MZI McFarland Cold Storage - Executive Summary |
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Table of Contents for Executive Summary MZI Pond Road Cold Storage 1. The Marko Zaninovich, Inc., Risk & Process Safety Management Program i 2. Description of Ammonia System i 3. Ammonia Release Scenarios ii 3.1. Worst Case Scenario ii 3.2. Alternative Case Scenario ii 4. General Accident Release & Ammonia Specific Prevention Steps ii 5. Five Year Accident History ii 6. Emergency Action Plan ii 7. Planned Changes to Improve Safety iii Milestones iii 1. The Marko Zaninovich, Inc., Risk & Process Safety Management Program This is to inform all interested persons, Including employees, that Marko Zaninovich, Inc. is preparing a unified Risk & Process Safety Management Program to comply with California's Accidental Release Prevention (CalARP) Program (in California CCR Title 19, chapter 4.5, Program Level 3 Elements and Federally Title 40 CFR Part 68) and California OSHA's "Process Safety Management (PSM) of Acutely Hazardous Materials" standard (in California CCR Title 8, Section 5189, "Process Safety Management of Acutely Hazardous Materials" and Federally Title 29 Code of Federal Regulations (CFR) 1910.119). This program Is being prepared to address the risks involved with the presence of anhydrous ammonia in an amount in excess of 10,000 lbs. which is c ontained in our refrigeration system. Our Program will promote overall plant, worker and public safety. The program will enable our facility to prevent the occurrence, and minimize the consequences, of significant release of anhydrous ammonia. Overall, the program is designed to prevent accidental fatalities, injuries and illnesses and avoid physical property damage. Our company has an exemplary safety record, one that we are quite proud of. Our program incorporates and brings together several existing safety programs which already set forth rules, procedures and practices which help our employees protect themselves and our neighbors. 2. Description of Ammonia System We operate a commercial warehouse for the storage of fresh table grapes. We store all of our packed product in cold storage. Our facility has an ammonia system that provides refrigeration capacity to multiple precoolers and storage rooms. Refrigeration is provided by one engine room. In this system, high pressure liquid from a main receiver is piped to refrigeration equipment, where it passes through an expansion valve to the low pressure and temperature side of the system. The low temperature and pressure gas from refrigeration equipment is returned to it's engine room, where it passes though a compressor. The high pressure discharge from the compressor is sent to a water cooled condenser where the high pressure ammonia gas is liquefied and returned to a receiver. The ammonia system at our facility consists of vessels, which are interconnected, or which are co-located such that a release of ammonia could impact the ability to operate vessels which are not directly connected. Therefore, we are treating out facility as a single process. 3. Ammonia Release Scenarios 3.1. Worst Case Scenario Our worst case scenario is the failure of a high pressure receiver in one of our engine rooms. The vessel contains 8,900 lbs. of ammonia. The vessel is located inside the engine room and would be passively mitigated . Using RMP*Comp the estimated distance that the ammonia would travel before dispersing enough to not pose a hazard to the public is 1.5 miles (urban conditions). A map showing the area that would be affected is attached. In our opinion, it is extremely unlikely that the worst-case scenario will ever take place. Our receiver meets industry standards for manufacture and quality control of pressure vessels; ammonia is not corrosive in this service; pressure safety relief valves limit the operating pressure in this vessel; and our operators are trained in the safe operation of our system. 3.2. Alternative Case Scenario Our alternative release scenario is as follow. A high pressure safety relief valve lifts and fails to reseat. The rated release rate for our high pressure safety relief valve is 70ils/min. We assume the leak would continue for 10 minutes until the header pipe is switched over to the backup safety relieve valve. Following industry practice, our relief vales are installed in pairs with a switch over valve, and the discharge is piped to a release point that is remote from the valve. Under this scenario 700 lbs. of ammonia would be release over a time period of 10 minutes. Using RMP*Comp we estimate that ammonia would travel 0.2 miles (urban conditions) before dispersing enough to no longer pose a hazard to the public. A map showing the area that would be affected is attached. 4. General Accident Release & Ammonia Specific Prevention Steps The ammonia refrigeration system at the Marko Zaninovich, Inc. facility is an integral part of the overall business. It has a system charge of approximately 52,000 lbs. It is extremely important that it is maintained and operated in a safe and efficient manner. Management is committed to making sure that all employees are made aware of the potential danger of an ammonia leak. The ammonia refrigeration system/process is constantly being monitored by our refrigeration engineer. In addition, the system/process is checked f requently by our outside refrigeration contractor, Chillpoint Refrigeration. Who also performs an annual pre-season preventative maintenance review of our system/process equipment. Our system is completely monitored by personnel. We have on site security that also monitors our systems. Our evaporator coils are also equipped with water defrost, which can be used to absorb released ammonia. Water containing ammonia would be held in holding pond. We inform employees of the dangers of an accidental release of ammonia through monthly safety meeting. During these meetings we also discuss the preventative measures to take, such as evacuation, in order to not be affected by a release. Our ammonia refrigeration system was designed and built by professional refrigeration engineers in accordance with ANSI.IIAR 2-1992 "Standard for Equipment, Design and Installation of Ammonia Mechanical Refrigeration Systems." It was also built in compliance with Uniform Building Code and Uniform Mechanical Cod e applicable at the time of construction. Our ammonia refrigeration system is equipped with safety relief valves. These valves limit the operation pressures of the entire system, and prevent failures due to over pressurization. 5. Five Year Accident History This Marko Zaninovich, Inc. Facility has not had any reportable accidents within the last five years. 6. Emergency Action Plan This facility's emergency response program is based on the Cal OSHA requirements for Emergency Action Plans (in California CCR Title 8, Section 3220, "Emergency Action Plans" and Federally Title 29 CFR 1910.38 and 1910.119) and HAZWOPER (standard (in California CCR Title 8, Section 5192, "Hazardous Waste Operations and Emergency Response") and Federally Title 29 CFR 1910.120). Strategically, we will respond Defensively to a release. Our operator has received Defensive Training (First Responder, Operations Level) specific for ammonia response and meeting HAZWOPER criteria. Under this plan our employees will take whatever steps are necessary to bring a release under control. Initial training to the defensive level (First Responder, Operations Level) as defined in the HAZWOPER regulations will take place before the end of the year. The first priority will be to operate the ammonia system to bring a release under control safely, from a distance, without donning personal protective equipment. Steps might include stopping the flow of ammonia to a leak point. Further response requiring the donning of personal protective equipment would be done in coordination with an outside agency. All response activities would be coordinated with the local fire department and Kern County Department, Hazardous Materials Response Team. Every year at the beginning of the season we review with our employees our evacuation procedures in the event of an emergency, including an ammonia release. We have windsocks at our facility that employees can use to determine the "upwind" side of any point of release. 7. Plann ed Changes to Improve Safety As June 21, 1999, the time that this Executive Summary is being submitted, our Risk & Process Safety Management plan is not complete. The reason is that in order to do it right a lot of work must be done. We simply do not have enough qualified employees or resources to meet the initial deadline. Our company operates seasonally and we have found that our ability to allocate managerial and operator resources to prepare this plan depends upon our workload. In addition, we have found it necessary to obtain help from outside vendors for some critical elements, such as preparing Piping & Instrumentation Diagrams and conducting a Process Hazard Analysis. These vendors are attempting to meet the requests of numerous facilities such as ours at the same time, and have the same problem of only a limited number of people qualified to carry out the required tasks. Thus, these vendors are setting completion dates for plan elements that we cannot entirely control. Howeve r, we have prepared the following milestones and allotted times for the completion of our plan: Milestone Allotted Time Conduct Offsite Consequence Analysis Done Prepare RMP*Submit showing status as of 6/21/99 Done Collect Process Safety Information 30 Days 7/21/99 Conduct Process Hazard Analysis 30 Days 7/21/99 Finish PHA documentation including Action List 30 Days 7/21/99 Prepare Process Prevention Program element. 30 Days 7/21/99 Prepare Standard Operating Procedures 30 Days 7/21/99 Compile all elements into Risk & Process Safety Management Prog ram, review internally, and submit 30 Days 7/21/99 We understand our obligation to consolidate our safety activities in a Risk Management Program under the CalARP regulation. We are committed to preparing and implementing a Risk & Process Safety Management Program according to the above milestone and timeline chart. |