Ito Cariani Sausage Company, Inc. - Executive Summary |
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EXECUTIVE SUMMARY ITO CARIANI SAUSAGE COMPANY, INC. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICY The Ito Cariani Sausage Company, Inc. is a recently constructed (1991) plant, which uses an ammonia-based refrigeration system. It was required by California State law and the City of Hayward Fire Department to prepare a Risk Management Prevention Plan and to meet design and operating requirements to minimize accidental releases from the facility. This investment in equipment and safe operating procedures has resulted in incident-free (zero 5-year accident history) operation. Efforts to improve plant safety, release prevention and emergency response are a constant priority in coordination with the Fire Department. THE FACILITY AND THE REGULATED SUBSTANCE HANDLED The Ito Cariani Sausage Company, Inc. operations include meat processing, sausage manufacturing and distributing. Various types of meats are received at the facility and subsequently processed and prepared for sausage. Sausage is prepared, packaged and distributed from the facility. The plant is located at 3190 Corporate Place in Hayward, California at the southeast corner of Corporate Avenue and Corporate Place. The facility is in the Eden Landing Industrial Park. The industrial park and surrounding area is used for light industrial and commercial warehousing activities. Ammonia is used in the facility's refrigeration system and is the only regulated substance or acutely hazardous material used at the site. The engineering evaluation of the ammonia refrigeration system conducted as part of the state/local required RMPP prior to initial operates provided design parameters to minimize potential for releases and identified conditions which would result in releases of ammonia. The system engineering/design description was prepared by Industrial Design Corporation (IDC) of San Jose, California. Ammonia is colorless gaseous compound with a sharp, irritating, and pungent odor that can be detected in air at concentrations between 1.0 and 5.0 parts per million (ppm). Ammonia is an acutely toxic chemical because it can burn the lungs, eyes, and skin. The most hazardous exposure pathway is inhalation. There is no evidence for immunological, neurological, developmental, reproductive, carcinogenic or genetic effects to humans from exposure to ammonia. The Cal/OSHA permissible exposure limit for worker average daily exposure is 25 ppm for full shift exposures. The toxic end point established by EPA for ammonia, which defines the significance of an off-site exposure, is 200 ppm. WORST-CASE RELEASE SCENARIO AND THE ALTERNATIVE RELEASE SCENARIO Pursuant to mandatory worst-case scenario and modeling required by EPA, the plant is required to presume the highly improbably release of the entire contents of its ammonia receiver tank which may contain at certain times the entire 16,000 pounds of ammonia present in the refrigeration system, within a ten minute period. This scen ario predicts off-site impacts of up to 1.5 miles based on the toxic end point established by EPA, and the modeling tables provided in EPA's RMP guidance. Ito Cariana has equipment and procedures in place to prevent such scenarios and their releases and emergency procedures, which will mitigate the consequences of any such release. ACCIDENTAL RELEASE PREVENTION PROGRAM AND EQUIPMENT The extensive release prevention program developed and implemented by Ito Cariani Sausage Company, Inc. includes both administrative procedures and engineered controls to preclude releases from the ammonia refrigeration system. The administrative procedures include: 1. Written standard operating procedures are in effect. They assure uniform operations according to design parameters and improve employee performance and training. Standard operating procedures (SOP) which require that safety procedures adhered to will be included in employee training in facility operations, location and use of shut-off valves, and the handling of spills and/or leaks. 2. Employee Training. The facility has a training program for all employees; no one is permitted to operate equipment until certified by a qualified and certified supervisor. A continuing safety training program, with annual updates, is conducted so that employees will have knowledge of job hazards, evacuation procedures, first aid and rescue procedures, maintenance and cleanup procedures, and correct use of respirators and protective clothing. Supervisors will undergo additional supervisor's safety training. 3. Inventory Control. Ammonia will only be added to the system when required. After initial charging this may be annual but recharging is not anticipated for two to three years. Inventory control is provided by a gauge at the high-pressure receiver. This will be the only place that ammonia can be put into the system and it will be monitored by operators and the delivery truck operator when charging and recharging operati ons occur. 4. Over or Under Filling is always possible during charging or recharging of any chemical handling system. However, this system will be refilled no more than annually, system charging and refilling will be done under the direct supervision of the plant owner and system vendor, the ammonia system inventory will be strictly managed, and vendor safety procedures will be employed. 5. Security from Vandalism/Sabotage is provided by restricted access to the facility, a security fence, and a 24-hour security company. Most of the refrigeration equipment is located in the mechanical room, which will have locked doors to prohibit unauthorized entry. The engineered controls include: 1. Earthquake/seismic Protection and Structural Bracing designed to account for a credible seismic event. Mechanical equipment (including pressure vessels and piping) inside the facility will be anchored as required by the Uniform Building Code (UBC) for Seismic Zone 4. 2. Vapor/Gas Suppression and Containment. The mechanical room has self-closing, tight-fitting doors which open outward. There are no openings from the mechanical room which will allow ammonia to escape to other parts of the building. The exhaust systems electric-driven fans can be activated from emergency switches located inside and outside the mechanical room. Exhaust has been provided for the mechanical room separately, therefore should a leak occur, ammonia will be restricted to the mechanical room prohibiting entry to the rest of the building. 3. Over or Under Pressure Controls; if high pressures occur, a relief valve opens and ammonia is released at a predetermined safe rate (depending on device or vessel), until the pressure drops below the set limit of the relief valve; the valve will then reseal. 4. Over or Under Temperature: High temperature will result in high pressures within the system (see Over or Under Pressure). Under temperature will not occur because ammonia will be under liquid condi tions. 5. Gas or Vapor Detection capability is provided through a continuous ammonia leak detection and alarm system. Ammonia detectors will be installed in all rooms containing refrigeration evaporators. In the event that ammonia concentrations reach or exceed 150 ppm, the vapor sensor control system will activate. The purpose is to detect equipment failures in unoccupied areas. 6. Automatic Shutdown will occur in response to a rupture in a safety valve, because of high pressure in a refrigeration vessel, will cause the safety valve to release enough ammonia to drop the pressure below the valve setting. The valve will then close stopping ammonia discharge. 7. Computerized monitors and control devices will prevent releases. The refrigeration system is controlled by an electronic control system connected, via modem, to a computer. The control system can shut down any system component or the entire system should temperature and/or pressure exceed system design. A system malf unction will also be announced and displayed on the computer system to the plant operator. 8. Electrical Failure will result in the refrigeration system shutting down. Emergency power is available to power the exhaust ventilation system for the mechanical room and the ammonia leak detection and alarm system. 9. Fire in the facility will result in the immediate initiation of the emergency dump procedures for the ammonia refrigerant. This will promptly and safely reduce refrigerant system pressure. A fire extinguishing system has been installed in the plant according to UBC, UFC, and NFPA requirements. Fire extinguishers are also located throughout the facility. 10. Treatment of dumped ammonia is accomplished by the emergency dump system to capture discharged ammonia and sufficiently dilutes the effluent prior to discharge to the sanitary sewer. 11. Delivery Systems are designed to minimize releases. Delivery of ammonia to the plant will be by truck to the receiver vessel on ly. No internal or portable tanks will be located within the facility. Pipes and connections are to be welded and installed in accordance with UBC, UMC, and ASME standards. Local gas shut-off valves will be at the high-pressure receiver and at all equipment connections to allow for periodic maintenance, repair and isolation in the event of a problem or emergency. Solenoid shut-off valves are placed at the main refrigerant supply line from the high-pressure receiver to the mechanical room to assure effective isolation. FIVE-YEAR ACCIDENT HISTORY The plant has not had any accidents which affected off-site receptors in the last 5 years, nor any since its initial operation in 1991. EMERGENCY RESPONSE PROGRAM The plant has an effective emergency response plan in place, including an emergency response team and coordination with the City of Hayward Fire Department. Emergency response drills are conducted quarterly involving emergency response coordinators and members of the emergency response team. All employees participate twice each year. The emergency response team has protective equipment available to enable it to effective respond and to take appropriate actions as necessary to control or mitigate releases. Prompt notification of the Fire Department and coordination with this important resource in an emergency is a significant part of the plants emergency procedures. PLANNED CHANGES TO IMPROVE SAFETY Although Ito Cariani's release prevention programs and engineered controls have proven to be effective in preventing releases, the plant continues to evaluate procedures and equipment to assure proper performance and function and to determine whether further improvements are feasible. |