Jovista Cold Storage - Executive Summary

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Accidental Release Prevention and Emergency Response Policies 
Lucich Farms utilizes anhydrous ammonia in the refrigeration system at their  
Jovista Cold Storage facility northeast of Delano, 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 applicable  
Uniform Building and Uniform Mechanical Codes at the time of construction.   
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 at the Jovista Cold Storage facility.  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 the Jovista Cold Storage facility 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 the Jovista Cold Storage facility located at 369  
Road 176.  Delano is the closest city to the Jovista Cold Storage facility.  The  
rural plant was originally constructed during 1978 utilizing all new equipment at  
the time of construction.  In 1985, five additional cold storage rooms were added  
to the Jovista Cold Storage facility.   
Anhydrous a 
mmonia is used as the refrigerant that provides cooling for the  
Jovista Cold Storage facility.  The refrigeration system currently consists of a  
suction accumulator with a liquid transfer system, four compressors, three  
evaporative condensers, two high pressure receivers, six pre-cooler rooms, nine  
cold storage rooms, and the associated hallway, staging and shipping areas.   
Roof mounted accumulators are utilized to feed the flooded evaporators in the  
pre-cooler rooms, cold storage rooms, and the hallway, staging and shipping  
During normal operation, the anhydrous ammonia is distributed throughout the  
refrigeration system.  However, during major maintenance activities, the  
refrigeration system can be "pumped down" to evacuate the ammonia from the  
system and store it in the high pressure receivers.  The maximum quantity of  
ammonia that can be stored in the largest high pressure receiver is 20,447  
Worst Case Release Scenario and Alternative Rel 
ease 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 ammonia-based refrigeration system at the Jovista Cold Storage facility 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 recepto 
rs must be  
identified.  For purposes of the offsite consequence analyses, the RMP  
regulations define the toxic endpoint for anhydrous ammonia as 0.14 mg/l (200  
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 o 
ffsite impact.  A leak from a  
valve packing was identified in the PHA as having a medium probability of  
occurrence with a discharge rate high enough 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 20,447 lbs. of ammonia over a 10 minute 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 81  
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 isolatio 
n valve located  
outdoors was modeled as a release of liquefied ammonia stored under pressure.   
For a release of 11 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 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 technolog 
y 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 every 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 are implemented as needed. 
    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  
    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 re 
quire 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, 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-base 
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.  
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