process safety information. ? Audits are conducted at least every three years to evaluate compliance with the CalARP regulations. ? Incident investigation procedures hav e been established. ? A written plan of action regarding the implementation of employee participation has been developed and implemented. ? Hot work permits are issued for all hot work operations conducted on or near the ammonia system. ? 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, Lucich Farms has assigned overall responsibility for the RMP elements to the Purchasing Manager. The Purchasing Manager has the overall responsibility for the development, implementation, and integration of the RMP elements. Five-Year Accident History Lucich Farms 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 Lucich Farms 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 Lucich Farms 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 Lucich Farms does not currently have any additional changes planned for the ammonia refrigeration system to improve safety. |