U.S. Growers Cold Storage Areas 5&6 - Executive Summary |
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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 Ammonia is used as the refrigerant in the cooling system at t he U.S. Growers facility. The ammonia is circulated throughout the system using pressure differentials created by compressors and pumps. The pipes that carry the refrigerant are insulated for maintaining temperatures and pressures. Compressor discharge lines are not insulated to facilitate the cooling process before arrival at the condensers. High pressure liquid ammonia is circulated via exterior insulated pipelines to evaporator coils throughout the cold storage facility. Ammonia is vaporized in the evaporators and returned to the compressors. The ammonia vapor is returned to the booster compressors, intercoolers, high stage compressors, and finally, the condensers where the high pressure vapor is condensed to high pressure liquid ammonia. Ammonia is used as the refrigerant in the refrigeration process. The total ammonia inventory is 10,500 pounds. HAZARD ASSESSMENT SUMMARY Worst Case Release Result Summary: The worst case release scenario is a release of the tota l quantity of ammonia in the largest vessel in the ammonia refrigeration system, taking into account administrative controls that limit the maximum quantity in the vessel. The high pressure receiver (on the Engine Room roof) is the largest vessel in the system (witha capacity of 1100 gallons of ammonia, approximately 6050 pounds of ammonia) and is assumed to be filled to capacity for the worst case scenario. 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 receptors. 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 p ressure 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 PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Administrative Measures: The facility operates in accordance with the International Institute of Ammonia Refrigeration (IIAR) guidelines and sta ndards 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. Building Codes: 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 directed 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 Engineering Measures: 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. Growers 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 regula tory 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 notify 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 ove rall 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 TO 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 5 and 6. 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. |