Ducor Cold Storage - Executive Summary |
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A. Accidental Release Prevention and Emergency Response Ducor Cold Storage ("DCS") accidental release prevention policy involves a unified approach that integrates technologies, procedures and management practices. It is the policy of Ducor Cold Storage to adhere to all applicable Federal, State and local environmental and safety laws and regulations. DCS 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 DCS is located at Divizich and Carlisle Street, in the town of Ducor, Tulare County, California. DCS is a cold storage facility and utilizes anhydrous ammonia (CAS # 7664-41-7) as a refrigerant. Ammonia is the only regulated substance at DCS in quantities over the threshold limit. The quantity of anhydrous ammonia in the refrigeration system at DCS is 53,500 pounds. C. Worst-Case and Alternative Release Scenarios EPA gu idelines for determining the worst-case release scenario were applied. The worst case release scenario asumed the release of ammonia from the single largest vessel (receiver) as a gas over 10 minutes. Dispersion analysis was conducted using the public domain code DEGASIS. The distance to EPA end-point for the worst case release scenario at DCS was off-site. The worst case release scenario is unlikely because the company has employed the following control and mitigation measures. Industry standards and quality controls were followed in the design of the equipment at its manufacture. The ammonia refrigeration system was installed to codes and good practices at the time of the installation and when upgrades were completed. 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 the sight glass on the ammonia receiver was the alternative scenario that could have the greatest impact outside of BCS. The release will be as a flashing liquid or a "two-phase flow". The release rate was calculated using methodology due to Fauske and Epstein, and was modeled as a ground level release for a 10 minute duration. Dispersion modeling was done using DEGASIS. The distance to the end-point for this scenario was determined to be off-site. D. General Accidental Release Prevention Program DCS accident 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 DCS prevention program is in accordance with OSHA's process safety management PSM rules. DCS complies with: 7 Applicable California safety laws and regulations 7 International Institute of Ammonia refrigeration (IIAR) standards for good work practices 7 Applicable local fire Codes and California laws and regulations for the handling of hazardous materials. E. Five-Year Accident History DCS has not had any accidents involving anhydrous ammonia in the last five years. F. Emergency Response Program DCS emergency response program . It includes procedures for general facili ty response as well as ammonia release response. The plan 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 DCS are trained in appropriate response to hazardous material releases with emphasis on anhydrous ammonia. G. Planned changes to improve safety DCS will continue to ensure that its employees are properly trained, and that all safety processes and procedures are followed. |