Crystal 10th Street Plant - Executive Summary

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Crystal Cream & Butter Co. has instituted a Risk Management Program for their fluid milk processing facility, Tenth Street Plant, as required by Federal Accidental Release Prevention (ARP) Program regulations at 40 CFR Part 68.  The Risk Management Program identifies the equipment, procedures, maintenance, inspection, and training associated with Regulated Substances (RS's) handled at this facility in excess of Federal threshold quantities; describes the structured assessment of hazards which was conducted to assess possible effects on employees and offsite public and environmental receptors; provides the results of an offsite consequences analysis; defines a prevention program, emergency response program, and mitigation measures to reduce the probability and magnitude of accidental releases of RS's; and establishes a schedule and responsibilities for implementation of mitigation measures and auditing of program elements.  This Risk Management Plan (RMP) is being filed as required by A 
RP regulations in order to report the elements of the current Risk Management Program and to describe further measures planned to mitigate or prevent accidental releases of RS's.   
Crystal Cream & Butter Co.'s fluid milk processing and dairy products manufacturing facility, Tenth Street Plant, is located at 1013 D Street, Sacramento, CA in Sacramento County, and uses anhydrous ammonia, a RS, for refrigeration in quantities greater than the Federal threshold quantity for this RS. The facility is located in downtown Sacramento in a mixed industrial / residential area.  There are 110 full-time employees at this site.  The ammonia refrigeration system at the Tenth Street Plant consists of three interconnected systems operating under different conditions to accomplish product cooling, storage room refrigeration, and freezing functions.  The ammonia is fully contained in piping and vessels throughout the system, and changes its physical st 
ate at different locations in the system.  The basic ammonia refrigeration cycle operates by allowing liquid ammonia to vaporize, removing heat from the product being processed.  The vaporized ammonia is returned to the liquid state by compressing it and passing it through piping in an evaporative condenser, where the excess heat carried by the vapor is rejected to water which in turn evaporates, while the ammonia vapor condenses to liquid again.  Anhydrous ammonia is received in bulk liquid form by truck and charged into the main ammonia receiver periodically  to make up minor losses.  
It is the policy of Crystal Cream & Butter Co. that the receipt, storage and handling of anhydrous ammonia at its facility be done in a manner which meets regulatory requirements and minimizes the probability and severity of releases of anhydrous ammonia to the atmosphere, in order to protect the health and safety of its workers, the public 
, and the environment.  In order to accomplish this goal, Crystal Cream & Butter Co. has gathered safety information on anhydrous ammonia and on the process, equipment and procedures involving anhydrous ammonia; performed a structured assessment of hazards of the process and external events which might affect the process; performed an offsite consequences analysis of defined release scenarios; established a written program for prevention and mitigation of releases; and established a written emergency response program coordinated with emergency response agencies. 
A single "worst case" release scenario is required to be considered for each stationary source, resulting in the maximum distance to an endpoint for all toxic RS's contained on site above the threshold quantity. 
The worst case release scenario for toxic chemicals is defined in the ARP regulations as the release of the contents of the largest single container of RS (in this case anhydrous ammonia) o 
ver a period of 10 minutes. The scenario considered the release of the contents of the largest container of anhydrous ammonia on site, in this case 25,000 lb., the entire charge of ammonia in the system.  This release scenario is not physically possible, due to the characteristics of anhydrous ammonia. 
An "alternative case" release scenario is required to be considered for each toxic RS handled in quantities greater than the threshold quantity at the site. 
The "alternative case" scenario is described in the ARP regulations as a likely release resulting in offsite effects, considering administrative controls and mitigation measures in place, and is to be determined by the facility operators as part of the Process Hazard Analysis required to be performed during RMP development.  The "alternative case" considered for this facility is the release of liquid anhydrous ammonia from an oil drain from a vessel due to an operator error, with the release secure 
d by an employee wearing proper personal protective equipment closing the oil drain valve after 5 minutes. 
Administrative controls in effect at Crystal Cream & Butter Co. which were considered to mitigate the severity of the Worst Case and Alternative Case release scenarios include Crystal Cream & Butter Co.'s written policies and procedures for training of operators and maintenance personnel, written procedures for control of the inventory of anhydrous ammonia at the facility, and policies regarding quality level of replacement materials and components for the anhydrous ammonia system. 
No mitigation measures were considered to limit the severity of the Worst Case scenario.  No passive mitigation measures were considered to limit the severity of the Alternative Case scenario.  Active mitigation was considered for the Alternative Case, in the form of response of trained employees in a timely manner. 
General accidental release prevention programs instituted by Crystal Cream & Butter Co. are categorized as administrative (management) programs; procedures, training, and engineering controls; and emergency response programs. 
Crystal Cream & Butter Co. has instituted a Process Safety Management (PSM) Program meeting OSHA requirements at 29 CFR 1910.119 covering its refrigeration process.  This constitutes the general accidental release prevention program for Crystal Cream & Butter Co.'s operations. The program and document management procedures included in the PSM Program will be used as the management system for the Risk Management Program. 
Release prevention steps specific to anhydrous ammonia have been identified and implemented.  These include, among other things, the creation of numerous facility-specific operation procedures with check boxes for completion of critical steps. 
There have been no acc 
idents involving anhydrous ammonia at this facility within the past five years resulting in injuries or offsite consequences. 
Crystal Cream & Butter Co.'s Emergency Response Program applicable to anhydrous ammonia has been coordinated with Sacramento County Environmental Management Department, Hazardous Materials Division, the local agency responsible for hazardous materials inventory reporting and release response coordination.  It consists of notification of the public agency assigned responsibility for First Response to hazardous materials release emergencies.  First Responders have participated with Crystal Cream & Butter Co. personnel in response drills. 
All of the improvements and mitigation measures identified in the process hazard analysis which Crystal Cream & Butter Co. committed to accomplish have been completed or are in progress.  Any other measures identified by employees during workplace hazard surveys, or  
as a result of audit activities, will be thoroughly reviewed and considered for implementation.
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