Producers Dairy Foods, Inc. - Executive Summary |
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EXECUTIVE SUMMARY FOR RMP*SUBMIT Accidental Release Prevention and Emergency Response Policies Producers Dairy Foods, Inc. (Producers) utilizes anhydrous ammonia in the refrigeration system at their facility in Fresno, California. It is Producers' policy to comply with all applicable governmental regulations. Further, it is Producers' objective to be a responsible citizen of the community in all of its business activities. Additionally, an emergency action plan has been prepared for Producers and a chain of command to respond to emergencies has been established. Description of the Stationary Source and Regulated Substances Producers owns and operates a milk and milk products processing facility located on East Belmont Avenue in Fresno, California. The corporate office and mailing address is 250 E. Belmont. The ammonia-based refrigeration system at Producers provides cooling for the raw milk tanks, the glycol chiller for the pasteurizing process, pasteurized milk tanks, cream tank, cold storage rooms, and the ice makers. The major components of the refrigeration system are the high pressure receiver, direct expansion evaporators, flooded evaporators, accumulators, compressors, condensers, and a glycol chiller. The largest vessel in the refrigeration system at Producers in the high pressure receiver. The maximum quantity of ammonia that can be stored in the high pressure receiver is approximately 4,700 pounds. For purposes of the offsite consequence analyses, the RMP regulations define the toxic endpoint for anhydrous ammonia as 0.14 mg/l (200 ppm). This concentration has been established by the American Industrial Hygiene Association as the Emergency Response Planning Guideline Level 2 (ERPG-2). ERPG-2 is the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an indivi dual's ability to take protective action. Worst-Case Release Scenario and Alternative Release Scenario Offsite consequence analyses are used as tools to assist in emergency response planning. The RMP regulations require the owner or operator of a stationary source to analyze the offsite impacts due to an accidental release of a regulated substance. The offsite consequence analysis for a Program 3 process must analyze the worst-case release scenario and an alternative release scenario. Since Producers' ammonia-based refrigeration system is considered a Program 3 process, both release scenarios were evaluated in the offsite consequence analysis. The offsite consequence analysis must include an estimate of the residential population within an area potentially affected by the accidental release scenario. This area is defined as a circle with a radius equivalent to the distance the release would travel with concentrations at or above the endpoint. The circle also defines the area in which potential environmental receptors must be identified. The worst case release is defined by the U.S. EPA as the total release of the contents of the single largest vessel or pipe within 10 minutes. For liquefied gases stored under pressure, the entire contents of the vessel or pipe are assumed to be released as a vapor. A total vapor release is highly unlikely. However, this standardized worst case scenario was developed for emergency response agencies to use for planning purposes. An alternative release scenario is a release that is more likely to occur than the worst-case release scenario. For Producers, the alternative release scenario was selected based on the results of the Process Hazard Analyses (PHAs) and operating experience with the ammonia-based refrigeration system. A credible release event with a high discharge rate would potentially have the greatest offsite impact. A release from a pressure safety valve on the evaporative condenser was identified in the PHAs as having a medium probability of occurrence with a discharge rate high enough to cause an offsite impact, and therefore, was chosen as the alternative release scenario. Producers has analyzed the offsite consequences of the worst-case and alternative release scenarios. For the worst-case release scenario, the release of approximately 4,700 lbs. of ammonia over a 10 minute period, the plume would travel 0.9 miles at concentrations at or above the endpoint. Sensitive receptor information is provided in the RMP*Submit. Using 1990 Census data, the population potentially affected within the worst-case release scenario circle is 13,000 people. There are no environmental receptors within the worst case release scenario circle. In the alternative release scenario, a release from a pressure safety valve on the evaporative condenser located outdoors was modeled as a release of ammonia vapors. For a release of 41 lb/min of anhydrous ammonia, the model calculated that the plume wo uld travel less than 0.1 mile at concentrations at or above the endpoint. The alternative release scenario circle includes the nearby commercial facilities, residences, and roadways. Using 1990 Census data, the population potentially affected within the worst-case release scenario circle is 150 people. There are no sensitive receptors or environmental receptors within the alternative release scenario circle. General Accidental Release Prevention Program and Chemical-Specific Prevention Steps A PSM program, which meets the requirements of the general accidental release prevention program, has been developed at Producers to address the anhydrous ammonia system. The PSM program includes the following chemical-specific prevention steps: Written process safety information, including information pertaining to the hazards of ammonia, the technology of the process, and the equipment in the process has been compiled. An initial Process Hazard Analysis (PHA) was performed and will b e updated and revalidated at least every five years. Written operating procedures have been developed and implemented, and will be reviewed at least annually. Safe work practices, such as lockout/tagout, confined space entry, opening process equipment or piping, and control over entrance into the facility have been developed and implemented. Each employee involved in operating the ammonia system has received initial training and refresher training at least every three years. Written mechanical integrity procedures have been established and implemented. A Management of Change (MOC) program has been developed and implemented to address all proposed changes to the ammonia system. Pre-startup safety reviews are performed when a modification is made to the ammonia system that is significant enough to require a change in the process safety information. Audits will be conducted at least every three years to evaluate compliance with the CalARP regulations. Incident inve stigation procedures have been established. A written plan of action regarding the implementation of employee participation has been developed and implemented. Hot work permits are issued for all hot work operations conducted on or near the ammonia system. A Contractor Safety Policy has been developed and implemented. To ensure that the general accidental release prevention program and the chemical-specific prevention steps are implemented, Producers has assigned overall responsibility for the RMP elements to the Operations Manager. The Operations Manager has the overall responsibility for the development, implementation, and integration of the RMP elements. Five-Year Accident History Producers has not had any accidental releases from the ammonia-based refrigeration system that have resulted in deaths, injuries, or significant property damage on site, or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage in the last f ive years. Emergency Response Program Producers has established an emergency action plan and a chain of command to respond to emergencies and to notify emergency responders when there is a need for a response. However, an emergency response program does not need to be developed for the facility since Producers employees will not respond to accidental releases of ammonia, the facility is included in the community emergency response plan, and appropriate mechanisms are in place to notify emergency responders. Planned Changes To Improve Safety Based on the PHAs performed in March, 1995, no changes were recommended. There are currently no planned changes to improve safety on the existing ammonia refrigeration system. Since the last PHAs, there have been several "replacements in kind" (such as replacement of the milk silos) that have helped maintain the mechanical integrity of the system. Through accidental release prevention program program, Producers regularly evaluates the need f or any additional changes to improve safety. |