Santee Dairies, Inc. - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The Santee Dairies, Inc. (Santee) facility has adopted emergency response procedures and policies. The Emergency Response Plan (Plan) is detailed in the Emergency Procedures Manual. This Plan was designed to meet the following objectives: 1.) To save lives. 2.) To minimize and avoid injuries. 3.) To protect the environment. 4.) To minimize property damage. Santee maintains an emergency response committee whose members are the designated emergency coordinators for the facility. The Plan provides the response organization and notification procedures, evacuation routes, ammonia health hazards, and mitigation procedures which will be implemented to respond effectively to emergency situations that may arise at the facility. This Plan is reviewed and updated at least once per year. This Plan was reviewed and updated to ensure compliance with the PSM and RMP regulations, as well as to incorporate facility changes due to moving into a new facility. STATIONARY SOURCE AND REGULATED SUBSTANCE Startup of the ammonia refrigeration system was during the week of October 6, 1997 with Santee personnel taking full responsibility for operating the entire facility in December 1997. The facility is located at 17851 East Railroad Street, City of Industry, California 91748. The facility was constructed in accordance with the most recently adopted Uniform Fire and Mechanical Codes. The ammonia refrigeration system uses 12,500 pounds of ammonia for the following three purposes: To provide cooling for 1) dairy processing, 2) warehouse cold storage, and 3) HVAC (Heating, Ventilation, and Air Conditioning) for offices. With the exception of the condensers and the diffusion box (including associated piping), the entire ammonia system is located inside the engine room. The refrigeration cycle begins with the transfer of ammonia from the thermosyphon receiver to the high pressure receiver. The thermosyphon receive r also supplies ammonia to the compressors for oil cooling. From the high pressure receiver, high pressure liquid ammonia is transferred to three accumulators that maintain ammonia at three different temperatures. As the ammonia enters each accumulator, it is expanded through a hand expansion valve, reducing the temperature and the pressure. Each accumulator supplies liquid ammonia to a distinct heat exchanger which provides cooling for one of the three purposes listed above, vaporizing the ammonia. The heat exchangers are located in the engine room and use a secondary fluid to provide the required cooling throughout the facility. The vapor is returned to each accumulator in which constant pressures are maintained by back pressure regulating valves. The vapor from two of the accumulators is then pulled to the compressors (6) where the pressure and temperature of the gas is increased. The other accumulator feeds a suction accumulator which transfers the vapor to the compressors a nd sends any residual liquid to a transfer unit. Upon a certain level detection in the transfer unit, hot gas from the compressors pressurizes the vessel and the liquid is then returned to the high pressure receiver. Compressor discharge (high pressure ammonia vapor, or hot gas) is sent to the condensers (3) where it is condensed to a high pressure liquid and returned to the thermosyphon receiver. An Auto Purger periodically purges the system of non-condensibles collected in the high pressure receiver and the condensers. The system also has a diffusion box (for equalizing pressure between vessels in the event of an emergency) and a dilution tank (into which the relief header vents), which is kept full of water. HAZARD ASSESSMENT SUMMARY Worst Case The worst case release at this facility is a release of the maximum quantity of ammonia that can be stored in a vessel, accounting for administrative controls, in ten minutes. The high pressure receiver is the largest vessel at the f acility and can hold the entire system charge of 12,500 pounds. All ammonia vessels are located inside the engine room, therefore, the building was used as a passive mitigation measure. The most pessimistic meteorological conditions were used: 1.5 meters/second wind speed, F stability, and urban topography. The potential downwind distance to 200 ppm was determined using Exhibit 4-4 from the EPA Risk Management Program Guidance for Ammonia Refrigeration, November 1998. This release scenario reaches off-site and may affect population receptors. No environmental receptors were affected by this potential release scenario. MITIGATIONS: It was recommended during the Process Hazard Analysis study that the ammonia sensor setpoints and the associated system actions be confirmed (R01). This release scenario assumes that mitigation measures are not in place and therefore, the entire contents of the system was released. The implementation of R01 will reduce the likelihood of this release scenario by increasing the possibility of early detection and system shut down. The ammonia sensor, located in the engine room, will respond as follows: At 50 ppm (PEL): Activate alarm in computer control system, alarm horn and beacon in engine room. At 250 ppm (50% of LFL): Activate duct work motorized damper, purge fan, visual and audible alarms in refrigeration equipment room. Activate condenser purge fan and water pump for scrubbing. Turn off power to electric motors for the hydraulic pumps, the suction trap ammonia pump, equipment room lights, and ammonia refrigeration compressors. Alternative Release Scenario The alternative release scenario was that of a 0.25 inch leak in a high pressure liquid line that continues (33 lbs/min) until the system is empty (6.3 hours). This release may occur outside, therefore, no passive mitigation measures were incorporated into the release rate calculations. Again, worst case meteorological conditions were used: 1.5 meters/second wind speed , F stability, and urban topography. The potential downwind distance to 200 ppm was determined using the DEGADIS disperion model. This release scenario reaches off-site and may affect population receptors. No environmental receptors were affected by this potential release scenario. MITIGATIONS: This scenario assumes that no engineering or administrative controls operate. These controls include daily inspections of the ammonia refrigeration equipment and an ammonia detection and shut down system. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS The Santee Dairies, Inc. facility was designed and constructed in accordance with the 1994 Uniform Mechanical Code which specifically outlines requirements for the safe operation of ammonia refrigeration systems. These safety features include a water diffusion tank, ammonia sensors in the engine room, and automatic shut down systems. In addition, all of the ammonia is located inside the engine room or on the e ngine room roof (condensers). The facility uses a heat transfer medium to provide cooling throughout the plant. In addition to the Uniform Mechanical Code, the facility will operate in accordance with the International Institute of Ammonia Refrigeration (IIAR) guidelines. In particular, the IIAR Bulletin 110, "Startup, Inspection, and Maintenance of Ammonia Refrigeration Systems". DETECTION AND MONITORING: There are two ammonia sensors placed in strategic locations in the engine room. In the event of ammonia detection, a facility alarm sounds and a visible alarm is triggered. In addition, Santee Dairies personnel circulate throughout the plant, taking note of unusual conditions in any portion of the systems. If a leak is detected or observed by any Santee Dairies employee (or contractor), it is immediately reported to the chief maintenance technician and the refrigeration engineer. Action is promptly taken to mitigate the leak so normal operations can resume. FIVE YEAR ACCIDEN T HISTORY There have been no releases since the startup of the ammonia refrigeration system. EMERGENCY RESPONSE PROGRAM Employees and contractors of Santee Dairies, Inc. are obligated to report any significant releases or potential releases of hazardous materials. Organizations which require immediate notification are listed below: 1. First call 911 on an internal/land line phone for the Los Angeles County Fire Department, Hazardous Materials Division, Police Departments, and California Highway Patrol. 2. Call the Governor's Office of Emergency Services (OES) Chemical Emergency Planning & Response Center 1-800-852-7550. 3. If additional help is required for an ammonia spill or leak, the facility can call Chemtrec - Manufacturing Chemists Association 1-800-424-9300. 4. If an ammonia release exceeds 100 pounds (Federal Reportable Quantity CERCLA), call the National Response Center 1-800-424-8802 and Los Angeles County Fire Department, Hazardous Materials Division at 213-890-4317. The NRC will likely designate the Coast Guard Captain of the Port, L.A./Long Beach 562-980-4445 as on-scene coordinators. 5. If serious injuries or harmful exposures to workers occurs, call the nearest Cal/OSHA Regional Office in West Covina at (626) 966-1166. 6. If an employee ingests ammonia, the Poison Control Center can be reached 24 hours per day at 800-342-9293. 7. If a significant amount of ammonia is released into the storm drain, contact the Department of Fish and Game at 562-590-5132 Monday through Friday, 8:00 am to 5:00 pm and at 916-445-0045 after hours, weekends, and holidays.* 8. If an ammonia release spills into the sewer system, contact the Los Angeles County Sanitation at 562-699-7411 x2907 (Supervising Industrial Waste Inspector) Monday through Friday, 8:00 am to 5:00 pm and at 562-437-6520 (Long Beach Pump Plant) after hours, weekends, and holidays. 9. If an ammonia release is significant enough to potentially cause odor complaints from neighboring facilities, contact the South Coast Air Quality Management District at 800-572-6306 and choose the menu selection entitled "Breakdowns" or call 800-CUTSMOG. *The Department of Fish and Game receives a copy of the OES report; however if a significant amount is spilled directly into the storm drain, they would appreciate being contacted directly. The Emergency Response Plan is detailed in the Santee Dairies' Emergency Procedures Manual. The plan is distributed to new hires who are required to read and sign a certification page. Santee Dairies, Inc. has a trained Emergency Response Team that will be activated in the event of an emergency release of ammonia. This team is trained to OSHA's First Responder - Technician Level and is therefore qualified to respond offensively to a release. PLANNED CHANGES TO IMPROVE SAFETY The Process Hazard Analysis, Seismic Hazard Assessment, and Hazard Assessment (Off-Site Consequence Analysis) were completed prior to charging the system with ammonia in October 1997. These studies provided the mitigation measures outlined below to improve safety at the Santee Dairies, Inc. facility located at 17851 East Railroad Street in the City of Industry, California. All recommendations were implemented by March 1, 1998. R01 Confirm ammonia sensor setpoints and system actions upon each level of detection, including alarm sequences (i.e. visual/audible). COMPLETE: Ammonia sensor setpoints and actions are as follows: At 50 ppm (PEL): Activate alarm in computer control system, alarm horn and beacon in engine room. At 250 ppm (50% of LFL): Activate duct work motorized damper, purge fan, visual and audible alarms in refrigeration equipment room. Activate condenser purge fan and water pump for scrubbing. Turn off power to electric motors for the hydraulic pumps, the suction trap ammonia pump, equipment room lights, and ammonia refrigeration compressors. R02 Establish and document a relief valve maintenance program. Industry standard requires replace ment/recertification every five years and any time a valve unseats. Include a daily inspection of relief valves to check for condensate or ice formation (indicating venting). COMPLETE: Included in the Mechanical Integrity program. R03 Ensure the system is equipped with a method for remote shut down. COMPLETE: An emergency shut off switch is located at the ammonia emergency box and at exit door. R04 Establish and document a procedure to ensure proper charge of the system. COMPLETE: Tri-Com Refrigeration managed initial charge and startup of system. Procedures are included in the Operating Procedures section. R05 Establish a procedure to follow manufacturer's recommendations regarding ammonia sensor calibration and maintenance. COMPLETE: Included in the Mechanical Integrity program. R06 Investigate the possibility and code applicability of piping the oil pot relief valve back to the suction accumulator. COMPLETE: The oil pot relief valves are piped to ammonia relief heade r. R07 Confirm that the computer control system knows to shut down the appropriate compressors upon triggering of a safety switch. Consider not standard valving where an alternate compressor is providing suction. COMPLETE: Each accumulator is hard wired for high level cut out with its corresponding suction level compressors. An exception was made for the Process accumulator, which is piped in series with an additional suction trap. For situations where compressors are crossed over at a different suction level there will be no high level cut out for the crossed-over compressors. During these cross over situations, plant managers will have to monitor the high level alarms for proper compressor operation. R08 Confirm and document that the return glycol temperature is interlocked with the glycol pump to shut down on high temperature. COMPLETE: The heat exchanger glycol pump is monitored for operation only. Actual control of the glycol pump should be part of University Mechanica l's control scheme. R09 Test the level control sensors on the accumulators annually to ensure proper operation. In addition, identify and exercise unused valves that may be critical in the event of an emergency on an annual basis. COMPLETE: Included in the Mechanical Integrity program. R10 Install a pressure gauge on the line between the check valve and the isolation valve downstream of the pump. COMPLETE: Pressure gauge will be installed between check valve and isolation valve downstream of pump. R11 Perform an annual pressure test to ensure that the compressor shut down prior to the relief valves venting. NOT APPLICABLE: The annual checklist published by the International Institute of Ammonia Refrigeration (IIAR) is used as the industry standard. R12 Establish a procedure to periodically check the pH of the water in the dilution tank. Properly dispose of the water if it is higher than 11 or lower than 5.5. COMPLETE: Included in the Mechanical Integrity program. R13 Inv estigate whether there is a daily log taken by the computer control system. If there is, have operators perform periodic system checks to ensure proper data reporting by the computer control system. If not, have operators take daily logs. R14 Establish a procedure to have a trained operator on site to manually monitor the system for high level conditions in the event that the compressor valves are rearranged so that the computer controls are not correct. (Note all compressors can be manually valved to service all accumulators; however, the computer is set up in a fixed configuration of certain compressors to certain accumulators.) R15 Update training procedures from existing Santee Dairies facility so that they are appropriate for the new City of Industry facility. COMPLETE: Included in the employee training section. R16 Certify in-house training for new employees with a statement signed by the trainer (head refrigeration mechanic) and the trainee. R17 Tri-Com Refrigeration, I nc. is responsible for the initial ammonia fill. Ensure that Tri-Com provides documented fill procedures to Santee Dairies prior to the initial fill date. COMPLETE: Included in the Operating Procedures (system was charged on 10/6/97). R18 Meet with the local fire department to decide the response procedures required in the event the ammonia sensor detects 250 ppm in the engine room. Prioritize the nearest hospitals in terms of the order in which to receive personnel with ammonia-related injuries. R19 Establish a policy for safe temporary operations including: Restricting engine room access Posting signs that warn of the presence of ammonia Ensuring the presence and functionality of the engine room ammonia sensor(s) and safety shower/eye wash stations Ensuring a wind direction indicator (wind sock, flags) is present and visible from the engine room exits Informing all contractors when to evacuate and the locations of assembly points Ensuri ng all contractors will account for their employees during an emergency R20 Verify that there is a single relief valve assembly on the liquid transfer unit. R21 Regarding the diffusion box, ensure that there is a diagram indicating where each line is coming from, that each valve is labeled, that the diffusion box is labeled "Emergency Control Box", and that emergency phone numbers are listed inside the box. A break-away lock should be maintained on the outside of the box. R22 Ensure adequate lighting is available for night-time maintenance work on the roof. R23 Install a safety shower/eye wash station on the engine room roof. R24 Complete the Human Factors Engineering Checklist that was started by the HAZOP team during session 2 after the construction of the facility is completed and Santee has taken control of operations. R25 It is recommended that the three condensers located on the roof be welded to their steel W-beam supports. |