California Dairies, Inc. (Danish Creamery) - Executive Summary |
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THE CALIFORNIA DAIRIES, INC., RISK & PROCESS SAFETY MANAGEMENT PROGRAM This is to inform all interested persons, including employees, that California Dairies, Inc. has prepared a unified Risk & Process Safety Management Program. The program is/will be in compliance with California's Accidental Release Prevention (CalARP) Program (in California CCR Title 19, Chapter 4.5 Program Level 3 Elements. At the Federal level, Title 40 CFR Part 68), and California OSHA's "Process Safety Management (PSM) of Acutely Hazardous Materials" standard (in California CCR Title 8, Section 5189, "Process Safety Management of Acutely Hazardous Materials," and Federally Title 29 Code of Federal Regulations (CFR) 1910.119). This program is being prepared to address the risks involved with the presence of anhydrous ammonia in an amount in excess of 10,000 lbs., which is contained in our refrigeration system. Our program will promote overall plant, worker, and public safety. The program will enable our fac ility to prevent the occurrence, and minimize the consequences, of significant releases of anhydrous ammonia. Overall, the program is designed to prevent accidental fatalities, injuries and illnesses and avoid physical property damage. Our company has an exemplary safety record, one that we are quite proud of. Our company has many policies and procedures in place to promote overall plant, worker and public safety. We have: (1) prepared a unified program based on the PSM plan to meet CalARP obligations as well; (2) reorganized the program so that it meshes more closely with general California Dairies business practices; and (3) reviewed plan documentation forms and responsibilities. The unified Risk & Process Safety Management Plan sets forth rules, procedures and practices which will help our employees protect themselves and our neighbors. 2. DESCRIPTION OF AMMONIA SYSTEM The California Dairies Fresno facility is part of a dairy coop that receives and processes dairy products including non-fat dry milk, butter and condensed milk. The facility has an ammonia system with a charge of approximately 11,000 lbs, that provides refrigeration capacity in support of these activities. The ammonia system has a single High Pressure Receiver, suspended outside approximately one story above ground level. From the High Pressure Receiver high pressure liquid (HPL) ammonia travels in three directions. HPL ammonia is piped to the engine room, where it is used for liquid injection cooling of two FES screw compressors. HPL ammonia is piped to a King Coil HVAC unit. After passing through an expansion valve, it provides cooling capacity for the HVAC. Finally, HPL ammonia is pumped to individual cooling devices including a turbo water chiller, an ice builder, a glycol plate chiller, a glycol tube & shell chiller, and a low pressure pump receiver. In each case the HPL provides cooling capacity after passing through an expansion valve to the low pressure side of the system. With the exception of the low pressure pump receiver, the ammonia resides in the cooling device. Cooled ammonia from the low pressure pump receiver is pumped to banks of evaporator coils in the cold storage rooms. Low temperature and pressure gas from the cooling devices are returned to one of three suction accumulator vessels in the engine room. One of these vessels is the low pressure pump receiver. From the accumulator vessels low pressure gas is piped to four compressors served by a common suction return header. There are two 300 hp FES screw compressors and two Vilter reciprocating compressors (200 and 250 hp). The high pressure discharge from the compressors is sent to a water cooled condenser located on the rooftop, above the high pressure receiver. In the condenser the high pressure gas ammonia is liquified and drains back into the high pressure receiver to complete the refrigeration cycle. The overall cycle is considered to be a one-stage system, and all parts of the low pres sure side are at the same suction pressure. There is only one ammonia system at our facility, and therefore we are treating our facility as a single process. 3. AMMONIA RELEASE SCENARIOS 3.1 Worst Case Scenario At California Dairies, the worst case scenario is the failure of our high-pressure receiver. This vessel contains 11,000 lbs. of ammonia. Following the instructions set forth in EPA's "Risk Management Program Guidance for Ammonia Refrigeration (40 CFR Part 68)," we considered the failure of one vessel. We did not include any liquid ammonia in pipework connected to the failed vessel. Our worst case scenario is the failure of our high-pressure receiver containing 11,000 lbs of ammonia. Under this scenario, the release would not be passively mitigated because the primary receiver vessel is not located inside a room or housing. The ammonia would be released over a ten-minute period. Using RMP*Comp we estimate that the ammonia would travel 1.2 miles (urban conditions) before dispersing enough to no longer pose a hazard to the public. The potentially affected area can be found on a site map in appendix A. 3.2 Alternative Case Scenario Our ammonia refrigeration system is equipped with safety relief valves. These valves limit the operating pressures of the entire system, and prevent failures due to overpressurization. Our alternative release scenario is as follows. A high-pressure safety relief valve lifts and fails to reseat. The rated release rate for our high-pressure safety relief valve is 70 lbs./min. We assume the leak would continue for 10 minutes until the header pipe was switched over to the backup safety relieve valve. Following industry practice, our relief valves are installed in pairs with a switch over valve, and the discharge is piped to a release point that is remote from the valve. Under this scenario 700 lbs. of ammonia would be released over a time period of 10 minutes. Using RMP*Comp we estimate that the ammonia would travel less t han 0.1 miles (urban conditions) before dispersing enough to no longer pose a hazard to the public. The potentially affected area can be found on a site map in Appendix A. 4. GENERAL ACCIDENT RELEASE & AMMONIA SPECIFIC PREVENTION STEPS The ammonia refrigeration systems at the California Dairies, Inc. facility are an integral part of the overall business The system contains a total charge of approximately 11,000 lbs. It is extremely important that it is maintained and operated in a safe and efficient manner. Management is committed to making sure that all employees are made aware of the potential danger of an ammonia leak. We have thirteen refrigeration and maintenance personnel onsite who monitor the ammonia refrigeration system/process and keep an active diary of all procedures and transactions that pertain to ammonia. In addition, when necessary we employ the services of a qualified refrigeration contractor, Allied Refrigeration and Engineering. We inform our employees of the dang ers of an accidental release of ammonia in a tailgate safety meeting. New employees are made aware of the potential risk of ammonia in an employee orientation meeting. During these meetings we also discuss preventative measures, such as evacuation, in order to be prepared for a release. Our ammonia refrigeration system was designed and built by professional refrigeration engineers in accordance with ANSI/IIAR 2-1992 "Standard for Equipment, Design, and Installation of Ammonia Mechanical Refrigerating Systems." It was also built in compliance with the Uniform Building Code and Uniform Mechanical Code applicable at the time of construction. 5. FIVE YEAR ACCIDENT HISTORY California Dairies, Inc. has not had any reportable accidents within the last five years. 6. EMERGENCY ACTION PLAN This facility's emergency response program is based on the Cal/OSHA requirements for Emergency Action Plans (in California CCR Title 8, Section 3220, "Emergency Action Plans." Federally, Title 29 CFR 1910 .38 and 1910.119), HAZWOPER (standard (in California CCR Title 8, Section 5192, "Hazardous Waste Operations and Emergency Response," and Title 29 CFR 1910.120). Strategically, we will respond Defensively to a release. Under this plan our ammonia refrigeration personnel will take whatever steps are necessary to bring a release under control. The first priority will be to operate the ammonia system to bring a release under control safely, from a distance, without donning personal protective equipment. Further response requiring the donning of personal protective equipment would be done in coordination with an outside agency. To better prepare for this type of action, initial training to the defensive level (First Responder, Operations Level) as defined in the HAZWOPER regulations will take place. All response activities would be coordinated with the Fresno City Fire Department and the Hazardous Materials Response Team. We have a windsock at our facility that employees can use to deter mine the "upwind" side of any point of release. 7. PLANNED CHANGES TO IMPROVE SAFETY Our company has an outstanding safety record, one that we are quite proud of. Many policies and procedures have been implemented to promote overall plant, worker and public safety. Nevertheless, Califorina Dairies, Inc. continually strives to improve in all areas, including safety. The Risk & Process Safety Management Program has been written so that program elements are aligned with California Dairies, Inc., business practices rather than the order presented in the law. Thus, Safe Operating Procedures are grouped together for the benefit of our system operator. Safe Operating Policies are grouped together so that appropriate office staff may administer them. The Emergency Action Plan is now separated out and distributed widely through the plant for easy reference. The Risk & Process Safety Management Program documentation forms and company policy forms pertaining to employee, contractor, and community safety have been carefully reviewed so as to prevent unnecessary complexity and redundancy. Our Engineering Department assisted in the writing of Standard Operating Procedures, and they are presented in a format which is easy to use. For the future, California Dairies, Inc., now thinks of the Risk & Process Safety Management Program as a "living document". It is an interactive framework that guides safe action for California Dairies, Inc., employees, but allows for feedback and continual improvement. Through the Risk & Process Safety Management Program California Dairies, Inc., will continue to profit while maintaining overall plant, worker and public safety. |