Alta-Dena Certified Dairy, Inc. - Executive Summary |
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General Executive Summary for Ammonia Refrigeration Facilities 1. Accidental Release Prevention and Emergency Response Policies We at Alta-Dena Certified Dairy, Inc. are strongly committed to employee, public and environmental safety. This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. Unforseeably, if a release should occur, our highly trained emergency response personnel are at hand to control and mitigate the effects of a release. We are also completely coordinated with the Los Angeles County Fire Department; Hazardous Materials Response Unit serving the City of Industry Area, which provides additional emergency response expertise. 2. The Stationary Source and the Regulated Substance s Handled Our facility's primary activities encompass production of fluid milk products, condensed milk products, cultured milk products, cottage cheese, butter, ice cream, non-carbonated fruit drinks, and ice. We have one regulated substance present at our facility; ammonia (anhydrous) used as a refrigerant. The maximum inventory ammonia (anhydrous) is 44,000 pounds and is contained within a single large refrigeration system serving the various production and process areas within the Alta Dena Certified Dairy, City of Industry Plant. 3. The Worst Case Release Scenario and the Alternative Release Scenario, including administrative controls and mitigation measures to limit the distances for each reported scenario To perform the required offsite consequence analysis for our facility, we have used the EPA's OCA Guidance Reference Tables or Equations. The following paragraphs provide details of the chosen scenarios. The worst case release scenario submitted for Program 2 and 3 toxic substances as a class involves an hypothetical catastrophic release from the ammonia refrigeration system. In this scenario 5068.34 pounds of ammonia are released from the controlled pressure receiver, the largest vessel in the system. The toxic liquid released inside an enclosed building and is assumed to form a one cm deep pool from which evaporation takes place. The entire pool is estimated to evaporate over 10-minutes. Passive mitigation systems such as the building enclosure is taken into account to calculate the scenario. The alternative release scenario for ammonia involves an hypothetical release from ammonia piping on the roof above the refrigeration equipment room. The scenario involves the release of 46.22 pounds of ammonia from a pipe flange or pipe fitting. The release is assumed to be controlled by emergency shutdown systems, monitoring and manual shutdown. The release is estimated to occur over a 15-minute period prior to the implementation of control measures by system operational and emergency response personnel. 4. The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR Part 68 of the EPA. This facility was designed and constructed in accordance with Uniform Building Code. The following sections briefly describe the elements of the release prevention program that is in place at our stationary source. Process Safety Information Alta-Dena Certified Dairy, Inc. maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. Process Hazard Analysis Our facility conducts comprehensive studies to ensure that hazards associated with our processes are identified and controlled efficiently. The methodology known as a Hazards and Operability Study (HAZOP) was used to carry out the process hazard analysis. The studies are undertaken by a team of qualified personnel with expertise in engineering and process operations and are revalidated at a regular interval or with major system component changes or additions. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 05/27/1999. Operating Procedures For the purposes of safely conducting activities within our covered processes, Alta-Dena Certified Dairy, Inc. maintains written operating procedures. These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the processes. Training Alta-Dena Certified Dairy, Inc. has a comprehensive training program in place to ensure that employees who are operating processes a re competent in the operating procedures associated with these processes. Refresher training is provided at least every three years and more frequently as needed. Mechanical Integrity Alta-Dena Certified Dairy, Inc. carries out highly documented maintenance checks on process equipment to ensure proper operations. Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps. Maintenance operations are carried out by qualified personnel with previous training in maintenance practices. Furthermore, these personnel are offered specialized training as needed. Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. Management of Change Written procedures are in place at Alta-Dena Certified Dairy, Inc. to manage changes in process chemicals, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 05/27/1999. Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. Pre-startup Reviews Pre-startup safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Alta-Dena Certified Dairy, Inc. and are coordinated with the management of change element of the safety program. The most recent review was performed on 05/27/1999. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. Compliance Audits Alta-Dena Certified Dairy, Inc. conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented. The most recent compliance audit was conducted on 05/27/ 1999. These audits are carried out at least every three years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. Incident Investigation Alta-Dena Certified Dairy, Inc. promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a regulated substance. These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring. All reports are retained for a minimum of five years. Employee Participation Alta-Dena Certified Dairy, Inc. truly believes that process safety management and accident prevention is a team effort. Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements. In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including informat ion resulting from process hazard analyses in particular. Contractors On occasion, our company hires contractors to conduct specialized maintenance and construction activities. Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out. Alta-Dena Certified Dairy, Inc. has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 5. Five-year Accident History Alta-Dena Certified Dairy, Inc. has had an excellent record of preventing accidental releases over the last five years. Due to our stringent release prevention policies, there has been no serious accidental release that caused offsite impacts during this period. 6. Emergency Response Plan Alta-Dena Certified Dairy, Inc. carries a written emergency response plan to deal with acci dental releases of hazardous materials. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. To ensure proper functioning, our emergency response equipment is regularly inspected and serviced. In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. 7. Planned Changes to Improve Safety Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Enhanced communications and coordination proccedures between plant safety management and process operations personnel, addition and reinforcement of perimeter ammonia monitoring, improved preventive maintenance,scheduled equipment replacement, and local agency communication and coordination are some of the steps we are taking to improve safety at our facility. These changes are expected to be implemented by mid-April, 2000. |