E&J Gallo Winery - Livingston - Executive Summary

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EXECUTIVE SUMMARY - RISK MANAGEMENT PLAN 
The E&J Gallo Livingston Winery is located at 18000 West River Road in Merced County, California.  The facility crushes grapes in order to produce wine and distilled spirits.  These products are stored prior to shipment to another Gallo facility for bottling and distribution. 
 
The facility operates anhydrous ammonia refrigeration systems to provide product cooling.  Refrigeration systems have storage vessels (receivers) sized to contain all the liquid ammonia in the system, with additional capacity for thermal expansion.  
 
The ammonia refrigeration system is a closed loop heat transfer system.  Ammonia moves through the system due to pressure differences produced by the compressors.  A brief description of the ammonia refrigeration cycle follows: 
 
1.  The receiver vessel stores liquid ammonia under pressure.  High pressure liquid ammonia flows from the receiver through liquid lines to the expansion valve, which partitions the pressure and temper 
ature.  Liquid ammonia at reduced pressure and temperature is then piped into the chiller shell.   
 
2. Product is circulated through sealed stainless steel tubing within the chiller shell.  Heat from the warm product transfers through the tubing walls to the cooler refrigerant, causing liquid refrigerant to boil off as low pressure vapor.  The rate of vaporization, and thereby the cooling of product, is determined by the amount of pressure in the chiller as controlled by a back pressure regulator, and suction from the compressors. 
 
3. The compressors draw the low pressure vapor from the chiller, compress it into high pressure vapor, and discharge to the evaporative condenser (cooling tower). 
 
4. In the evaporative condenser, ammonia vapor flows through tubing which is sprayed with water and located within fan driven air flow to promote cooling.  The ammonia vapor transfers heat through the tubing walls to the cooling water.  The ammonia condenses back to a liquid which drains by gra 
vity to the receiver vessel. 
 
In addition to ammonia refrigeration systems, the facility uses anhydrous ammonia to adjust the pH of process water. 
 
The Winery maintains a storage vessel of liquid sulfur dioxide used as a stabilizing agent during processing activities.  
Ammonia - Processes in Federal RMP Program Level 3: 
 
Refrigeration System # 1 
capacity 4808 gal x 80 = 3846 gal = 19,809 lbs. 
 
Refrigeration System # 2 
capacity 3024 gal x 80% = 2419 gal = 12,459 lbs. 
 
Refrigeration System # 3 
capacity 5000 gal x 80% = 4000 gal = 20,600 lbs. 
 
Refrigeration System # 4 (Plants 4, 10, & 12) 
capacity 8859 gal x 80% = 7087 gal = 36,499 
 
Refrigeration System # 5 (Plants 5 & 11) 
capacity 5839 gal x 80% = 4671 gal = 24,057 lbs. 
 
Refrigeration System # 6 
capacity 2829 gal x 80% =  2263 gal = 11,655 lbs. 
 
Refrigeration System # 7 
capacity 3010 gal x 80% = 2408 gal = 12,401 lbs. 
 
Refrigeration System # 8 (Plants 8, 9, & 13) 
capacity 9030 gal x 80% = 7224 gal = 37,204 lbs. 
 
Process Water pH Adjustm 
ent System  
capacity 12,500 gal x 80% = 10,625 gal = 56,857 lbs. 
 
Sulfur Dioxide - One Process in Federal RMP Program Level 3: 
Sulfur Dioxide Storage Vessel  
capacity 6000 gal x 80% = 5100 gal = 58,436 lbs. 
 
FIVE YEAR ACCIDENT HISTORY 
In the five year period prior to this submission, the E&J Gallo Winery has experienced no accidents involving Cal ARP (RMP) covered processes, that resulted in injury or evacuation of employees or the public. 
 
TOXIC WORST CASE RELEASE SCENARIO: 
The worst case release scenario was determined in accordance with requirements of the California Accidental Release Prevention Program. 
This requires modeling the offsite consequences of a total catastrophic failure of the largest storage vessel, with all product within the vessel dispersing into the air within ten minutes.  For the Livingston facility, the worst case scenario involves the sulfur dioxide storage tank.  Under pessimistic weather conditions (stability F, wind speed 1.5 meters per second) sulfur diox 
ide was predicted to reach the toxic endpoint of 3 parts per million in air at a distance 12.4 miles from the source.  This is an unrealistic scenario and highly unlikely to ever occur.  Among other things, it does not take into account the plant's safety programs and specific operational and prevention programs. 
 
TOXIC ALTERNATIVE RELEASE SCENARIOS:   
Sulfur Dioxide - An alternative  release scenario would involve damage to piping due to contact from motorized equipment operating in the area.  If damage was sufficient to cause a failure, it could result in a 1 square inch opening.  The release of sulfur dioxide from the opening could be expelled into the air and onto surrounding surfaces.  Under more typical weather conditions (stability D, wind speed 4.5 meters per second)  the predicted distance to the 3 ppm toxic endpoint would be  2.8 miles from the source.  
 
Ammonia - An alternative release scenario would involve damage to liquid ammonia piping at a chiller due to contact from m 
otorized equipment operating in the area.  If damage was sufficient to cause a failure, it could occur at a flange due to bolt failure, and result in a 1 square inch opening.  The release of liquid ammonia from the opening could be expelled into the air and onto surrounding surfaces.  Under more typical weather conditions (stability D, wind speed 4.5 meters per second)  the predicted distance to the 200 ppm toxic endpoint would be  0.51 mile from the source.    
 
ACCIDENTAL RELEASE PREVENTION  
The E&J Gallo Winery employs refrigeration mechanics, supported by Engineering.  The refrigeration system is maintained through the implementation of a scheduled preventive maintenance program based upon standard industry practices, and many years of practical experience.    
 
Employees required to operate ammonia refrigeration equipment receive training specific to their assigned duties. 
EMERGENCY RESPONSE 
The facility coordinates emergency response through the Security Department.   In the event 
of a reportable chemical release, notifications will be made to the appropriate agencies including the Merced County Environmental Health Department, the State Office of Emergency Services, and the Federal National Response Center.   
 
Gallo management and members of the in-house emergency response team would respond to the site, and work with public emergency response personnel in mitigating the problem. 
 
MANAGEMENT OF CHANGE 
The Management of Change procedure will require evaluation of new construction and modifications to existing ammonia systems to determine the likelihood of an effect on ammonia safety.  Changes expected to have a significant safety effect on quantity, systems, or procedures will be referred to the appropriate Risk Management Program team for further study.   
 
COMPLIANCE AUDITS 
E&J Gallo Winery will perform an annual Risk Management Program compliance audit.  The specific items in the Risk Management Plan will be re-examined, and compliance documented.  The team r 
eviewing these systems will consist of personnel from Engineering, Instrumentation, Maintenance, and Operations. 
 
PLANNED CHANGES TO IMPROVE SAFETY 
Hazard and Operability Studies (HAZOPS) were performed for ammonia systems (in 1997), and sulfur dioxide systems (in 1995).  The study teams were composed of engineering, maintenance, and management personnel from E&J Gallo Winery.  As a result of the study, numerous improvements were made to existing systems, and included in major renewal and upgrade projects.  These improvements were completed prior to submission of this Risk Management Program document.
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