F&A Dairy of California, Inc. - Executive Summary |
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A. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The emergency response procedures for the facility are included as part of the "Training Programs" manual and the Injury and Illness Prevention Program document. These procedures were 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. The emergency response procedures provide the reporting and notification procedures, evacuation procedures, and mitigation procedures that may be implemented to ensure operators respond effectively to an emergency situation. This manual is distributed to all plant personnel upon initial employment and is readily available at the facility. B. STATIONARY SOURCE AND REGULATED SUBSTANCE The F&A Dairy facility is located at 691 Inyo Street, in Newman, California. This location is situated along Inyo Street, approximately one kilometer (0.62 miles) east of Highway 33. The immediat e area is primarily industrial and commercial with residential areas to the east. The facility manufactures various dairy products. The facility operates the ammonia refrigeration system in order to maintain appropriate temperatures for process and storage conditions. The facility was originally built in 1985. The facility currently covers approximately 2.5 acres ( 10,900 square feet). Ammonia is used as the refrigerant in the refrigeration process. The system, consisting of piping, valves, and process equipment, cycles ammonia through various physical states (high pressure liquid, low pressure liquid, low pressure vapor, high pressure vapor, then back to high pressure liquid) in order to provide refrigeration for cold storage rooms and process equipment. Changes in pressure are directly related to changes in temperature: lowering the ammonia pressure lowers its temperature. Low pressure (cold) liquid ammonia provides refrigeration by removing ambient heat. Removal of ambient heat causes the liquid ammonia (contained within the system) to vaporize. Heat is later removed from the ammonia as it is condensed back into a liquid. Typical operating conditions range from approximately 5 psi on the low pressure side of the system to 165 psig on the high side. The total ammonia inventory is 13,750 pounds. C. HAZARD ASSESSMENT SUMMARY Worst Case Release: The worst case release for this facility was that of the maximum quantity of ammonia that can be stored in a single vessel. The largest vessel at this facility is the high pressure receiver which is sized to hold the entire charge, 13,750 pounds, of ammonia. This vessel is located outside, therefore, no passive mitigation measures were used. The most pessimistic meteorological conditions were used: 1.5 meters/second wind speed, and F stability. The facility is located in a rural setting. The SLAB dispersion model was used to determine the maximum downwind distance reached by 200 ppm. The release reaches o ff-site and may affect population receptors. No environmental receptors are affected by this potential release. Alternative Release: The alternative release was that of a 0.25 inch diameter leak of high pressure liquid ammonia for one hour. The quantity of ammonia released in one hour at this rate is 6000 pounds. This scenario represents a small leak that could occur at a valve connection, flange seal, or pump seal. The meteorological conditions used were 3 meters/second wind speed, and D stability. The facility is located in a rural setting. The SLAB dispersion model was used to determine the maximum downwind distance reached by 200 ppm. The release reaches off-site and may affect population receptors. No environmental receptors are affected by this potential release. D. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS The facility operates in accordance with the International Institute of Ammonia Refrigeration (IIAR) guidelines and standards in cluding the following: IIAR Bulletin 107, "Suggested Safety and Operating Procedures When Making Ammonia Refrigeration Tie-ins" IIAR Bulletin 109, "Minimum Safety Criteria for a Safe Ammonia Refrigeration System" IIAR Bulletin 110, "Startup, Inspection, and Maintenance of Ammonia Refrigeration Systems" IIAR, "A Guide to Good Practices for the Operation of an Ammonia Refrigeration System" In addition, the F&A Dairy facility has implemented a Process Safety Management program for compliance with the Cal-OSHA regulation. E. FIVE YEAR ACCIDENT HISTORY There have been no reported releases of ammonia at this facility over the last five years (June 21, 1994 through June 21, 1999). F. EMERGENCY RESPONSE PROGRAM The following summarizes the emergency response and notification procedures at the facility. 1. In the event of a spill, release, near miss, or threatened release involving ammonia, evacuate the immediate area and report the situation to the area supervisor. 2. Area su pervisor will contact the Plant Manager and the Chief Engineer. If both are not available (e.g. off-site), then the highest ranking supervisor on-site is contacted at the front office. If needed, the Plant Manager and Chief Engineer are contacted using pagers and/or telephone calls. The Plant Manager, Chief Engineer, or the highest ranking on-site official can authorize a plant evacuation. 3. When the evacuation horn sounds, all employees should follow the evacuation procedures and evacuate the plant to ensure their safety. Currently, the facility evacuates its employees by the use of an alarm system and personal communication. It is the responsibility of the management and supervisory staff to notify all employees of the need to evacuate. 4. Call 911 to ensure public safety and have the emergency response team (trained to use SCBAs) readily available. The Chief Engineer or his designated alternate will evaluate the situation and determine appropriate response measures (e.g. use remote emergency switch to shut down equipment, clean up spills, etc.). 5. Notify the Stanislaus County Department of Environmental Resources, Hazardous Materials Division at (209) 525-4150 (after hours contact (209) 525-7911, ask for pager 141). Also contact the Governor's Office of Emergency Services (OES) Chemical Emergency Planning & Response Center 1-800-852-7550. The following information should be relayed: Address of the plant. Caller's name and name of the company. Name of the hazardous material released. Time of the release. Quantity of hazardous chemical released. 6. If more than 100 pounds of ammonia is released, the National Response Center should be notified at 1-800-424-8802. 7. Within 48 hours, a complete investigation must be performed. 8. Within 30 days of the release, the Emergency Release Follow-up Notice Reporting Form must be completed and sent to the Chemical Emergency Planning and Response Center (CEPRC) Local Emergency Planning Committee (LEPC) in Sacrame nto. G. PLANNED CHANGES TO IMPROVE SAFETY There were several recommendations resulting from the development of the PSM/RMP document including recommendations from the Process Hazard Analysis and Off-Site Consequence Analysis studies. These Teams made several procedural/managerial recommendations to improve safety at the facility. These recommendations are expected to be implemented by June 1999 and are listed as follows: HIGH PRESSURE RECEIVER R01 Correct drawing to include the king valve. Update all piping and instrumentation diagrams so that they may reflect the current ammonia refrigeration system accurately. R02 Install a solenoid king valve on the main liquid feed line close to the receiver and ammonia sensors in the area. The sensors should be interlocked to close the solenoid valve. Allow the compressors to run in the event of an emergency. In addition, install two remote shut off switches near the maintenance shop exits that will close the solenoid king valve. R0 3 If the facility plans to have employees respond to an emergency situation where Level A HAZMAT suits are required, at least three suits must be owned. Employees must be trained such that three employees would be able to assist in an emergency at any one time. These employees need to be certified annually. R04 Implement a maintenance program (recertification/replacement) for all pressure relief valves. Industry standard is every five years. Automatically replace any relief valve that unseats. R05 Consider placing sensors at the end of the pressure relief header throughout the system. R06 Insulate or paint all exposed piping and equipment. Ensure that all piping is fitted with appropriate moisture barriers when insulated. R07 Include in maintenance program a regular check for corrosion of all piping and vessels. R08 Implement a maintenance matrix log for all types of inspections/programs for documentation verification. This should include the name of who performed the task and the date. In addition, include documentation pertaining to tests and maintenance performed by outside contractors. R09 Write and implement a comprehensive training program for all new employees hired to work with the ammonia system. Refresher training should be given to employees on an as needed basis. Training should include areas such as operations, maintenance, and emergency response. R10 Require all employees to sign an agreement stating that he or she is confident in their ability to perform a task for which they received training, before he or she performs the task. R11 Install safety shower/eyewash stations to satisfy all OSHA requirements. Specifically, personnel must be able to reach an eyewash station within ten seconds from standard maintenance locations where the ammonia system is opened. R12 Instruct employees to wear a full face mask and carry an eyewash squeeze bottle when performing maintenance on the roof. R13 Write and implement an emergency res ponse plan that includes evacuation procedures and appropriate response training for all employees. Document such events and invite the local fire department to discuss emergency procedures. R14 Annual evacuation drills should include alarms or horns, planned evacuation routes and head counts at designated reporting stations. Invite the local fire department to supervise the drills. R15 Designate an alternate gathering place that may be used during an evacuation in the event that an ammonia release occurs in or near the primary gathering place. R16 Investigate procedures that may be used to alert employees of wind direction in the event that an alternate gathering site must be used (such as a wind sock or public address system). LOW PRESSURE RECEIVER R17 Keep on hand a supply of absorbent and a tarp to clean up low pressure liquid spills. R18 Familiarize employees with low pressure ammonia spill cleanup procedures. R19 Incorporate written oil draining procedures into ma intenance program. STORAGE COOLER R20 Install ammonia sensors in the storage cooler as well as in all other storage rooms, warehouses, and production areas where ammonia is present. In order to isolate each area, interlock each sensor to the liquid feed solenoid valve for that particular area only. Do not interlock these sensors with compressor shut off switches. R21 Include in maintenance program a regular check for corrosion, scaling, and pinhole leaks. R22 Consider moving the breaker switches for the PLC outside the cold storage room. COMPRESSORS R23 Install ammonia sensors in the compressor area. Interlock these sensors to shut off the compressors and close the new solenoid king valve. R24 Interlock sensors recommended in R23 with evacuation alarms. MISCELLANEOUS Document facility fill procedures - this should include having an F&A Dairy operator present during fills. Obtain and approve supplier's ammonia fill procedures. Before each fill, require the driver to s ign a procedural agreement. Keep a supply of safety equipment on hand when filling. Hang evacuation signs (such as evacuation routes, directional notices, etc.) in the alleyways to direct employees to the gathering site during an evacuation. Place sensors in the alleyways and interlock them to the king solenoid valve and low pressure receiver liquid feed solenoid valve. Include exercising critical valves annually in the preventive maintenance program. |