Bakersfield Cold Storage - Executive Summary |
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A. Accidental Release Prevention and Emergency Response Bakersfield Cold Storage (" BCS") accidental release prevention policy involves a unified approach that integrates technologies, procedures and management practices. It is the policy of Bakersfield Cold Storage complies with all applicable Federal, State and local environmental and safety laws and regulations. BCS emergency release policy involves the preparation of a response plan, and training of employees in evacuation and appropriate response to releases of ammonia. B. Facility and Regulated Substance Handled BCS is located at 6001 Snow Rd, in the city of Bakersfield, Kern County, California. BCS is a cold storage facility and utilizes anhydrous ammonia (CAS # 7664-41-7) as a refrigerant. Anhydrous ammonia is the only regulated substance at BCS in quantities over the threshold limit. The quantity of anhydrous ammonia in the refrigeration system at BCS is 60,000 pounds. C. Worst-Case and Alternative Release Scenar ios EPA guidelines for determining the worst-case release scenario were applied. The worst case release scenario is based on the release of ammonia from the receiver (north or south). It assumes that the total quantity of ammonia in the single largest vessel (receiver) is released as a gas over 10 minutes. Dispersion analysis was conducted using the public domain code DEGASIS. The distance to the end-point for the worst case release scenario at BCS was determined to be off-site. The two methods used to estimate the population that could be impacted by a release (Block group centroid method and Block group Proration method) gave strikingly different results. An average of the two results, validated by an inspection of the area, was used to estimate the number of people that could be impacted by a release. The worst case release scenario is unlikely because the company has employed the following control and mitigation measures. Industry standards and quality controls were followe d in the design of the equipment at its manufacture. Pressure safety valves limit the operating pressures in the receiver. The facility utilizes a preventive maintenance program to maintain the on-going integrity of the vessel The facility has a training program that insures that only qualified personnel operate the system The facility has trained personnel and procedures on site to respond quickly to isolate any potential releases Only trained and authorized personnel have access to the system The maintenance program includes a mechanical integrity audit system The facility has a process control system that will automatically shut down the system and autodial in the event that normal operating procedures are exceeded. Low level controls, high level controls and sensors for ammonia monitoring would act as active mitigation before the event reaches the levels that would bring about the above scenario. Alternative releases were also considered. A release resulting from failure of t he sight glass on the ammonia receiver was the alternative scenario that could have the greatest impact outside of BCS. In this scenario it is assumed that the 1-1/4 inch line at the hydrocooler fails, and as a result ammonia is release to the atmosphere. The release will be as a flashing liquid or a "two-phase flow". The dispersion modeling was done using DEGASIS for a ground level heavy gas release. The distance to the end-point for this scenario was determined to be off-site. D. General Accidental Release Prevention Program BCS accidental release prevention program is based in the following key elements: 7 written operating procedures 7 training of personnel 7 preventative maintenance programs 7 written safety procedures and safety equipment BCS prevention program is in accordance with OSHA's process safety management PSM rules BCS complies with: 7 Applicable California safety laws and regulations 7 International Institute of Ammonia refrigeration (IIAR) standards for good work practices 7 Appplicable local fire codes and California laws and regulations for handling of hazardous material E. Five-Year Accident History BCS has not had any accidents involving anhydrous ammonia in the last five years. F. Emergency Response Program BCS emergency response program complies with the provisions of 29CFR 1910.38, and includes the following elements: 7 emergency escape procedures 7 procedures for employees to operate critical plant operations before evacuation 7 procedures to account for all employees after emergency evacuation 7 rescue and medical training for employees who perform them 7 means of reporting fires and other emergencies 7 names of persons who can be contacted for further information Employees at BCS (refrigeration personnel and management) are trained in appropriate responses to hazardous material releases with emphasis on anhydrous ammonia. G. Planned changes to improve safety BCS is currently installing new process safety con trols including new safety shutdown and dial out system. In addition, BCS plans to replace all isolation and back pressure valves this year. |