Super Store Industries Turlock Dairy Division - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The Super Store Industries Turlock Dairy Division abides by the emergency response procedures and policies detailed in the Emergency Response Plan 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. Super Store Industries 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 any facility changes. STATIONARY SOURCE AND REGULATED SUBSTANCE The Super Store Industries' facility is located at 2600 Spengler Way in Turlock, California. This location is situated along Kilroy Road, approximately one kilometer (0.62 miles) south of West Main Street. The area is primarily industrial with sparse residential areas to all sides. The facility manufacturers food products such as orange juice, flavored drinks, ice cream, sour cream, cheese, and yogurt. The facility was originally built in 1988. The facility was later expanded in 1994 to install additional processing equipment. The facility currently covers approximately 13 acres ( 560,000 square feet). The Super Store Industries Turlock Dairy Division uses anhydrous ammonia as a refrigerant within a closed system. The system, consisting of piping, valves, and 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. For example, 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 vacuum (approximately 6" Hg) on the low pressure side of the system to 150-160 psig on the high side. Ammonia is used as the refrigerant in the refrigeration process. The total ammonia inventory is 110,000 pounds. HAZARD ASSESSMENT SUMMARY Worst Case Release Result Summary The worst case release at this facilityis a release of the maximum quantity of ammonia that is present in the largest vessel on site or 35,000 pounds in 10 minutes. This vessel is enclosed by the building and th erefore provided passive mitigation measures were incorporated into the release rate calcuation. The most pessimistic meteorological conditions were used: 1.5 m/s and F stability. The facility is located in a rural setting. The maximum potential downwind distance to 200 ppm was determined using Exhibit 4-4 from EPA's "Risk Management Program Guidance for Ammonia Refrigeration Facilities", November 1998. This potential release scenario reaches off-site and may affect population receptors. No environmental receptors are affected by this potential scenario. Alternative Release Result Summary The alternative release scenario 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. There is a possibility that this release could occur outside, therefore passive mitigation measures were not incorporated. The meteorological conditions used were 3 m/s and D stability. The facility is locate d in a rural setting. The maximum potential downwind distance to 200 ppm was determined using Exhibit 4-5 from EPA's "Risk Management Program Guidance for Ammonia Refrigeration Facilities", November 1998. This potential release scenario reaches off-site and may affect population receptors. No environmental receptors are affected by this potential scenario. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS Administrative Measures The facility operates in accordance with the International Institute of Ammonia Refrigeration (IIAR) guidelines and standards including 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 addi tion, Super Store Industries has implemented a Process Safety Management program for compliance with the OSHA 1910.119 regulation since April 1992. Engineering/Design Measures Super Store Industries operates the ammonia refrigeration system to maintain appropriate temperatures for manufacturing and storing various food products. The system has several inherent features including: 1. Ammonia, when properly handled, has proven to be a reliable and safe refrigerant. Industry has used ammonia as a refrigerant for over 100 years. 2. The facility is manned 24 hours a day with qualified ammonia personnel. Having personnel always on-site shortens the response time in the event that an ammonia related emergency occurs at the facility. 3. An off-site company is used to monitor system alarms. In the event of an alarm, Valley Security contacts the plant and also designated off-duty personnel (as necessary). 4. The facility is located in an industrial area away from concentrated resi dential populations. This location decreases the probability of impacting sensitive populations in the event of an ammonia release. FIVE YEAR ACCIDENT HISTORY The five year accident history from May 1994 through May 1999 shows that there have been no releases of ammonia at the facility that exceed the Federal Reportable Quantity of 100 pounds. In addition, there have not been any releases of ammonia that have resulted in an OSHA reportable injury. The facility maintains a log of small leaks that occur; records of small leaks were documented starting in September 1997. There are incident investigation reports completed for these minor leaks as well as "near misses". There was one incident that did not exceed the Federal Reportable Quantity, yet was reported to the California OES and the Department of Emergency Response. This release occurred on March 9, 1998 at 2:30 am. Approximately 27 pounds of ammonia and 15 gallons of oil were spilled in the engine room. EMERGENCY RESPONS E PROGRAM Super Store Industries has implemented an Emergency Response Team that is trained to handle an ammonia release. All refrigeration operators are OSHA Technician Level trained (24 hours) and all supervisors are OSHA First Responder Operations Level trained (8 hours). The Super Store Industries' "Emergency Response Plan", is designed to meet the requirements for "Process Safety Management", and give our employees and community the maximum protection in the event of an ammonia release. The contents of this plan is used in the Hazardous Materials Management Plan which is filed with the Stanislaus County Department of Environmental Resources, as well as to update the existing plan in the Training Program Manual. The process for developing the best possible mitigation to any release large or small is through employee participation using the "Process Safety Management Committee", and any site specific documented plan previously used. The "Response Plan", includes continuously c hanging scenarios that are discussed during those meetings to always improve Response Safety. An "Emergency Response Team", located at this facility as well as "First Responders Operational Program" gives Super Store Industries both defensive and offensive protection. Super Store Industries conducts on-site emergency drills to provide training and to evaluate employee response in the event of a potential release. Fire drills can be incorporated using the scenarios that the wind may have disrupted the designated area on occasion. PLANNED CHANGES TO IMPROVE SAFETY The facility has conducted an initial Process Hazard Analysis study and recently updated that study. The following mitigation measures resulted from these studies and are planned to be completed by June 1, 2000: 1. Examine the valve numbering system and determine whether or not this existing system should be modified. 2. Conduct a facility inspection to review pipelines to ensure proper supports are present. 3. Conduct a review of the piping/valve system to ensure that all drain valves are properly capped or plugged. 4. Ensure that the procedure to use a wrench on the packing nut is included in the operating procedures and/or included in the annual safety training. 5. Include the "temporary" operation of storing ammonia inventory in the engine room in the operating procedures. 6. Include emergency equipment maintenance/inspections in the computer work-order program. 7. Conduct a facility inspection to determine the locations where a ladder is currently being used against pipelines and if there are alternatives that can be implemented (i.e. catwalks, valve chains, extensions, etc.). 8. Consider modifying maintenance procedure (work order) for pressure relief valve change-out to include safety equipment. This should include having a respirator cartridge on person - at ready during change procedure. 9. Have all the engineers review the operating procedures at least annually. In addition, have t he operators use new procedures and modify as necessary. Remaining Initial HAZOP Study Recommendations R04: Remove the oil and solvents from the engine room. Put oil on a portable cart for easy transportation. NOTE: The facility plans to implement this with the purchase of an air-tight container. R21: Label all ammonia lines (liquid, vapor, etc.). NOTE: The labels have been purchased. The facility is in the process of installing the labels. R40: Install portable eyewash stations on roof as needed. |