Sun Pacific Lerdo Highway Cold Storage facility - Executive Summary

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Accidental Release Prevention and Emergency Response Policies 
Sun Pacific utilizes anhydrous ammonia in the refrigeration system at their cold  
storage facility east of Shafter, California.  It is Sun Pacifics policy to comply with  
all applicable governmental regulations.  Further, it is Sun Pacifics objective to  
be a responsible citizen of the community in all of its business activities. 
Sun Pacific emphasizes safe and environmentally sound operating practices and  
procedures through their employee training programs.  In addition to job specific  
training, operators and maintenance personnel receive training in accident  
prevention, safety, and first aid.  Additionally, an emergency action plan has been  
prepared for Sun Pacific and a chain of command to respond to emergencies has  
been established. 
Sun Pacific has developed a detailed Compliance Audit Checklist which is used  
to evaluate compliance with the Process Safety Management (PSM) and 40 CFR  
68 (RMP regulations).  At least every three years, Sun Pacific audits these  
programs and any findings of noncompliance are documented and responded to  
and the deficiencies are corrected. 
Description of the Stationary Source and Regulated Substances  
Sun Pacific owns and operates a cold storage facility located at 33374 Lerdo  
Highway.  Shafter is the closest city to the Sun Pacific Lerdo Highway Cold  
Storage facility.  The plant was constructed in 1988.  The refrigeration system  
has been upgraded several times, with the last expansion completed prior to  
September 1, 1992. 
At Sun Pacific, anhydrous ammonia is used in the refrigeration system which  
provides process cooling for the cold storage facility.  The system consists of a  
high pressure receiver, six evaporative condensers, four compressors, three  
recirculation accumulators, and numerous evaporators.  The three recirculation  
accumulators and evaporator units provide cooling to the cold storage rooms and  
the pre-cool/de 
greening rooms.  Flooded evaporators are utilized in the  
degreening room.  The halls and truck dock areas are cooled by direct expansion  
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 20,987 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 concentration below which it is believed that  
nearly all individuals could be exposed for up to one hour without experiencin 
g or  
developing irreversible or other serious health effects or symptoms which could  
impair an individuals 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 Sun Pacifics 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 d 
istance the  
release would travel with concentrations at or above the 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 Sun Pacific, 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 failure of one  
of the pump seals was identified in the PHA as having a medium probability of  
occurrence with a possible high discharge rate, and therefore, was chosen as the  
alternative release scenario.     
Sun Pacific 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 within the engine room, the  
plume would travel 1.2 miles at concentrations at or above the endpoint.  Using  
1990 Census data, the population potentially affected within the worst-case  
release scenario circle is 48 persons.  There were no sensitive receptors or  
environmental receptors within the worst case release scenario circle. 
In the alternative release scenario, a failure of the pump seal was modeled as a  
release of liquefied ammonia stored under pressure.  For a release of 580 lb/min  
of anhydrous ammonia within the engine room, the model calculated tha 
t the  
plume would travel 0.1 mile at concentrations at or above the endpoint.  No  
residences are located within the 0.1 mile area around the Sun Pacific 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.  
The ammonia refrigeration equipment, except for the evaporative condensers, is  
located within a building, which would greatly reduce the impact of a release.   
The modeling performed as part of this offsite consequence analysis includes a  
mitigation factor which assumes that the release is within an enclosed space, in  
direct contact with the outside air. 
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 Sun Pacific to address the  
anhydrous ammonia system.  The P 
SM 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 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 have been developed and implemented. 
    Each employee involved in operating the ammonia system has received  
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 chan 
ges 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 have 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, Sun Pacific has assigned  
overall responsibility for the RMP elements to the General Manager.  The  
General Manager has the overall responsibility for the development,  
implementation, and integration of the RMP eleme 
Five-Year Accident History 
Sun Pacific 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 
Sun Pacific 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 Sun Pacific 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 
Based on the PHAs performed in October, 1998, the following changes were  
recommended and will be impleme 
nted by December, 1999. 
1)    Installation of ammonia detectors in the engine room and key process  
2)    Installation of an actuator on the 4 inch suction ball valve so that the pump  
can be isolated from the accumulator with a remote switch outside of the  
accumulator room in the event of a seal failure (i.e. motor operated valve  
for isolation). 
3)    Consider installation of PSV between block valve and solenoid valve on  
liquid line associated with accumulator #3. 
Through the accidental release prevention program, Sun Pacific regularly  
evaluates the need for any changes to improve safety.  Currently, Sun Pacific  
does not have any additional changes planned to improve safety other than the  
above listed items.  
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