Jovista Cold Storage - Executive Summary
EXECUTIVE SUMMARY |
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.
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.
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
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
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.