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Pacific Coast Producers - Lod Ammonia Refrigeration <br />Anhydrous Ammonia Refrigeration System 1/5/2022 <br />No. F C R Consequence Safeguards and Control Measures Suggested Safeguards and <br />Control Measures <br />Management Response / Action Taken Estimated <br />Completion <br />Date <br />Assigned To Actual <br />Completion <br />Date <br />1.07 2 2 C Personnel safety, <br />Inadequate notification <br />to facilitate immediate <br />emergency response. <br />High discharge pressure alarms indicate issues <br />with condenser. <br />Daily rounds (each operating day) include <br />inspecting condensers for proper operation. <br />Routine PM on fans and motors. High <br />discharge pressure cutout at 200 psig. <br />Fans and water pumps cycle on to maintain <br />head pressure. <br />PRVs for HPR are connected to relief header <br />which is piped to a water diffusion tank. <br />Consider adding high discharge <br />pressure alarms to email and <br />text callouts. <br />High pressure discharge alarms all Functional / <br />Tested and working. 8/2024 <br />SMI Aug-24 <br />1.08 2 2 C Personnel safety, <br />Confusion during an <br />emergency. <br />High discharge pressure alarms indicate issues <br />with condenser. <br />Daily rounds (each operating day) include <br />inspecting condensers for proper operation. <br />Routine PM on fans and motors. High <br />discharge pressure cutout at 200 psig. <br />Fans and water pumps cycle on to maintain <br />head pressure. <br />PRVs for HPR are connected to relief header <br />which is piped to a water diffusion tank. <br />See Node 1.07 for <br />recommendation. <br />High pressure discharge alarms all Functional / <br />Tested and working. 8/2024 <br />0 SMI Aug-24 <br />2.12 2 3 B Confusion during an <br />emergency. <br />Experienced refrigeration operator. Operator <br />indicated equipment instrumentation is <br />adequate. <br />P&ID of system equipment, valves and <br />instrumentation. <br />Consider evaluating if labeling <br />manual isolation valves (king <br />valves) on HPR1 (HPR-02, <br />HPR-04, HPR-05) and LIC <br />isolation valve (HPR-15) for <br />HPR1 or alternate location is <br />needed at the valves and on the <br />P&ID. <br />Valves have been labeled. SMI July 2022 and <br />October 8, <br />2024 <br />2.13 2 3 B Delays and confusion <br />during an emergency. <br />Increased leak <br />potential. <br />Experienced refrigeration operator. Operator <br />indicated equipment valves are accessible at <br />ground level. <br />P&ID of system equipment, valves and <br />instrumentation. <br />See Node 2.12 for <br />recommendation. <br />Valves have been labeled. 0 SMI July 2022 and <br />October 8, <br />2024 <br />3.11 2 2 C Personnel safety, <br />Confusion during an <br />emergency. Inability to <br />monitor system and <br />correct deviations from <br />normal ranges. <br />Increased potential for <br />human error. Potential <br />to lead to an ammonia <br />release. <br />Operators indicate instrumentation is <br />accessible. <br />P&IDs for system include instrumentation and <br />valves. <br />Consider painting and labeling <br />SDs. <br />This is planned for completion after cold <br />storage system is shut down at end of <br />September 2024. <br />Painting of SDs to be completed after UA-1 <br />forms are located. We do not want to paint <br />them if they need to be replaced. <br />1/1/2025 <br />3.14 2 3 B Compromise Personnel <br />safety and potential <br />equipment damage. <br />SA1 and LTV1 are guarded by location inside <br />the engine room. <br />SD1-9 are located behind bunker walls. <br />Consider recertifying or <br />replacing SA1 and SDs without <br />manufacturer data reports. <br />Suction accumulator was replaced. Beverly <br />review SMI records (5/23) <br />For SD-We do not have an updated UA-1 form <br />but are looking for them. <br />5/23/24-suction <br />accumulator <br />Surge drum <br />pending <br />3.16 2 2 C Delays and confusion <br />during an emergency. <br />Increased leak potential <br />Operators indicate instrumentation is <br />accessible with ladders. Precooler SD valves <br />are accessible on the roof from access ladder. <br />P&IDs for system include instrumentation and <br />valves. <br />See Node 3.11 for <br />recommendation. <br />This is planned for completion after cold <br />storage system is shut down at end of <br />September 2024. <br />Painting of SDs to be completed after UA-1 <br />forms are located. We do not want to paint <br />them if they need to be replaced. <br />1/1/2025 0 0 <br />4.08 2 1 D Potential for a liquid <br />ammonia leak at <br />system head pressure <br />(see ranges). <br />Mechanical <br />deterioration of <br />compressors is highly <br />unlikely, based on the <br />commitment to <br />maintaining <br />compressors. <br />Compressors are included in preventive <br />maintenance program. <br />Compressors will be observed at least once <br />each operating dial. <br />Compressor safeties are tested annually. <br />Ammonia detection in engine room alarms at 25 <br />ppm. <br />Consider developing <br />compressor maintenance tasks <br />based on runtime hours based <br />on manufacturer and IIAR 6. <br />PCP Lodi maintenance program conducts <br />inspection, testing and maintenance tasks more <br />frequently than required by runtime hours. <br />Daily occur during season. <br />The compressors are on a schedule to be <br />inspected and preventive maintenance <br />completed prior to pack season. By the time the <br />compressors are due for maintenance on a <br />runtime basis, they are shut down for the <br />season. However, we will develop a written <br />inspection and maintenance program. <br />Created a schedule for inspection items on an <br />annual basis (items are spread out and not all <br />conducted at once). <br />1/1/2025 <br />4.10 3 3 B Oil will drip from seal. If <br />no operator response, <br />ammonia release could <br />result. <br />Compressors are included in scheduled PM <br />program. <br />Operators observe compressors at least once <br />each operating day. <br />Operators look for oil drips at shaft seal. <br />Engine room is equipped with an exhaust fan <br />that continuously operates. Ammonia detection <br />system alarms at 25 ppm. <br />Consider upgrading ventilation <br />system to updraft fan and <br />activation from ammonia <br />detectors to meet IIAR 2. <br />9/23/24 Fan switch is replaced to ON/AUTO <br />instead of ON/OFF. <br />1/1/2025 <br />(replace fan <br />and motor) <br />9/23/24-Fan <br />switch replaced <br />Updraft fan with <br />nonsparking <br />blades <br />completed <br />3/5/2025 <br />4.11 2 2 C Personnel safety, <br />Inadequate notification <br />to facilitate immediate <br />emergency response. <br />PM program includes testing ammonia <br />equipment alarms. Operation of compressor <br />checked during daily rounds. Critical <br />parameters (high pressure, high temperature, <br />etc.) shut down equipment. <br />Ammonia detection alarms at 25 ppm inside the <br />engine room. <br />See Node 1.07 for <br />recommendation. <br />High pressure discharge alarms all Functional / <br />Tested and working. 8/2024 <br />0 SMI 8/1/2024 <br />4.12 2 2 C Personnel safety, <br />Confusion during an <br />emergency. <br />E-stops are installed on SC-4 compressor <br />panel and outside engine room. <br />Critical parameters (high pressure, high <br />temperature, etc.) shut down equipment. <br />Ammonia detection alarms at 25 ppm inside the <br />engine room. <br />Consider adding e-stops to <br />HSC-1 - 3 inside the engine <br />room. <br />E-stops have been added. (Photo "LCS RC1-2- <br />3 Estops") <br />10/4/2024 SMI 10/8/2024 <br />4.15 2 3 B Personnel safety PRVs vent to relief header that is connected to <br />ammonia diffusion tank. <br />PRVs are replaced every 5 years. <br />Consider evaluating the existing <br />relief design basis for PRVs <br />and diffusion tank. <br />Pressure relief valve calculations provided and <br />show that the valve design is adequate. <br />10/10/2024 SMI 10/10/2024 <br />4.18 2 2 C Delays and confusion <br />during an emergency. <br />Increased leak potential <br />Compressor isolation valves are accessible. <br />Emergency stop switch located outside engine <br />room. <br />Ammonia detection activates alarms at 25 ppm. <br />See Node 4.12 for <br />recommendation. <br />E-stops have been added. (Photo "LCS RC1-2- <br />3 Estops") <br />10/4/2024 SMI 10/8/2024 <br />Table 1 (Recommendations), Page 1