U.S. Growers Cold Storage Areas 1, 2, and 7 - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES |
U.S. Growers Cold Storage has implemented emergency response policies in order 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.
U.S. Growers maintains an emergency response committee whose members are the designated emergency coordinators for the facility. The Emergency Response 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 was reviewed and updated to ensure compliance with the PSM and RMP regulations, as well as to incorporate any facility changes.
STATIONARY SOURCE AND REGULATED SUBSTANCE
The U.S. Growers Cold Storage facility is located between Boyle
and Alcoa (the whole block) on East 44th Street (north side), Vernon, California. U.S. Growers consists of three facilities that use ammonia for refrigeration, Areas 1, 2, and 7.
Area 1 was built in 1996 with start up in January 1997.
Area 2 was built in 1998 with start up in October 1998.
Area 7 was built in 1950
Areas 1 and 2 utilize the same engine room equipment while Area 7 has a separate engine room. The three areas are connected via a common liquid and suction header; however, they are operated separately as there is a valve in each header that is closed during normal operations. The two separate ammonia refrigeration processes are closed systems that cycle the refrigerant, or ammonia, from liquid to gas and back again. The processes, consisting of vessels, piping, valves, and process equipment, cycle 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 product and process equipment.
Changes in pressure are directly related to changes in temperature: lowering the ammonia pressure lowers its temperature. Low pressure (cold) liquid ammonia provides refrigeration 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 approximately 7 psig on the low pressure side of the system to 160 psig on the high side.
Ammonia is used as the refrigerant in the refrigeration process.
The total ammonia inventory is 33,000 pounds. The maximum intended inventory of ammonia at the U.S. Growers facility is 15,000 pounds in Area 7 and 18,000 pounds at the Areas 1&2 plant.
HAZARD ASSESSMENT SUMMARY
Worst Case Release Result Summary:
The worst case release scenario is a release of the total quantity of ammonia in the largest vessel in t
he ammonia refrigeration system, taking into account administrative controls that limit the maximum quantity in the vessel. The Liquid Recirculating Unit #1 (located in the Engine Room) is the largest vessel in the system (with a capacity of 4000 gallons of ammonia, equivalent to 22,000 pounds of ammonia) and is assumed to contain the total charge of the Areas 1 & 2 system (18,000 pounds of ammonia) for the worst case scenario. Since the Unit is enclosed by the facility, passive mitigation effects were taken into consideration when determining the release rate of ammonia to the outside atmosphere. The most pessimistic meteorological conditions were used: 1.5 m/s and F stability. This facility is located in an urban setting. The maximum potential downwind distance to 200 ppm was determined using Exhibit 4-4 from EPA's "Risk Management Program Guidance for Ammonia Refrigeration Facilities", November 1998. This potential release scenario reaches off-site and may affect population re
ceptors. No environmental receptors are affected by this potential scenario.
Alternative Release Result Summary
The alternative release scenario was that of a 0.25 inch diameter leak of high pressure liquid ammonia for one hour. The quantity of ammonia released in one hour at this rate is 7560 pounds. This release could occur due to a gasket rupture, pinhole leak, flange seal leak, valve bonnet seal leak, etc. In addition, this release could occur outside; therefore passive mitigation measures were not utilized. The meteorological conditions used were 3 m/s and D stability. This facility is located in an urban setting. The maximum potential downwind distance to 200 ppm was determined using Exhibit 4-5 from EPA's "Risk Management Program Guidance for Ammonia Refrigeration Facilities", November 1998. This potential release scenario reaches off-site and may affect population receptors. No environmental receptors are affected by this potential scenario.
ACCIDENTAL RELEASE PREVENTIO
N PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS
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, "A Guide to Good Practices for the Operation of an Ammonia Refrigeration System"
In addition, U.S. Growers has implemented a Process Safety Management program for compliance with the OSHA 1910.119 regulation since September 1993.
The facility was constructed to comply with the current edition of all applicable codes, ordinances, regulations, and requirements of the local, county, state, and national bodies having jurisdiction. Special attention is directe
d to but not limited to:
AHSI/ASHREA 15-1989 - Safety Code for Mechanical Refrigeration
ANSI/IIAR 2-1984 - Equipment, Design, and Installation of Ammonia Mechanical Refrigeration Systems
ANSI BB31.5-1983 - Refrigeration Piping
ASME - Pressure Vessel Code, Section IX
UMC - Uniform Mechanical Code
UFC - Uniform Fire Code
NFPA - Fire Protection
UBC - Uniform Building Code, 1991, Seismic Zone 3
The ammonia system uses a computer system to bring equipment on-line, off-line, control the hot gas (compressor discharge) defrosting process, manipulate solenoid valves, and monitor the system for alarms. Ammonia sensors are used throughout the facility and are connected to the computer system.
EMERGENCY RESPONSE PROGRAM
All U.S. Growers employees have read and are familiar with the "Crisis Emergency Response Hazardous Materials" (CER) document that outlines the Business Plan, Emergency Response, and Hazardous Communication Program for the U.S. G
rowers Facility. All employees and management have read this plan thoroughly and have signed an acknowledgement to this fact. U.S. Growers Cold Storage participates in many in house and regulatory functions that insure constant training to their employees in regards to Emergency Response.
U.S. Growers Cold Storage also meets 26 times a year to discuss regulatory requirements of the RMPP (OES), PSM (OSHA), Rule 1415 (AQMD), as well as other issues that affect compliance. The purpose of these meetings is to inform all maintenance employees of any changes in the system, operating procedures, and any changes that might occur in the regulations.
The "Crisis Emergency Response Hazardous Materials" document (CER) is designed to assure proper protection during a crisis/emergency situation. In the event of an emergency that could threaten human health or the environment, the Emergency Coordinator shall assess the situation and determine if area evacuations are necessary. The EC will no
tify the local authorities and surrounding areas. The EC is the primary contact for the local authorities when they arrive at the scene. This individual will oversee the management of the overall operation.
It is the responsibility of the supervisor/lead person to sound an alarm when a situation occurs that requires evacuation. He is also responsible for ensuring that all his employees have evacuated the area. Evacuation drills are performed at the facility at least on an annual basis. The drill procedures are outlined in the CER. Prior to the drill, notice is given to the employees, emergency response agencies, and neighbors. A record of the employees in attendance is maintained along with a record of the results of each drill. Evacuation and drill procedures are reviewed for new employees upon hire.
All personnel at U.S. Growers receive emergency response training annually and are directed to medically assist other employees in an emergency situation.
PLANNED CHANGES T
O IMPROVE SAFETY
Below is a summary of the recommendations resulting from the Process Hazard Analysis Revalidation study performed on April 14, 1999 at U.S. Growers Cold Storage Areas 1, 2, and 7.
REV01: Incorporate the use of radios for operators working on the roof so that they can radio for help if necessary.
REV02: Install spring actuated hand valves on all oil pots.
REV03: Ensure that the recommendations from the initial Hazard and Operability Study and Seismic Assessment are completed (R14, S04, and S05).
The Engineering Manager will be responsible to ensure that all recommendations are completed on or before August 1, 1999.