USS POSCO Industries - Executive Summary

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USS-POSCO Industries (UPI) has a long-standing commitment to business  
principles which promote the safe, ethical operation of its steel  
manufacturing facilities in Pittsburg, California.  These principles have  
resulted in clear UPI business strategies that call for continual improvement  
of safety, quality, customer satisfaction, protection and preservation of the  
environment, and community responsibility.  Implementation of, and  
adherence to, these business strategies requires the full commitment of all  
UPI employees. 
UPI policy dictates that each division continuously identify methods to  
reduce the use of hazardous materials and to reduce the risk to the community  
and environment through implementation of inherently safer technology and  
procedures.  This commitment to safe and environmentally sound operations  
is documented in the facility  
policy statements and the manual "Principles of  
Accident Prevention", which are available to all employees. UPI stresses safe  
and environmentally sound operations in employee training programs, and in  
written materials  (such as safety and health bulletins) periodically provided  
to all employees.  UPI safety and environmental programs include monthly  
safety meetings for all employees and a joint worker/company safety  
committee. UPI supervisory and management personnel conduct both  
regularly scheduled and unscheduled (surprise) audits of internal safety,  
housekeeping and environmental compliance and practices. 
Description of Stationary Source 
USS-POSCO Industries (UPI) is located at 900 Loveridge Road in the city of  
Pittsburg, approximately 1/2 mile north of Highway 4.  The UPI property  
occupies approximately 490 acres.  It is bordered by the New York Slough of  
the San Joaquin/Sacramento River on t 
he north and by open space and  
industrial facilities in all other directions.  The nearest residences are  
located approximately 3/4 miles to the southwest of  any facilities handling  
chemicals regulated under the RMP Rule. 
The plant employs approximately 1000 people.  The major divisions within  
the UPI facility include: the Rolling Division, the Tin Products Division, the  
Sheet Products Division, and the Technology Services Division. 
The Rolling Division is responsible for the initial steel processing operations  
of the facility.  It typically operates continuously, 24 hours per day, seven  
days per week, with management supervision continuously present. 
The Tin Products Division is responsible for the subsequent steel processes  
that result in the production of tinplate products.  The processing facilities  
include two Electrolytic Tinning Lines (ETLs), where sulfuric acid is utilized  
for pickling and chrome recovery, and a continuous annealing line.  As in the  
Rolling Divis 
ion, operation and supervisory coverage are continuous. 
The Sheet Products Division is responsible for subsequent processes that  
result in the production of sheet products, cold rolled sheets, and galvanized  
sheets.  The facilities include a Kawasaki Multipurpose Continuous  
Annealing Line (KMCAL), where ammonia is utilized for reducing NOx  
(nitrogen oxide compounds) emissions from the furnace exhaust stack. 
The annealing furnaces operated by the Tin Products and Sheet Products  
Divisions require internal atmospheres consisting of hydrogen diluted in  
nitrogen (concentrations ranging from 5 to 30 volume percent hydrogen).   
These reducing atmospheres are required to exclude moisture and air from  
the furnaces to prevent oxidation of the steel at the high furnace temperatures. 
The Technology Services Division provides engineering services and  
maintenance support for the facility.  This Division also operates the facility  
utility systems including a Demineralization Unit, where s 
ulfuric acid is used  
for both reverse osmosis and demineralized water purification systems. 
Hydrogen and anhydrous ammonia are the only two state or federally  
regulated substances present at UPI.  The sulfuric acid solutions used at UPI  
are at concentration of 93 weight percent or less and, thus, fall below the  
concentration threshold established under the RMP Rule. 
Description of the Ammonia Process 
Anhydrous ammonia is used at UPI for reducing NOx (nitrogen oxide  
compounds) emissions from the KMCAL furnace exhaust stack.  NOx  
compounds in the atmosphere are one of the significant precursors to  
photochemical smog.  The ammonia, in the presence of a catalyst,  
decomposes NOx compounds into nitrogen (N2) and water (H2O).   
Anhydrous ammonia is stored in liquid form in an outdoor 12,000-gallon  
supply vessel.  The vessel sits on a concrete pad that is surrounded by a  
locked fence.  
The amount of ammonia stored in the supply vessel is limited to 85% of the  
vessel capacity, w 
hich is 10,200 gallons (52,500 pounds at 60oF).   
Instrumentation on the vessel includes a low and low-low level switch, a  
level indicator, a pressure gage, and a temperature indicator.  The ammonia  
supply vessel has a design pressure of 265 psig and is protected by two 1-1/4- 
inch relief valve manifolds, each with two separate relief valves that vent to  
the atmosphere (one relief valve on each manifold is valved into service at  
any time). 
Ammonia is withdrawn from the vapor space of the supply vessel via a 3/4- 
inch line.  The line feeds into a pressure-reducing valve, also on the concrete  
pad.  The pressure is reduced to approximately 30 psig, at which point the  
line expands to 1-inch diameter.  The 1-inch line runs supported and above  
ground into the Sheet and Tin Mill Building.  Inside the Sheet and Tin Mill  
Building, it runs through an underground trench and an overhead pipeway to  
a fenced-in flow control station. 
The flow control station consists of a pressure regulato 
r, a temperature  
transmitter, a pressure transmitter, a flow transmitter, a nitrogen purge line, a  
flow control valve, and a solenoid shut-off valve.  The flow control station  
regulates the ammonia vapor flow to the furnace stack as a function of the  
flue gas flow rate.  The solenoid valve shuts off the ammonia supply in the  
event of a furnace upset, such as low temperature in the furnace stack.  This  
precaution is necessary since ammonia entering the flue gas at a temperature  
of less than 392oF can form the explosive compound ammonium nitrate  
The 1/2-inch diameter ammonia vapor supply line exits the flow control  
station and travels up a structural steel column to the flue gas injection point.   
An air blower mixes air with the ammonia stream, and the mix enters the  
furnace stack through a manifold.  
The pressure in the ammonia supply vessel varies with the ambient  
temperature.   A vaporizer is provided to ensure that sufficient ammonia  
vapor is available during 
cold ambient conditions.  The vaporizer heats the  
liquid as necessary to maintain a vessel pressure above 80 psig (vapor  
pressure of ammonia at approximately 53oF).  The vaporizer switches off  
when the vessel pressure exceeds 100 psig (approximately 64oF).  A high- 
high pressure switch will also shut down the vaporizer at 200 psig  
(approximately 101oF).  An independent high temperature switch set at  
100oF (corresponding to a vapor pressure of approximately 197 psig) will  
also shut down the vaporizer. 
Ammonia is received in tank trucks and is transferred into the storage tank  
through a two inch liquid fill line.  Vapors displaced from the storage tank  
return to the tank truck via a 1-inch pressure equalizing line.  The pressure  
equalizing line, which connects the vapor space of the supply vessel to the  
vapor space of the tanker truck, is opened to equalize any pressure  
differences between the systems prior to loading.  The liquid fill line enters  
the top of the tank  and t 
he liquid ammonia is discharged into the tank vapor  
Characteristics and Hazards of Ammonia 
Ammonia is a colorless gas with a very irritating odor, and is highly soluble  
in water.  When ammonia is released to the atmosphere, it creates a dense,  
white fog because it reacts with water in the atmosphere. 
At normal temperatures and pressures, anhydrous ammonia is a gas.  It is  
easily liquefied by pressurizing in a container and is commonly transported  
and stored as a liquid.  At atmospheric pressure, the liquid density of  
ammonia is approximately 2/3 that of water, and ammonia gas is lighter than  
Physiological Effects 
Ammonia in the ambient air has an intense, acute effect upon the mucous  
membranes of the eyes, nose, throat, and lungs.  Exposure to a high  
concentration of ammonia can produce corrosive action on these tissues,  
which can lead to impairment of the respiratory system and, possibly, death.   
Ammonia is a regulated substance under the RMP Rule due to th 
is acute  
toxicity. A more detailed description of the health effects of ammonia is  
presented in the offsite consequence analysis section of this document. 
Description of the Hydrogen Process 
Liquid hydrogen is stored in two double-walled stainless steel pressure  
vessels (one 9000-gallon, one 18,000 gallon).  Administrative controls limit  
the contents of the larger tank to no more than 9500 lbs of liquid hydrogen. 
The hydrogen is delivered, and unloaded by the supplier, who also has  
responsibility for the operation, inspection and maintenance of the hydrogen  
storage system. The hydrogen is stored at a pressure of approximately 40  
psig; an economizer that circulates vaporized hydrogen to the tank headspace  
maintains hydrogen storage pressure.  The storage vessels are pressure  
protected by primary relief valves, installed spare relief valves, and rupture  
discs.  The relief valves are set to open at 150 psig.  Both the relief valves and  
the rupture discs discharge to atmosphe 
Liquid hydrogen is passed through ambient temperature vaporizers.  The  
vaporized hydrogen is then transferred to mixers and furnaces through a  
series of pressure reducing stations.  The first, immediately downstream of  
the vaporizers, drops the hydrogen pressure to approximately 15 psig.  An  
additional pressure reducing station further drops the pure vaporized  
hydrogen system pressure to 12 psig. 
The vaporized hydrogen is split into two separate process streams.  One  
stream goes directly to two of the four annealing furnaces through an  
additional pressure reducing station, set at approximately 5 psig.  The  
remaining pure vaporized hydrogen is piped to nitrogen mixing stations in the  
West Gas Room and in the KMCAL Gas Room. There are three parallel  
mixing systems in the West Gas Room and a single system in the KMCAL  
Gas Room.  Each mixing system includes a mixer, a dryer, and treating  
In the mixing systems, hydrogen is mixed with nitrogen to produce a 5%  
hydrogen, 95% nitrogen mixture (identified as HN).  This HN mixture is used  
for producing a reducing atmosphere in the annealing furnaces to prevent  
oxidation of the steel at high temperatures.  The pure hydrogen and the HN  
flows are adjusted to control the HN concentration in the furnaces to the  
appropriate value for efficient annealing.  
In addition to supplying HN to the furnaces for annealing, HN is stored in a  
purge gas storage system.  The purge system consists of three purge tanks,  
two having a capacity of 2500 cubic feet, and one having a capacity of 1650  
cubic feet.  The purge tanks provide an emergency deluge of 5% HN to the  
two galvanizing furnaces that uses a 30% hydrogen atmosphere.  This dilute  
HN addition is intended to lower the hydrogen concentration in the furnaces  
in the event that a potentially explosive atmosphere should develop. 
The entire hydrogen system, including the HN system, is provided with  
analyzers, alarms, and shutdown safety interlocks des 
igned to detect, prevent,  
and counteract, the causes and effects of explosive atmospheres in the  
furnaces.  Specifically, if conditions are detected that could lead to a  
potentially explosive condition within the furnace, the safety systems: 
o Stop all hydrogen flows to the furnaces 
o Activate the emergency purge system 
o Isolate HN and shutdown furnaces upon loss of nitrogen flow or supply,  
 or upon detection of high oxygen concentrations in the system. 
Characteristics and Hazards of Hydrogen 
Liquefied hydrogen is transparent and  is only 1/14 as dense as water and its  
vapor is only about 1/14 as dense as air. Hydrogen burns readily in air with  
an almost invisible flame which rapidly propagates through the mixture.   At  
atmospheric pressure its flammable range is approximately 4 percent to 74  
percent by volume of hydrogen in air. Hydrogen is a regulated substance  
under the RMP Rule because to its flammability. 
Physiological Effects 
Hydrogen is nontoxic but can cause asp 
hyxiation when it displaces the  
oxygen in a confined space without adequate ventilation. Hydrogen is  
colorless, odorless, and tasteless and, thus, offers no discernible warning  
The approaches used in determining possible release rates and durations were  
unique to the various scenarios and are discussed in the scenario-specific  
All scenarios were modeled as toxic gas releases.  In other words, all of the  
liquid released was assumed to either vaporize or to be entrained as aerosol  
droplets in the cloud; i.e., there was no rainout of liquid droplets to form a  
liquid pool that would subsequently vaporize.  This is a conservative  
assumption with respect to the estimation of the effect distance.  However, it  
is a reasonable assumption based upon current knowledge of how flashing  
liquid releases behave. 
The effect zone for toxics is determined to estimate how far potentially  
hazardous concentrations o 
f the toxic will extend downwind.  Since it is  
typically not possible to predict or exclude particular wind directions, the  
potential effect zone is defined as a circle, centered at the point of release,  
with a radius equal to the downwind distance to the threshold concentration  
of concern.  The concentration of concern, as specific in the RMP Rule, is the  
ERPG-2 concentration which, for ammonia, is 200 ppm (0.14 mg/l).   
Potential effect distances were determined using the EPA's RMP Offsite  
Consequence Analysis Guidelines and the associated software tool,  
RMP*Comp, assuming the EPA-recommended "typical" meteorological  
conditions of D atmospheric stability and a wind speed of 3 m/second.  Urban  
terrain was assumed.  
Residential population estimates within the potential effect zone were  
determined using Landview III software (produced by the US Census  
Bureau).  This tool is based upon the 1990 census database, which provides  
population figures aggregated by census count 
ing block.  
Non-residential public receptors were identified using a number of  
o Some schools, parks, public buildings, shopping centers, etc., can be  
 identified from USGS survey maps; 
o The Delorme. Phone Search USA. software (Ver. 4.0, 1998) was  
 searched by SIC code to identify day care centers, nursing homes, etc.  
 within a three-mile radius of the UPI site; 
o An internet "yellow pages" utility was used to search the 94509  
 and 94565 zip codes for terms such as "child care", "adult care",  
 "hospitals", "long-term care centers", and "nursing homes".  Note that the  
 greatest potential effect distance does not extend beyond the two zip  
 codes that were searched.  
o For schools, searches were of the school district websites, followed up by  
 phone conversations with district office personnel, as necessary. 
Environmental receptors were identified from the appropriate USGA survey  
Well-documented offsite consequence analyses are essential to the adequate  
communication of potential hazards at UPI.  Consistent with the requirements  
of the RMP Rule, and EPA's guidance, UPI has conducted offsite  
consequence analyses (OCA) for both the ammonia and hydrogen systems,  
using the EPA's RMP Offsite Consequence Analysis Guidelines for the  
Worst-Case Scenarios (WCS). 
Following are the results from the WCS OCA. 
Ammonia Worst Case Release Scenario 
The Worst-Case Scenario (WCS) for toxic substances at UPI is the release of  
the total contents of the anhydrous ammonia (NH3) vessel.  The vessel is  
assumed to contain a maximum of 52,500 lbs of NH3 which is assumed to be  
released over a period of 10 minutes.  Although there are installed control  
measures that would prevent or mitigate an actual release event, no credit for  
mitigation measures was taken into account for this scenario.  The results for  
the WCS were generated from the EPA's RMP Offsite Consequenc 
e Analysis  
The maximum distance to the toxic endpoint of 200 ppm (the ERPG-2 for  
NH3) for this WCS is 2.6 miles.  Using census data from LandView III, the  
estimated population within the worst-case scenario circle is 52,000. Sixteen  
schools are within the WCS ERPG-2 circle, as well as three child day care  
facilities and six senior and long-term care facilities. 
Since this WCS reaches off-site receptors, the ammonia process falls under  
Program Level 3 of the RMP Rule.  There is only a single process containing  
NH3 and there are no other regulated toxics at UPI. 
Hydrogen Worst Case Release Scenario 
The Worst-Case Scenario (WCS) for flammable substances at UPI is the  
release of the total contents of the larger liquid hydrogen (H2) vessel.  The  
vessel is assumed to contain a maximum of 9500 lbs of H2 which is assumed  
to be released immediately, leading to a vapor cloud explosion.  Although  
there are installed control measures that would prevent or mitigate an act 
release event, no credit for mitigation measures was taken into account for  
this scenario.  The results for the WCS were generated from the EPA's RMP  
Offsite Consequence Analysis Guidelines. 
The maximum distance to the explosion overpressure endpoint of 1 psig for  
this WCS is 0.2 miles.  Since this WCS does not extend beyond the UPI  
facility perimeter, no residences or other off-site receptors are impacted by  
the WCS.  As will be shown, the hydrogen process meets all additional  
requirements as a Program 1 process.  There are no other processes at UPI  
containing greater than the threshold quantity of flammables. 
Offsite consequence analysis is also a useful tool in helping UPI to coordinate  
with the CCCHSD Incident Response Team in emergency response planning.   
To do this, UPI modeled a series of three potential alternative release  
scenarios (ARS) to establish a reasonable "outer bound" for emergency  
response planning and to provide  
for explaining potential hazards to the  
Ammonia Alternative Release Scenarios 
1. Failure of unloading hose.  This ARS assumes that the 2" flexible line  
from the tank truck to the rigid UPI piping is severed, resulting in a twenty- 
minute release at a rate of approximately 1200 lb/min of ammonia. The  
release rate is limited by the excess flow valve at the tank truck connection.   
Twenty minutes was the time determined for the release to be detected, for  
response personnel to don the required protective equipment, and to shut the  
isolation valves on the tank truck and the UPI piping to stop the leak.  The  
actual release duration may be appreciably shorter, since the unloading  
process is continuously attended by the truck driver and there are two remote  
shut-off controls located at different points on the tank truck.  These shut-offs  
are intended to be used to close the tank outlet valve prior to the driver  
evacuating from the vicinity of the truck.   
Using the E 
PA-recommended meteorological conditions, the maximum  
distance to the toxic endpoint of 200 ppm (ERPG-2) is only 0.3 miles. There  
are no residential populations or public receptors, other than industrial  
facilities, within this radius. 
2. Relief valve discharge.  As previously described, the emergency pressure  
relief requirements for the storage tank are based upon the assumption of an  
external fire heating the tank, boiling the liquid ammonia, resulting in an  
internal overpressure that must be relieved.  The required venting capacity  
was previously determined in accordance with the requirements of ANSI  
standard K 61.1. At any time, there are two relief valves in service on the  
tank.  Each relief valve individually has the required venting capacity.  (There  
are actually two pairs of relief valves on the tank, manifolded so that one  
valve in each pair can be valved into service while the other is isolated for  
This ARS assumes that a single vessel relief valve open 
s resulting in a  
twenty-minute release at a rate of approximately 350 lb/min of ammonia (the  
actual, full flow capacity of the relief valve).  Twenty minutes was the time  
determined for the release to be detected, for response personnel to don the  
required protective equipment, and to stop the release. 
This actual release rate and duration could be appreciably less.  The ammonia  
tank is readily visible from the continuously-manned security guard station  
ensuring prompt detection. An actual fire exposure would most likely ignite  
and consume the ammonia discharging from the relief valve. 
Using the EPA-recommended meteorological conditions, the maximum  
distance to the toxic endpoint of 200 ppm (ERPG-2) is only 0.2 miles. There  
are no residential populations or public receptors, other than industrial  
facilities, within this radius. 
3. Failure of a 3/4 inch diameter liquid line from vessel.  This ARS assumes  
that the 3/4" liquid line from the vessel to the vaporizer is severed 
, resulting  
in a twenty-minute release at a rate of approximately 250 lb/min of ammonia.  
The release rate is limited by the excess flow valve at the tank outlet  
connection.  Twenty minutes was the time determined for the release to be  
detected, for response personnel to don the required protective equipment,  
and to shut the isolation valves necessary to stop the leak.    
Using the EPA-recommended meteorological conditions, the maximum  
distance to the toxic endpoint of 200 ppm (ERPG-2) is only 0.1 miles. There  
are no residential populations or any other public receptors within this radius. 
Other smaller liquid releases and various vapor releases are possible, but their  
effects would be markedly less severe than those discussed above. 
A number of mitigation systems serve to: make releases less likely to occur;  
to reduce the rate or duration of a release should it occur; or to reduce the  
consequences of the leak should it occur.  These mitigation systems,  
including those dis 
cussed above, include: 
o NH3 detection systems with alarms at the tank and at the control station  
 within the building; 
o Remote isolation of the tank truck unloading valve; 
o Excess flow valves on storage tank and tank car liquid and vapor transfer  
 lines (exception: there are no excess flow valves in the relief valve lines); 
o Ammonia storage vessel was designed and built in accordance with the  
 ASME Code for Pressure Vessels, Section VIII, Division 1; 
o Ammonia storage vessel, relief valves, and other safety systems inspected  
 on a periodic basis; 
o Fire hose with fog nozzle located adjacent to storage facility, to be used  
 in "knocking down" the water-soluble ammonia vapors that would result  
 from a release; 
o Redundant relief valve protection on the storage vessel, and an additional  
 relief valve on the vaporizer; 
o High temperature and high pressure interlocks on the vaporizer; 
o Robust barricades to prevent vehicles from impacting the ammonia- 
 bearing equipment; 
o Locked, chain link enclosure surrounding the storage vessel, the  
 vaporizer, and the primary pressure reducing station and the flow control  
 station inside the Sheet and Tin Mill Building is similarly enclosed; 
o The majority of the ammonia transfer lines are routed either on elevated  
 pipe racks or in an underground trench, to limit the potential for impact  
o The majority of the piping connections are socket-welded to minimize  
o The pad under the tank is sloped to a liquid drain that would divert any  
 ammonia spilled on the ground to the facility waste water treatment plant,  
 minimizing the amount of ammonia vaporized; 
o The ammonia storage vessel is within a direct line of sight of the nearby  
 security gate, which is manned 24 hours a day, 7 days a week.  
Hydrogen Alternative Release Scenarios 
Since the liquid hydrogen process qualifies for Program Level 1, no ARS are  
required for hydrogen. 
Note that  
the anhydrous ammonia process is the only Program level 2 or 3  
process and, therefore, is the only process requiring a RMP prevention  
program.  The following information is specific to the anhydrous ammonia  
Management System 
UPI has developed a formal management system for planning, organizing,  
implementing and controlling the risk management program elements.  This  
management system is consistent with the recommendations contained in  
CCPS Plant Guidelines for Technical Management of Chemical Process  
Safety.  This management system satisfies the requirements of ' 68.15 of the  
RMP Rule, and ensures that the risk management program elements are  
developed, implemented, and continually improved. The management system  
activities are further discussed below. 
o Planning - UPI has an overall risk management program policy that  
 clearly identifies the goals and objectives of the risk management program. 
o Organizing - Individuals responsible for each risk management pr 
 element have been designated.  The designated individuals are responsible  
 for developing and maintaining policies and procedures for each risk 
 management program element that meet program goals and objectives.  
o Implementing - Detailed responsibilities for program implementation  
 may be delegated to other individuals.  Such individuals are trained on  
 their responsibilities, and the corresponding procedures, before they are  
 allowed to perform their responsibilities. Strict adherence to procedures is  
 emphasized.  Refresher training is provided on an as-needed basis.   
o Controlling - Members of management and the individuals responsible  
 for each risk management prevention program element periodically  
 conduct internal reviews or audits against the goals and objectives of the  
 element. All records associated with the prevention program elements are  
 retained for a minimum of five years unless otherwise specified in the  
 RMP Rule, to permit periodic 
, comprehensive audits.  Weaknesses in  
 program elements, or in their implementation, that may be discovered  
 during internal audits or reviews are corrected. 
Prevention Program: 
The prevention program elements described in the following section represent  
an integrated system of administrative controls intended to ensure the safety of  
workers, the public, and the environment.  Many of these prevention program  
elements (e.g., PHAs, compliance audits, incident investigation) result in the  
development and implementation of additional safeguards (i.e., administrative  
and engineering controls).  Those recommendations that are planned for  
implementation at UPI will be discussed in "Planned Changes to Improve  
Safety".  Those applicable safeguards that have already been implemented or  
that were part of the original design are described below.  These safeguards  
prevent, detect, or mitigate the effects of accidental releases of regulated  
ION: Process safety information (PSI)  
development, dissemination, and use is vital to the effective operation of a  
stationary source.  Personnel use information regarding chemical hazards,  
equipment specifications, and operating limits in daily and strategic decision  
making.  Accurate and complete information that is readily accessible enables  
personnel to identify and understand the hazards posed by those processes  
involving anhydrous ammonia and is, therefore, a basic component of the  
prevention program. 
Requisite PSI, satisfying the regulatory requirements of ' 68.65 of the RMP  
Rule, was compiled prior to the original process hazard analysis (PHA)  
conducted in 1995.  Implementation of the management of change (MOC)  
and pre-startup safety review (PSSR) elements ensures that the PSI is  
maintained current and accurate. Personnel have 24-hour access to the PSI  
required by their responsibilities.  
The following PSI is particularly important to the prevention program: 
o Information pertaining to the hazards of the regulated substances in  
 the process - The following information is available in the material safety  
 data sheet (MSDS) maintained for anhydrous ammonia: toxicity  
 information, permissible exposure limits, physical data, reactivity data,  
 corrosivity data, and thermal and chemical stability data; 
o Information pertaining to the technology of the process - The  
 following information is available in the facility operating procedures  
 and/or the original RMPP documentation for the facility: a process flow  
 diagram for the ammonia process, a description of the process chemistry,  
 safe upper and lower parameter limits (e.g., temperature, pressure), and  
 an evaluation of the consequences of deviations from those parameter  
o Information pertaining to the equipment in the process - The  
 following information is maintained: accurate or redlined piping and  
 instrumentation diagrams (P&IDs), a listing of the vari 
ous safety systems  
 (e.g., alarms, interlocks, shutdowns, suppressions systems, relief  
 systems), and specifications of materials of construction for the process  
PROCESS HAZARDS ANALYSIS: By systematically examining each process and  
identifying hazards associated with the operation of a covered process, UPI  
has been able to plan and take appropriate action to improve the safety of  
employees, the community, and the environment.  UPI performed a Process  
Hazard Analysis (PHA) on the ammonia storage process with the objectives  
of: identifying hazards; identifying credible human errors and/or equipment  
failures that could lead to an accidental release; evaluating the likelihood  
and/or consequence of various scenarios; determining if existing prevention  
steps/controls were sufficient; and, where existing controls were judged  
insufficient, identifying additional steps that could be taken to control the  
The PHA for the process was previously conducted 
to comply with the  
RMPP regulation.  This methodology was chosen due to the relatively  
complex design of the ammonia storage and transfer system, as well as  UPI's  
belief that a HAZOP would provide a high level detail for analysis of this  
The following objectives were addressed by the PHA: 
o Identify the hazards of the substance and of the process; 
o Identify the applicable external events (including seismic events) that  
 could lead to a release; 
o Identify possible equipment failures or human errors that could lead to a  
o Evaluate the consequences and likelihood of the accident scenarios; 
o Evaluate safeguards used to prevent or mitigate failures or errors; 
o Consider steps needed to mitigate the risks, including changes needed to  
 equipment design, operating procedures, process conditions, etc.; and 
o Propose recommendations/action items to mitigate the hazard.  
The PHA was conducted by a multi-disciplinary team that systematically  
identified haz 
ards and operability problems by searching for deviations from  
the design intent of each portion of the process.  The team considered the  
causes and effects of these deviations to identify hazardous conditions and  
their consequences, listed existing safeguards, and made recommendations  
for changes where appropriate. 
The PHA team was composed of qualified personnel including a team leader  
with 15 years of professional safety and engineering experience; the team  
leader had training and experience in conducting PHAs using techniques such  
as the HAZOP, What If and Checklist methodologies. 
The team identified and evaluated hazards of the process as well as accident  
prevention and mitigation measures, and made suggestions for additional  
prevention and/or mitigation measures when they deemed such measures are  
necessary.  The PHA was documented on worksheets containing a  
description of each process node and its design intent, a list of possible  
deviations, causes of deviation 
s, consequences, safeguards, and required  
action items/investigations/questions for further study.  This documentation  
will be maintained for the life of the facility.  
The study was conducted primarily using the HAZOP Study deviation  
guideword technique.  The guidewords, in conjunction with key process  
parameters, prompt the HAZOP Study team to brainstorm possible causes  
and potential consequences of deviations from design operation.  For  
example, the deviation "NO FLOW" would prompt the leader to ask the team,  
"What could cause no flow in this section or line segmento"  The "Possible  
Cause" and "Potential Consequence" scenarios are documented in the study  
worksheets.  The "Existing Systems and Procedures" (safeguards) that reduce  
the risk associated with the specific cause/consequence scenario are then  
discussed and documented.  For scenarios involving significant risk,  
"Recommendations" that the team believes may further reduce risk or  
improve the operability of the  
facility are also documented. 
Wrap-up Discussions 
The HAZOP Study technique was used to analyze line-by-line the ammonia  
handling systems at UPI.  However, the HAZOP Study technique may not  
document all the general issues affecting the health and safety of the  
workplace employee or identify all potential ammonia releases that could  
have off-site impact.  In addition to the line-by-line discussions that were  
documented in the section worksheets, "Wrap-up Discussions" were held at  
the end of the HAZOP Study to ensure that these general topics were  
The "Wrap-up Discussions" topics covered in this study included: 
o Safety/Fire Protection 
o Emergency Response 
o Procedures 
o Loss of Utilities 
o Siting/Control Room Location 
o Previous Incidents 
o Human Factors 
o Testing and Inspection 
o Maintenance 
o External Events 
o Other Hazards Analysis Studies 
The HAZOP Study team members used a risk matrix to qualitatively assess  
the risk associated with each cause/consequ 
ence scenario that was developed  
during the study.  The matrix used for this HAZOP Study is based on the  
information provided in the Contra Costa County Health Services  
Department (CCCHSD) RMPP Guidelines (March 1993), page 30.  
Seismic Evaluation 
A seismic evaluation was performed in accordance with the Proposed  
Guidance for RMPP Seismic Assessments, June 1992, prepared for the RMPP  
Sub-Committee of the Southern California Fire Chiefs Association.  The  
scope of work included a visual walkdown review of equipment and piping  
identified as containing AHMs, a quantitative evaluation of selected  
structures where warranted, and recommendations for reducing the risk of a  
potential ammonia release.  The seismic evaluation is intended to provide  
reasonable assurance that a major earthquake will not result in a release of  
acutely hazardous materials having potential off-site consequences.   
The key feature of the evaluation methodology was an on-site walkdown  
review of the  
existing facility.  This was primarily a systematic visual review  
that considered the physical condition of the installation.  The engineer  
performing the review investigated for potential seismic vulnerabilities,  
focusing on proven failure modes from past earthquake experience and  
engineering judgment.  The walkdown review also emphasized the primary- 
seismic-load resisting elements and the potential areas of weakness due to  
design, construction, or modification practices.  Special emphasis was placed  
on details that may have been designed without consideration of seismic  
Where necessary, specific items could be selected for analytical investigation.   
These analytical reviews typically focus on items that have unusual designs,  
"weak links," or other attributes that may indicate insufficient capacity to  
resist the seismic loads from a large earthquake. No such analytical  
evaluations were required for the UPI evaluation.  Potential seismic  
vulnerabilities were read 
ily evaluated using engineering judgment and  
The seismic review was performed by a registered professional engineer  
(civil) with more than 10 years of experience performing seismic evaluations  
of structures and equipment in industrial and power facilities.  The engineer  
had performed several RMPP evaluations in Contra Costa County, and had  
also participated in post-earthquake reconnaissance investigations after  
several major earthquakes, focusing on equipment and structural damage in  
industrial and power facilities 
The primary deficiencies identified with the ammonia system included a  
possible interaction hazard with the abandoned, unanchored tanks just west  
of the ammonia storage tank, interaction with a 3-inch diameter line in the  
Sheet Mill Building, lack of restraint on the lines at the injection point, and  
excess displacement of the exhaust duct.  Any one of these deficiencies could  
have resulted in a release of gaseous ammonia. 
Resolution of PHA 
The team findings for the PHA and seismic assessment were forwarded to  
site management for resolution.  Implementation of recommendations/action  
items in response to PHA findings was based on a relative risk ranking  
assigned by the PHA team.  This ranking helped ensure that potential  
accident scenarios assigned the highest risk receive greatest attention.  All  
approved recommendations/action items pending implementation were  
tracked by the Manager of Environmental Control until completed.  The final  
resolution of each finding was documented and such documentation will be  
retained for the life of the facility. 
PHA Revalidation 
The PHA will be revalidated every five years, or more often as required by  
significant process changes, using a team with qualifications similar to that of  
the original PHA.  
OPERATING PROCEDURES: Current, clearly written standard operating  
procedures and safe work practices ensure that employees (including contract  
employees) per 
form their duties in a safe, consistent, and prescribed manner.  
UPI has developed written operating procedures satisfying the requirements  
of ' 68.69 of the RMP Rule.  These procedures were prepared with the input  
of plant employees; they will be reviewed periodically and annually certified  
as being reflective of current plant practice. 
The operating procedures are intended to be available to employees for all  
aspects of operations.  Copies of the operating manual are maintained at the  
following locations: 
o KMCAL Exit Pulpit 
o Sheet Maintenance Office 
o Environmental Office 
o Plant System Repair Office 
Some key considerations in the safe operation of the ammonia system  
a. The addition of ammonia to the furnace-fired exhaust stack of the  
KMCAL Line is performed under automatic flow control.  Alarms are  
routed to an annunciator panel in the continuously staffed exit pulpit.  In  
addition, operators regularly drive by the ammonia supply vessel to check  
local fie 
ld indicators. 
b. It is operating practice to only store 10,200 gallons of ammonia at the  
supply vessel, which is 85% of the tank's capacity. 
c. Safe Job Procedure (SJP KM-122) "Anhydrous Ammonia Work  
Procedure For Leak Or Spill (General)" outlines steps for Operations and  
Maintenance personnel to follow when responding to ammonia leaks or  
spills (both vapor and liquid).  The SJP explains requirements and  
location of correct apparel and spill response equipment.  In addition, it  
lists the hazards of exposure. 
d. The ammonia supplier's loading procedure includes the following  
o The hoses are visually inspected for any signs of wear and tear prior to  
 each use.  The supplier replaces the hoses every 5 years (or sooner as  
 needed).  The hoses are rated for 7 years use. 
o The wheels of the tanker truck are chocked to prevent unwanted  
 movement while the truck and supply vessel are connected. 
o The supplier stays within 25 feet of the tanker truck at all t 
imes during  
 the loading operation, to ensure an immediate response to any upset  
o There are two emergency isolation switch stations located on the  
 tanker truck, allowing the supplier to shut down the loading operation  
 in the event of a release. 
e. Ammonia is only loaded during normal business hours, Monday through  
Friday, when more experienced personnel are in attendance to respond to  
any upset condition. 
f. Operating practice calls for the operator to check the bill of lading prior to  
allowing the loading operation to commence. 
TRAINING: UPI believes that employees who clearly understand how to safely  
operate a process can significantly decrease the number and severity of  
incidents, and increase efficiency.  Therefore, a thorough training program  
focused on specific operating procedures and safe work practices is a key  
element of an effective prevention program. 
Employees involved with operating the process receive training on the  
hazards associat 
ed with the process, how to operate the process within safe  
operating limits, and how to handle potential emergencies. The training  
program satisfies the requirements of ' 68.71 of the RMP Rule and is  
comprised of the following: 
o Initial employee training 
o Training provided in response to equipment or process changes, as  
 identified under the MOC program; 
o Periodic refresher training; and 
o Training documentation. 
All operators receive initial training in safe work practices and basic  
operating principles prior to assignment.  The operators receive training  
specific to the operations of the process once they are assigned.  Various  
means are used to verify competency, but primary emphasis is placed on on- 
the-job observation by supervisors.  Documentation of the training is  
forwarded to the Learning Center for filing and tracking. 
In addition to on-the-job training, UPI personnel are trained in basic safety  
courses on an ongoing basis.  All operating division employe 
es and all  
building wardens in non-industrial areas of the plant are designated potential  
first responders.  Courses they take include: "Principles of Accident  
Prevention", "CPR", "First Aid", and "First Responder Training."  Operating  
division employees also regularly attend Safety Committee meetings to  
discuss safety issues. 
MECHANICAL INTEGRITY: A well-established mechanical integrity program  
ensures that equipment critical to process safety is fabricated to meet process  
specifications, is installed correctly, and is maintained in a safe operating  
condition.  It also allows maintenance employees to preemptively identify  
and correct equipment deficiencies to avoid associated incidents and down  
time.  UPI has therefore developed a mechanical integrity program, satisfying  
the requirements of ' 68.73 of the RMP Rule. 
The mechanical integrity program applies to the ammonia storage tank,  
piping systems, relief systems, emergency shutdown systems, controls and  
any addit 
ional equipment (e.g., heat exchangers) deemed by operating and  
maintenance personnel to be important to safety. 
Procedures for ensuring quality assurance - Site procurement procedures  
ensure that equipment: 
o meets or exceeds all design specifications; 
o is properly constructed; 
o is suitable for its application; 
o is designed in accordance with good engineering practice; and 
o will meet the requirements for safety, reliability, and product quality. 
After installation, appropriate checks and inspections ensure that the  
equipment has been installed properly and is consistent with the design  
specifications and the manufacturer's instructions.  These elements of the  
quality assurance program are often performed in conjunction with the  
management of change (MOC) program and the pre-startup safety review  
(PSSR) program.  Additionally, purchasing documents for spare parts include  
adequate technical and engineering data to ensure that maintenance materials  
and spare parts ar 
e suitable for the process application. 
Written maintenance procedures for process equipment - Written  
procedures (including step-by-step instructions, applicable warnings or  
hazards, manufacturer's recommendations, and required personal protective  
equipment) were developed for maintaining process equipment.  These  
procedures are reviewed annually by appropriate members of management  
for thoroughness and accuracy.  Hard copies of these procedures are available  
in the Maintenance Supervisor's office.  The regularly scheduled maintenance  
(preventive maintenance) requests are distributed to maintenance employees  
by the maintenance department.  Non-preventive maintenance activities are  
performed through the work order system (i.e., operators and engineers  
submit work order requests to the Maintenance Supervisor who then  
distributes them to appropriate maintenance employees).  The maintenance  
employee completes the preventive maintenance or work order  
documentation and submi 
ts it to the Maintenance Department for review and  
Maintenance employee training - UPI carefully assesses each applicant for  
employment and only hires maintenance personnel with appropriate skills  
and knowledge pertinent to their required job tasks.  Additional skills training  
is subsequently provided on an as-needed basis. The UPI Learning Center  
maintains documentation of skills training for maintenance employees. 
Maintenance employees are provided with an overview of the process, the  
hazards associated with the process, and safe work practices during initial  
employee training and annual refresher training. The UPI Learning Center  
maintains initial and annual training records including documentation of the  
content of the training, the identity of the instructor, and the means used to  
verify competency for maintenance employees. 
Inspection and testing procedures for critical equipment - Inspection and  
testing procedures and the required testing frequency fo 
r each piece of critical  
equipment were developed and documented by appropriate members of the  
maintenance and operating departments.  The procedures and frequency are  
based upon the manufacturer's recommendations, good engineering practice,  
and operating history.  The inspection and testing requests are distributed to  
maintenance employees at the established frequency.  Completed inspection  
and test documentation including maintenance employee signature, date of  
the inspection or test, serial number of the equipment, inspection and test  
procedures, and the results of the inspection or test are returned to the  
Manager of the Maintenance Department for review and filing. The results of  
each inspection or test are reviewed to determine if the frequency of the  
inspections or tests should be increased or decreased, to ascertain whether the  
equipment is within the acceptable limits, and to project the remaining useful  
life of the equipment.  Equipment outside of the acceptable  
limits is removed  
or replaced unless interim protective measures can be implemented to ensure  
continued safe operation. 
The ammonia leak detectors are calibrated at least every 6 months.  The  
detectors are two-point calibrated, at 100 and 200 ppm.  Relief valves are  
replaced every five years and the ammonia vessel is inspected every five  
years.   Additionally, a visual inspection of the vessel, piping, and related  
equipment is made at least quarterly.  
MANAGEMENT OF CHANGE: Changes in the process, procedures, or prevention  
program elements are sometimes necessary to address safety, environmental,  
or operational concerns.  A change made in one area may have unintended  
effects on other parts of the process, or on other prevention program  
elements. Such changes are therefore appropriately scrutinized before they  
are made to ensure the changes do not compromise the safety and integrity of  
the process and to avoid adverse effects to worker and public safety, and to  
the en 
UPI has developed a written management of change (MOC) procedure,  
including a change authorization form, that satisfies the requirements of '  
68.75 of the RMP Rule.  This procedure ensures that all changes to the  
following are properly managed: 
o Process chemicals (e.g., raw materials); 
o Technology (e.g., operating parameters, rates); 
o Equipment (e.g., materials of construction, equipment specifications); 
o Procedures (e.g., emergency response, preventive maintenance,  
 operating); and 
o Other processes and/or equipment that could affect the covered process. 
This procedure does not apply to a "replacement in kind" which is defined as  
a replacement that satisfies the original design specifications. 
Personnel (e.g., operations and safety) assess the potential impact of the  
proposed change on safety and health through a safety checklist for minor  
changes or a process hazard analysis (PHA) for major changes.  The  
following steps are taken, as necessary, prio 
r to startup of the modified  
facility to ensure proper implementation of the change:  
o Process safety information (PSI) is updated; 
o Operating procedures are updated; and    
o Employees (e.g., operations, maintenance, contract) whose job tasks are  
 affected by the change, are trained on the change and its potential impact  
 on their job responsibilities.  
The MOC records and recommendations are tracked according to the  
assigned tracking number.  The MOC records and documentation of  
completion of the recommendations are maintained for five years. 
PRE-STARTUP SAFETY REVIEW: UPI has developed a written pre-startup safety  
review (PSSR) procedure and checklist, for use in evaluating significant  
facility modifications prior to operation. Significant modifications requiring  
this review are those which require that the process safety information (PSI)  
be updated.  The PSSR procedure satisfies the requirements of ' 68.77 of the  
RMP Rule, by confirming the following prior to 
o The installation is in accordance with design specifications; 
o Safety, operating, maintenance, and emergency procedures are in place  
 and are adequate; 
o For new facilities, a process hazard analysis (PHA) has been performed  
 and recommendations have been resolved or implemented; 
o For modified facilities, the requirements contained in the written  
 management of change (MOC) program have been met; and 
o Training of each employee involved in operating the modified facility has  
 been completed. 
The PSSR records and documentation are tracked according to the assigned  
tracking number that corresponds to the MOC tracking number.  PSSR  
records and documentation of completion of the recommendations are  
maintained for a minimum of five years. 
COMPLIANCE AUDITS: UPI recognizes the importance of periodic self-audits  
for ensuring that the prevention program elements are functioning properly  
(i.e., that they are complete, current, and applied in compliance with co 
policy, regulations, and good process safety practices).  Personnel perform  
internal compliance audits at least every three years to review and evaluate  
the written documentation/records and implementation of the prevention  
program.  Potential areas that can be improved within the prevention program  
elements are identified and recommendations are formulated and  
implemented to ensure an effective and improved overall prevention  
program.  The developed compliance audit program satisfies the regulatory  
requirements of ' 68.79 of the RMP Rule. 
INCIDENT INVESTIGATION: UPI believes incident investigation to be a vital  
component in the overall prevention program, and has developed an incident  
investigation procedure satisfying the requirements of ' 68.81 of the RMP  
Rule.  The procedure requires the investigation of each incident which  
resulted in, or could reasonably have resulted in, a release of ammonia  
causing personnel injury or major property or environmental damage 
. The  
intent of the investigation is to identify underlying cause(s) and to develop  
and implement corrective actions necessary to prevent reoccurrence of the  
incident, or similar incidents. 
Trained management personnel assume the position of incident investigation  
team leader, when an incident occurs.  The number and experience of the  
other team members is dependent upon the severity and complexity of the  
incident.  Typically, the incident investigation team is comprised of a team  
leader, an expert in the process, and other employees (including contract  
employees) knowledgeable in the operation, design, and maintenance of the  
process.  The incident investigation team leader is responsible for initiating  
the investigation as soon as possible but definitely within 48 hours of the  
time of the incident or "near miss". 
The incident investigation involves four stages: 
o Gathering evidence (e.g., interviewing witnesses, taking photographs,  
 collecting evidence and records 
, and obtaining samples); 
o Analyzing the evidence; 
o Developing conclusions; and 
o Formulating recommendations. 
The incident investigation team prepares a written report at the conclusion of  
the investigation that includes: 
o Date and time of the incident or "near miss"; 
o Date and time the investigation was initiated; 
o Team members and their expertise; 
o Description of the incident or "near miss"; 
o Factors that contributed to the incident or "near miss"; and 
o Recommendations formulated as a result of the investigation. 
The written report is forwarded to the appropriate members of management  
for review.  Management addresses each recommendation to identify the most  
appropriate resolution and to establish a schedule for completion of each  
accepted recommendation.  The team leader or designee tracks the  
recommendation status until the recommendation is resolved. 
The investigation results, including the disposition of all recommendations,  
are reviewed with employees ( 
including contract employees) whose job tasks  
are relevant to the findings.  The Manager of Safety & Health retains copies  
of the investigation reports for a minimum of five years to be used during  
subsequent process hazard analysis (PHA) revalidations.  
EMPLOYEE PARTICIPATION: UPI recognizes the contributions to safety and  
operations that are made by employees (including hourly and contract  
employees when appropriate) at all levels and in all disciplines. UPI consults  
with employees to ensure consideration of their knowledge and experience in  
all applicable areas of the prevention program.   
Accordingly, UPI has developed a written plan of action regarding employee  
participation in the prevention program elements, the hazard assessment, and  
emergency response program, satisfying the requirements of ' 68.83 of the  
RMP Rule.  The written employee participation plan ensures that:  
o Employees and their representatives are consulted on the conduct and  
 development of p 
rocess hazard analyses (PHAs) conducted to comply with '  
 68.67 of the RMP Rule.  UPI requires participation by plant operators and  
 maintenance personnel as members of the PHA team.  Other employees  
 with responsibilities relating to specific processes are consulted prior to  
 and during the PHA; 
o Employees and their representatives are consulted on the development of  
 all elements of the prevention program in accordance of ' 68.65 to 68.87  
 of the RMP Rule, and the emergency response program developed in  
 accordance with ' 68.95 of the RMP Rule.  Examples of participation  
 include operations and maintenance employees being: 
  - actively involved in the development of procedures; 
  - integral members of the established incident investigation teams; and 
  - consulted with regarding the appropriate type and frequency of  
o Employees and their representatives are provided access to PHAs and to  
 all other information required to be developed under 
the RMP Rule (e.g.,  
 hazard assessment, emergency response program). 
HOT WORK PERMIT:  Control of ignition sources is a vital component of UPI's  
release prevention program.  Therefore, it is critical that pertinent personnel  
are notified when hot work (i.e., any spark-producing operation including use  
of power tools, grinding, burning, welding, brazing) is to be performed in the  
facility and that appropriate safety precautions are taken prior to initiation of  
the work.  UPI has developed a hot work permit program, satisfying the  
requirements of ' 68.85 of the RMP Rule, which requires that employees  
complete permits certifying that the applicable portions of the fire prevention  
and protection requirements are implemented prior to beginning hot work  
operations.  These requirements are contained in the fire prevention and  
suppression procedure and hot work permit, Title 8 California Code of  
Regulations (T8 CCR) '4848 and '6777 respectively. 
The Operations department is 
sues hot work permits for all grinding, burning,  
welding, and brazing performed in areas not otherwise approved for cutting  
and welding.  The hot work permit is terminated when continued use of the  
ignition source could be hazardous, when the conditions under which it was  
issued change, or when the permitted hot work has been inactive for more  
than 2 hours (unless tests show that conditions are still non-hazardous). 
The hot work permit contains the following information: 
o The effective date and time;  
o The authorized duration of the permit; 
o The specific location or piece of equipment where the source of ignition  
 will be used; and 
o Any special precautions or limitations to be observed before, during, or  
 after the use of the source of ignition, including the need for a fire watch  
 and fire hoses or extinguishers. 
Personnel in the control room are notified prior to initiation of the hot work  
to make them aware of the ignition source.  This awareness allows perso 
in the control room to quickly contact the fire watch and personnel  
performing hot work when continued use of the source of ignition becomes  
CONTRACTORS: UPI relies on contractors to supplement the existing  
workforce primarily during maintenance outages and when specialized  
expertise is required. UPI and all contract owners are jointly responsible for  
safety and must ensure that contract employees are trained in and understand  
the following: 
o Work practices necessary to perform job responsibilities; 
o Hazards associated with the process; 
o Applicable sections of the emergency response procedure; and 
o Applicable safe work practices. 
UPI has developed a contractor program, satisfying the requirements of '  
68.87 of the RMP Rule, to ensure that safety issues are addressed during  
contractor selection and that UPI and contractor owners share responsibility  
for the safety of all employees (including contractors). 
UPI requires that potential contract owne 
rs provide information regarding  
their safety programs and past safety performance to the Safety & Health  
Department for review. The Safety & Health Department may also request  
that the contract owner submit additional documentation (e.g., the written  
safety program) or safety training records/logs.  Contractors are selected, in  
part, based upon the completeness and maturity of their safety program, their  
past safety performance, and their ability to complete the required work. 
Contractor employees are required to receive training before being allowed  
on-site.  The training consists of a safety video describing emergency  
procedures and facility- wide practices (e.g., contractor and employee  
access).  The training also addresses safe work practices and process-specific  
hazards.  The content and duration of the training is dependent upon the  
contractor's responsibilities.  Contract employees are allowed on-site only  
after demonstrating adequate comprehension of the trainin 
g program content. 
The Safety & Health Department audits each contractor owner periodically. 
The frequency of the audits is adjusted according to safety  
performance/history, and the type of service being provided.  The Safety &  
Health Department ensures that proper training is provided and that  
documentation is maintained for each contractor.  The Safety & Health  
Department also monitors contractor performance (e.g., compliance with safe  
work practices, knowledge of types of work and the hazards involved).   
Documentation of the audits and on site evaluations is maintained for a  
minimum of five years. 
A review of facility incident investigation reports has shown that there have  
been no incidents involving ammonia or other hazardous substances, for  
which the onsite or offsite consequences exceeded the reporting requirements  
of ' 68.42 of the RMP Rule. 
Overall safety at UPI is governed not only by the  
ability to prevent accidental  
releases of anhydrous ammonia from occurring, but also by the ability to  
mitigate any accidental release that might occur.  UPI therefore has  
developed an emergency response program to minimize the effects of  
accidental releases of anhydrous ammonia to employees, the public, and the  
environment.  UPI has formed emergency response teams (ERTs) to respond  
to onsite releases of ammonia; approximately 10% of the plant staff is so  
An emergency response program was developed which addresses:  
o the emergency action plan (EAP) requirements of Title 8 California Code  
 of Regulations (T8 CCR'3220);  
o an emergency response plan (ERP), satisfying the requirements of the  
 Hazardous Waste Operations and Emergency Response (HAZWOPER)  
 regulation, T8 CCR '51921;  
o coordination with local emergency response personnel and officials,  
 satisfying the requirements of ' 68.95(c) of the RMP Rule. 
The EAP portion of the response program addresses tho 
se employees who are  
not responsible for responding to the release of anhydrous ammonia.  This  
plan provides for employee evacuation routes, (or, alternatively, for  
"sheltering-in-place" where circumstances warrant), personnel accountability  
procedures, and EAP training for employees.   
The EAP portion also includes a call list which provides the telephone  
numbers of agencies and individuals to contact in the event of one of several  
pre-identified emergencies (e.g., fire, employee injury, employee fatality).   
The agencies and individuals on this call list represent local emergency  
responders (e.g., Fire Department), public notification and regulatory  
reporting requirements (e.g., CCCHSD), adjacent industrial facilities, as well  
as UPI personnel requiring notification (e.g., Plant Manager, Emergency  
Control Group personnel).  
UPI ERT personnel are trained in fire suppression techniques and are able to  
fight incipient, non-structural fires.  All other fire suppression requi 
res the  
assistance of the local Contra Costa Fire Protection District (CCFPD).  UPI  
works closely with the CCFPD to prevent fires from occurring and to quickly  
mitigate fires.  UPI conducts drills with local fire and police departments, and  
participates in similar drills conducted by the neighboring industrial facilities.   
Such drills ensure  that members of the fire department are familiar with the  
facility, the hazards of the anhydrous ammonia, and the locations of resources  
available at UPI. 
UPI has developed and implemented an ERP to respond to releases of  
anhydrous ammonia.  The ERP identifies the emergency response team  
(ERT) training requirements, qualifications, and responsibilities within the  
incident command system.  The ERT is comprised of individuals from the  
Operations, Maintenance, and Technology groups. In addition to the ERT, the  
UPI Security force has properly trained, and properly equipped employees to  
administer first aid and emergency medical treatment 
until outside ambulance  
services and associated EMT personnel arrive.  
Chemical-specific emergency response procedures for releases of ammonia  
are contained in Safe Job Procedure SJP KM-122, "Anhydrous Ammonia  
Work Procedure for Leak or Spill (General)".  This procedure identifies the  
personal protective equipment (PPE) required for responding to ammonia  
releases, describes the safety hazards associated with ammonia, and describes  
mitigation measures to control the release. 
UPI maintains emergency response equipment and personal protective  
equipment (PPE) for use by the emergency response team and the Fire  
Department.  The emergency response equipment is included in the  
mechanical integrity program, requiring that testing and inspection  
frequencies be developed and preventive-maintenance activities be  
conducted.  Examples of PPE maintained at UPI include air-purifying  
respirators and self-contained breathing apparatus, as well as the appropriate  
chemical-resistant cloth 
UPI also works closely with Contra Costa County Health Services  
(CCCHSD) for any necessary response to hazardous material releases, to  
assist in determining any downwind air monitoring, and to alert the public of  
the accidental release of ammonia.   
The emergency response program, including the EAP and the ERP, is  
reviewed annually to ensure that it remains accurate and current.  Employees  
are trained on the emergency response program when initially hired, when the  
emergency response plan is revised, and when employees' responsibilities are  
At the present time, UPI plans one improvement to the pressure relief  
provided for the ammonia storage vessel; the intent is to capture smaller  
relief valve discharges in a scrubber, thereby reducing the release of ammonia  
to the atmosphere. 
As described previously, the ammonia storage tank is provided with two  
relief valve manifolds.  Each manifold has two relief valves, bu 
t only one  
relief valve on each manifold is valved into service at any time.  The relief  
valves are sized to safely relieve the internal pressure that would result from  
an external fire engulfing the vessel, and boiling its contents.  Calculations  
have shown that a single relief valve is adequate to protect against this design  
basis scenario; thus, redundant protection is provided. 
The relief valves are sized and installed in accordance with the requirements  
of ANSI standard K 61.1, which requires that these relief valves discharge  
directly to atmosphere.  In other words, the connection of any release  
mitigation equipment to the discharge of the relief valves is prohibited.  
It is recognized that the fire exposure scenario, while the most severe  
scenario, is not the only circumstance that could lead to vessel  
overpressurization, requiring that a relief valve open to protect the vessel.   
Accordingly, UPI proposes to provide an additional, smaller capacity relief  
on the ammonia storage vessel.  The discharge from this will be piped  
below the surface in a water-filled scrubber tank.  Smaller, more likely,  
ammonia releases would be absorbed in the water, reducing the amount of  
ammonia discharged to the atmosphere.  This safety enhancement would be  
achieved without degrading the required protection provided by the fire  
exposure relief valves.
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