Copeland Beverage Group, Inc. - Executive Summary |
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1. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The facility uses ammonia as a refrigerant within two closed systems which are treated here as one refrigeration process. Ammonia is a hazardous substance that must be handled properly in order to prevent accidental releases and injuries. It is the policy of Copeland Beverage Group to conduct all operations (including the ammonia refrigeration process) in a safe manner. This policy extends to all employees and contractors at the facility. Copeland Beverage Group implements this policy towards chemical and general safety through on-going employee participation, training, operating procedures, maintenance, inspections, safety committee meetings, and safety reviews/evaluations. These programs are in effect at the facility to prevent the accidental release of ammonia. In the event of an ammonia accident, the facility has an Emergency Action Plan to notify the appropriate authorities and safely evacuate the facility. 2. STATIONARY SOURCE AND REGULATED SUBSTANCES HANDLED The facility is located at 231 E. 23rd Street in Los Angeles, California. The Harbor Freeway (110) is approximately one kilometer (0.6 miles) west of the facility while the Santa Monica Freeway (10) is approximately 0.25 kilometers (0.2 miles) to the north. Prior to 1986 the facility was owned by the Knudsen Corporation. From 1986 to 1998, the facility was owned by Santee Dairies, Inc. In 1998, the facility was sold to the Copeland Beverage Group, Inc. The area immediately surrounding the facility is commercial/industrial with residential areas to the south and east. The primary business of the Copeland Beverage facility is to provide refrigeration for products during processing and to provide refrigerated storage facilities for food products. In order to conduct operations, the facility maintains two refrigeration systems containing approximately 45,000 pounds in total of anhydrous ammonia, a regulated substance. For the purpose of this RMPlan, the two systems are treated as one process. The refrigeration process, consists of piping, valves, and equipment, cycles ammonia through various physical states (high pressure liquid, low pressure liquid, low pressure vapor, high pressure vapor, and then back to high pressure liquid) in order to provide refrigeration for the processing and storing food products. Typical operating conditions range from 30 psig on the low pressure side of the system to 150-160 psig (approximately 90 F) on the high side of the system. 3. HAZARD ASSESSMENT SUMMARY (WORST CASE & ALTERNATIVE RELEASE SCENARIOS) A Hazard Assessment was conducted for the facility to determine the potential impacts to the surrounding community due to an accidental release of ammonia. The Hazard Assessment modeled two scenarios: a worst case and an alternate release scenario. As part of this analysis, the Emergency Response Planning Guidelines concentration level 2 (ERPG-2) was used as a toxic en dpoint to quantify off-site impacts for the facility. The ERPG-2 was developed to provide estimates of concentration ranges within which adverse health effects can be observed. Worst Case Release Result Summary: The worst case release scenario is a release of the total quantity of ammonia stored in the largest vessel at the facility, taking into account administrative controls that limit the maximum quantity in that vessel. The Main Engine Accumulator can contain a maximum amount of 20,600 pounds of ammonia. In accordance with the RMP regulation, the release duration is over a 10 minute period. The release rate is found by taking the maximum quantity released, divided by the release time (10 minutes). Note, the release rate did not include any administrative controls or mitigations to limit the amount of ammonia released. For analyzing the worst case release scenario, EPA requires the use of the most pessimistic meteorological conditions that will allow for the maximum downwin d exposure. Low wind speeds (1.5 m/s) and stable conditions (F stability) will allow the gas cloud to travel as far as possible by limiting cloud dispersion. The results will be conservative. EPA's "Risk Management Program Guidance for Ammonia Refrigeration", November 1998, Exhibit 4-4 for urban releases was used to find the downwind distances for the worst case release. The RMP*Comp Model developed by the National Oceanic and Atmospheric Administration and EPA was used to prepare the data in this guidance document. This guidance document for Ammonia Refrigeration was used to ensure consistency throughout the industry. This release reaches off site and may impact population receptors. No environmental receptors were affected by this potential release. Note, the worst case scenario is considered to be an unlikely event since the vessel is equipped with a level control, a high level switch, and two liquid transfer vessels which transfer liquid from the accumulator to other (smal ler) vessels. Alternate Release Result Summary The alternative release scenario chosen for this facility is that of a 0.25 inch diameter orifice leading to an airborne release, representative of a pump seal leak, a gasket rupture, pinhole leak due to corrosion, flange seal leak, valve bonnet seal leak, etc. It is assumed that this release is from the high side of the system; therefore at a pressure of approximately 150 psig. This release scenario will be assumed to last one hour, thereby incorporating mitigation measures such as the emergency response plan and actually shutting down the system. The release rate was calculated (using a simplified version of the Bernoulli equation) as 122 lbs/min. The quantity of ammonia released in one hour at this rate is 7,320 pounds. EPA allows a facility to use typical meteorological conditions at the facility. For this scenario, a wind speed of 3 meters/second and neutral conditions, D stability, were used for an urban area. EPA's "Risk Mana gement Program Guidance for Ammonia Refrigeration", Exhibit 4-5 for D Stability, Wind Speed 3.0 Meters per Second", was used to find the downwind distance for the alternate release scenario. This release reaches off site and may impact population receptors. No environmental receptors were affected by this potential release. 4. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS In order to operate the ammonia refrigeration system, the facility must comply with the following state and federal risk management regulations: 1) OSHA's Process Safety Management (PSM); 2) EPA's Risk Management Program (RMP); and 3) California's Accidental Release Prevention Program (CalARP). These regulations impose numerous requirements on the facility to ensure the safety of the public and on-site workers. The following summarizes the key compliance programs that have been implemented by Copeland Beverage Group to prevent the accidental release of ammonia from the facili ty. The Operating Procedures program ensures that the ammonia system is operated in a safe manner. The Training program ensures that personnel fully understand how to perform their jobs in a safe manner. The Mechanical Integrity program ensures that the ammonia system is in proper working condition based upon routine testing, inspections, and maintenance according to manufacturer's specifications and industry standards. The Management of Change program ensures that process modifications are implemented in a safe manner. The Pre-Startup Safety Review program ensures that adequate safety measures are in place before ammonia is introduced into a process. The Hot Work Permit program ensures that Copeland Beverage Group's employees and contractors perform hot work (e.g. welding) in a safe manner. The Contractor Safety program ensures that contractors understand the hazards of ammonia and must take specified precautions to safely complete job requirements. It is important to note tha t the refrigeration process has been designed with several safety features to prevent the accidental release of ammonia. For example, the compressors are equipped with safety mechanisms that will cause the units to shut down if operating conditions exceed designated safety limits. Also, level indicators, alarms, and switches are installed in key points within the system to monitor the supply of liquid ammonia and to ensure that a vessel is not overfilled. 5. FIVE YEAR ACCIDENT HISTORY There have been no reportable releases of ammonia from the facility within the last five years (June 21, 1994 through June 21, 1999). 6. EMERGENCY RESPONSE PROGRAM The facility has an Emergency Action Plan (Plan) in effect at the facility. This Plan was designed to meet the following objectives: 1) save lives; 2) minimize and avoid injuries; 3) protect the environment; and 4) minimize property damage. Since facility personnel will not respond to any ammonia release at the facility that poses a health or safety threat, the Plan provides the notification procedures and evacuation routes for emergencies that may arise at the facility. This Plan is reviewed and updated at least once per year to ensure compliance with the PSM, RMP, and CalARP regulations. Facility personnel receive annual training regarding the emergency procedures. 7. PLANNED CHANGES TO IMPROVE SAFETY The ammonia refrigeration process is periodically evaluated for safety hazards. For example, the following methods have been used to evaluate the safety of the refrigeration systems: 1) a Hazard and Operability (HAZOP) study; 2) a What If Analysis; 3) a seismic assessment; 4) a series of safety checklists; and 5) on-going monthly safety committee meetings. As part of the RMP development process, several procedural/managerial recommendations were made to improve the overall safety of the system. These recommendations are planned to be complete by June 2000. |