FRANK CAPURRO & SON - Executive Summary |
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EXECUTIVE SUMMARY 1 PREVENTION AND RESPONSE Frank Capurro & Son operates a shipping and cooling facility in Moss Landing, CA. in addition to facilities in other counties. Risk prevention and emergency response procedures are in place at all Capurro facilities. The same management and maintenance personnel are responsible at all facilities for maintaining the ammonia refrigeration equipment to prevent releases, and for responding to an emergency. The Emergency Response Plan lists the responsible personnel and the policies for responding to an accident involving the regulated substance. There are both portable and fixed refrigeration systems onsite and all have safeties to detect unsafe operating conditions. Adding an ammonia detection system to the fixed system is one of the risk reduction recommendations of the PHA (Process Hazard Analysis). This detection system along with system safety alarms would be tied into an alarm system that is monitored 24 hours per day. The portabl e equipment have no detection since the units are outdoors. Operators are present to monitor the operating conditions of these units when they are running. There is a list of responders experienced with ammonia refrigeration that would respond and determine specific responses for any incident. Safeties are tested and maintained by experienced maintenance personnel as spelled out in the SOPs and the maintenance program. 2 STATIONARY SOURCE AND SUBSTANCE DESCRIPTION At the Moss Landing facility, ammonia refrigeration systems are used for cold storage, produce precooling, and ice generation. The fixed system is attached to the building and is used for cold storage and ice generation. The portable refrigeration equipment is trailer mounted and is used for precooling of produce. The trailers are outdoors and can be moved from one facility to another. The fixed refrigeration system was started in 1991 and designed as per current applicable building and safety codes. There are thre e portable systems started in 1987, 1991, and 1997. The total charge refrigeration change for all systems is 15,000 LBS. 3 RELEASE SCENARIOS Both a worse case and an alternate case release scenario were modeled for this RMP utilizing a computer-modeling program. The worse case was a release of the entire ammonia charge of the largest system in 10 minutes with ambient conditions as required by EPA regulations. The alternate was a release for 17 minutes averaging approximately 100 LBS/minute. This is a more probable release due to items such as rotating seals, pressure relief valves, leaks in piping, charging system or draining oil. The modeling software used was "A Real Locations of Hazardous Atmospheres" (ALOHA) from the National Safety Council in cooperation with the EPA. Both scenarios were considered releases in a rural setting. Release plumes were plotted on maps, which showed the location of populations, schools, public areas, and acute care facilities if effected by th e release. The mapping software utilized was "Mapping Application for Response and Planning of Local Operational Tasks" (MARPLOT) also from the National Security Council. Effected populations were estimated using "Land View III," a computer census modeling program from the Bureau of Census that calculates census data of areas defined on MARPLOT generated maps. Offsite consequences were analyzed at 200 PPM level of concern for the two above release scenarios. Results show the worse case scenario having a potential endpoint of 1.6 miles. If the area were encircled with the 1.6 mile endpoint distance as the radius, the total area population would be approximately 9,000. This area contains one primary school, a state beach, a national preserve, and part of a state highway. The alternate scenario has considerably less offsite consequence with an endpoint of 1,557 feet at 200 PPM. Close residences would be effected as would smaller parts of the national preserve and state highway. There are various measures in place or recommended as PHA risk reductions to limit the endpoint distances of a release. One recommendation is an ammonia detection and monitoring system providing early alarming for the cold storage system. Another recommendation is to tie the relief valves into diffuser water tanks rather than piping to ambient. Preventive maintenance and safety inspections are used to insure equipment and piping is maintained and operating in a safe manner. 4 GENERAL RELEASE PREVENTION PROGRAM Capurro maintains a release prevention program to eliminate or minimize releases. The program includes regular inspections, monitoring equipment, logging conditions, scheduled maintenance, and operator training. A program to document releases and analyze ways to prevent a similar future releases is in place. A Risk Management Program, which includes accident prevention procedures for the ammonia refrigeration system, is maintained on-site along with this RMP. The ammon ia refrigeration system has specific safety procedures to prevent a release. Operators and mechanics are trained for safe operation and maintenance of the refrigeration system. They are also trained in emergency response procedures in the event of an ammonia release. One of the risk reduction recommendations in the PHA is for emergency shut off switches outside the mechanical room of the cold storage system that would shut down both the system and the ammonia flow. Another risk reduction recommendation is for the cold storage refrigeration system to be monitored by an alarm and detection system for unsafe ammonia concentration levels and for operating conditions outside of safety set points. Monitoring shall be 24 hours per day. There is also a recommendation is for tying relief valves into diffuser tanks. 5 FIVE YEAR ACCIDENT HISTORY There have been no accidents at this facility. 6 EMERGENCY RESPONSE PROGRAM In event of a release, certain personnel are designated to dete rmine the potential hazard and coordinate response procedures. The emergency coordinator is responsible for contacting emergency response agencies, schools, daycare centers, and acute care facilities that may be effected by the release. The coordinator will also be responsible for evacuation of employees if necessary, and for coordination with community emergency responders if off-site evacuations are required. 7 PLANNED CHANGES TO IMPROVE SAFETY Specific recommendations resulting from the PHA are listed in the Risk Management Program maintained at the facility. The major risk reduction corrections are adding an ammonia diffusion tanks, adding an ammonia detection system and emergency switches for the fixed cold storage system. A more intensive and formalized safety training program will be implemented by May 1, 1999. |