Cascade Hilltop LLC - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The Cascade Hilltop facility abides by the emergency response procedures and policies detailed in the Response Plan for On-Site Emergency Operations manual. This Plan was designed to meet the following objectives: 1.) To save lives. 2.) To minimize and avoid injuries. 3.) To protect the environment. 4.) To minimize property damage. Cascade maintains an emergency response committee whose members are the designated emergency coordinators for the facility. The Plan provides the response organization and notification procedures, evacuation routes, ammonia health hazards, and mitigation procedures which will be implemented to respond effectively to emergency situations that may arise at the facility. This Plan is reviewed and updated at least once per year. This Plan will be reviewed and updated to ensure compliance with the PSM and RMP regulations, as well as to incorporate any facility changes. STATIONARY SOURCE AN D REGULATED SUBSTANCE The ammonia refrigeration system at the Cascade Hilltop facility provides cooling for several cold storage and dock areas. Different temperatures are maintained by running two suction pressures with different sets of compressors. The majority of the refrigeration system is located in the compressor room. Evaporator valves and piping are mounted in their respective cold storage/process zones and the condensers and high pressure receiver are located outside. The refrigeration process, consisting of piping, valves, and equipment, cycles ammonia through various physical states (high pressure liquid, low pressure liquid, low pressure vapor, high pressure vapor, then back to high pressure liquid) in order to provide refrigeration for process equipment and cold storage rooms. Changes in pressure are directly related to changes in temperature. For example, lowering the ammonia pressure lowers its temperature. Low pressure (cold) liquid ammonia provides refrigeratio n by removing ambient heat. Removal of ambient heat causes the liquid ammonia (contained within the system) to vaporize. Heat is later removed from the ammonia as it is condensed back into a liquid. Typical operating conditions range from vacuum (approximately 6" Hg) on the low pressure side of the system to 150-160 psig on the high side. Ammonia is used as the refrigerant in the refrigeration process. The total ammonia inventory is 19,460 pounds. HAZARD ASSESSMENT SUMMARY Worst Case Release Result Summary The worst case release for this facility was that of the maximum quantity of ammonia that can be stored in a vessel. The largest vessel is the blast freezer low pressure receiver, which is located inside the engine room. This vessel can hold 15,120 pounds of ammonia. Utilizing the mitigation factor of 55% since the vessel is located inside a building, the release rate is 832 pounds/minute over a 10 minute duration. The high pressure receiver, on the other hand is smaller, but located outside. The release rate from the high pressure receiver is 979 pounds/minute. The most pessimistic meteorological conditions were used: 1.5 meters/second wind speed, and F stability. The facility is located in a rural setting. The downwind distance to 200 ppm was determined using Exhibit 4-4 from the EPA "Risk Management Program Guidance for Ammonia Refrigeration", November 1998. The release reaches off-site and may affect population and environmental receptors. Alternative Release Result Summary The alternative release scenario was that of a 0.25 inch diameter leak of high pressure gas ammonia for one hour. This scenario was chosen because the facility has high pressure gas lines external to the facility and a 0.25 inch leak could be caused by a flange seal leak or a valve packing leak. The quantity of ammonia released in one hour at this rate (134 lbs/minute) is 8,040 pounds. The meteorological conditions used were 3 meters/second wind speed, and D stability. The facility is located in a rural setting. The downwind distance to 200 ppm was determined using Exhibit 4-5 from the EPA "Risk Management Program Guidance for Ammonia Refrigeration", November 1998. The release reaches off-site and may affect population receptors. No environmental receptors are affected by this potential scenario. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Administrative Measures The facility operates in accordance with the International Institute of Ammonia Refrigeration (IIAR) guidelines and standards including the following: IIAR Bulletin 107, "Suggested Safety and Operating Procedures When Making Ammonia Refrigeration Tie-ins" IIAR Bulletin 109, "Minimum Safety Criteria for a Safe Ammonia Refrigeration System" IIAR Bulletin 110, "Startup, Inspection, and Maintenance of Ammonia Refrigeration Systems" IIAR Publication R-1, "A Guide to Good Practices for the Operation of an Ammonia Refrigeration System" I n addition, Cascade has implemented a Process Safety Management program for compliance with the Cal-OSHA 5189 regulation since April 1994. Engineering Measures The ammonia refrigeration system employed by Cascade is equipped with a computer which monitors and controls the system. The computer system is connected to controls and status indicators throughout the refrigeration system intended to minimize potential ammonia related accidents and to allow operators to monitor system operations. This monitoring system is comprised of liquid level controls, pressure and temperature controls and indicators, as well as other system safeguards and methods for allowing the computer (or facility operators) to effectively monitor and control refrigeration operations. FIVE YEAR ACCIDENT HISTORY Between April 1994 and April 1999, there have been no releases of ammonia that exceeded the Federal Reportable Quantity of 100 pounds. In addition, there have been no injuries resulting from an ammonia r elease. EMERGENCY RESPONSE PROGRAM The Cascade Hilltop facility has a Response Plan for On-Site Emergency Operations. This Plan outlines the policies and procedures in place to respond to potential ammonia alarms or releases. Cascade's policy is to contact 9-1-1 in the event of an ammonia release. The facility has several trained personnel to assist in an orderly evacuation as well as to diagnose the alarm condition. There are three "Operations Level" trained employees at the facility. These employees have completed the OSHA 8 Hour Operation Level Training program and participate in 8 hour annual refresher training classes. The facility has a close relationship with the Watsonville Fire Department who are extremely aware of the physical properties and hazards associated with ammonia. The Response Plan for On-Site Emergency Operations includes the facility emergency coordinators, the staff alerting list, emergency notification list, and the hazardous materials agency notification and procedures. This Plan then proceeds to detail the procedures for employees and management in the event of a fire, evacuation, compressor room shut down, earthquake, blackout, and ammonia release/clean-up. PLANNED CHANGES TO IMPROVE SAFETY Following a review of the existing Process Safety Management programs in place at the facility and the development of the EPA Risk Management Program submittal documentation, the following changes have been planned for the facility. These mitigation measures will be implemented by the Engineering Department by December 1999. 1. Conduct a Process Hazard Analysis using the checklists and What-If scenarios. 2. Complete the standard operating procedures and certify as accurate. Review and certify annually thereafter using the Certification form in Section 5 of the PSM notebook. The following procedures will be developed: a. Initial Startup b. Normal Startup c. Ammonia Delivery d. Normal Shutdown e. Emergency Shutdown f. Startup Follo wing an Emergency Shutdown g. Equipment Isolation for Maintenance 3. Incorporate equipment specifications and consequences of deviation in the operating procedures. 4. Develop and utilize training certification forms for refrigeration operators. One form for existing operators and one form for initial training of new operators to document on-the-job training. Form 1 is the "Grandfather" form. OSHA allows facilities to certify that the operators who started working at the facility and on the regulated process, prior to June 21, 1999, are qualified to carry out their responsibilities outlined in the operating procedures. Form 2 is the Initial Training Form. This form should be signed by the supervisor and operator to certify that the operator understands the operating procedures enough to work independently. In addition, Form 2 should be developed for each operating procedure. 5. Review the Inspection Schedules (Tables 2 - 5) in Section 9 of the RMP manual to ensure that it is an accurate representation of the facility's maintenance program. Once the facility's maintenance schedule has been finalized, develop checklists with dates of completion and operator initials for record keeping purposes. 6. Add an ammonia detection system at the facility that will alarm and/or provide automatic shut down of the system in the event of a release of ammonia. |