Union Ice Co. - Executive Summary |
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1. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The facility uses ammonia as a refrigerant within a closed system. Ammonia is a hazardous substance that must be handled properly in order to prevent accidental releases and injuries. It is the policy of Union Ice to conduct all operations (including the ammonia refrigeration system) in a safe manner. This policy extends to all employees and contractors at the facility. Union Ice implements this policy towards chemical and general safety through on-going employee participation, training, written 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 loca ted at 6100 E. Sheila Street in Commerce, California. The facility is situated approximately 0.25 miles west of the Santa Ana Freeway (I-5) near the Washington Boulevard exit. The facility was constructed in phases between 1954 and 1973. The facility, which covers 13.3 acres, also includes building space for tenants. The area immediately surrounding the facility is primarily commercial/industrial with some residential areas to the north. The primary business of the Union Ice facility is to provide refrigerated warehousing and storage for food products such as meats, fruits, and vegetables. In addition, the facility also manufactures and packages party ice. In order to conduct operations, the facility maintains a refrigeration system containing approximately 20,000 pounds of anhydrous ammonia, a regulated substance. The refrigeration system, 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 cold storage rooms and freezers as well as the ice production equipment. Typical operating conditions range from vacuum (6" Hg) to 30 psig on the low pressure side of the system to 140-160 psig 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. The worst case scenario was that of the maximum quantity of ammonia that can be stored in a vessel. The largest vessel, Intercooler #4, is located outdoors and has a maximum capacity of 8,250 pounds of ammonia. This quantity was modeled as being released in 10 minutes, in an urban setting, under pessimistic meteorologi cal conditions (1.5 meter per second wind speed and F atmospheric stability class). Based upon the Risk Management Program Guidance for Ammonia Refrigeration Exhibit 4-4 modeling method, the worst case scenario reaches locations off-site and may affect population receptors. No environmental receptors are affected by this potential release scenario. The worst case scenario did not include any administrative controls or mitigations to limit the amount of ammonia released. Note, the worst case scenario is considered to be an unlikely event since the vessel is equipped with level controls to limit the amount of ammonia present in the vessel to less than the maximum capacity of 8,250 pounds. Also, by June 2000, the facility will have installed barriers to protect the vessel from vehicular impacts. The alternative scenario was a release of 7,320 pounds of ammonia from a 0.25 inch diameter hole (representative of a pump seal leak, pinhole leak in pipeline, etc.) in 60 minutes. This qua ntity was modeled as being released in 60 minutes, in an urban setting, using a wind speed of 3.0 meters per second and D atmospheric stability class. Based upon the Risk Management Program Guidance for Ammonia Refrigeration Exhibit 4-5 modeling method, the alternative release scenario reaches off-site locations and may affect population receptors. No environmental receptors are affected by this potential release scenario. The alternative scenario did not include any administrative controls to limit the amount of ammonia released but did include the mitigation that the emergency response team would terminate the release within 60 minutes. 4. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS In order to operate the ammonia refrigeration system, the facility complies with the following risk management regulations: a. OSHA's Process Safety Management (PSM); b. EPA's Risk Management Program (RMP); and c. California's Accidental Release Prevention Progr am (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 Union Ice to prevent the accidental release of ammonia from the facility. 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 Union Ice'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 that the refrigeration system 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. The facility has also installed ammonia sensors at strategic locations throughout the facility which will send an alarm to an off-site monitoring company if an ammonia release is detected. 5. FIVE YEAR ACCIDENT HISTORY No ammonia accidents, injuries, or near mis s situations have occurred at the facility dating back to June of 1994. 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 an ammonia release at the facility, 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 system is periodically evaluated for safety hazards. This Process Hazard Analysis (PHA) of the refrigeration system consisted of: a. a Hazard and Operability (HAZOP) study; b. a What If Analysis; c. a seismic assessment; and d. a series of safety checklists. As part of the PHA revalidation of the previously conducted studies and the analysis of recent modifications to the refrigeration system, recommendations were made to improve the overall safety of the system. The key planned changes to the system include: a. Improving labeling and signage. b. Equip and train facility personnel to respond to accidental ammonia releases. c. Develop the Emergency Response Plan (ERP) that details how to respond to ammonia releases. d. Once the ERP is developed, conducted training drills with facility personnel and the fire department. e. Install barriers to protect vessels recently installed outdoors. All safety recommendations are expected to be implemented by June 2000. |