HUMBOLDT CREAMERY ASSOCIATION - Executive Summary |
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INTRODUCTION This California Accidental Release Prevention (Cal ARP) Program, Risk Management Plan (RMPlan) has been prepared by SHN Consulting Engineers & Geologists, Inc. (SHN), on behalf of The Humboldt Creamery Association (HCA). This Program has been compiled for the HCA Facility, in accordance with the Cal ARP Program requirements which are specified in the California Code of Regulations (CCR Title 19, Division, Chapter 4.5), OSHA Process Safety Management (PSM) standards (Section 5189 of Title 8 of CCR, or Code of Federal Regulations Title 29, Section 1910.119), and EPAs Risk Management Program (RMP) Rule (40 CFR 68). The HCA facility is owned and operated by The Humboldt Creamery Association, and is located at Fernbridge, Humboldt County, California (Figure 1). Anhydrous ammonia is being used in the cooling and refrigeration systems. The following plan covers the HCA Facility, and its processes (Figure 2). The format used in producing this plan come directly from the Ca l ARP Program guidelines for completing Risk Management Plans. 1.0 EXECUTIVE SUMMARY The Humboldt Creamery Association (HCA) is committed to operating in a manner that is safe for the HCA workers, the public, and the environment. As part of this commitment, HCA has established a system to help ensure safe operation of the processes at this facility. One component of this system is a Risk Management Program (RMP) that helps manage the risks at this HCA facility. Additionally, this RMP complies with all requirements Cal ARP, the OSHA PSM standards, and the EPA RMP Rule. The risk management program at HCA consists of three elements: 1. A hazard assessment to help understand the potential on- and off-site consequences of hypothetical accidental releases, and accidents that have occurred during the past five years associated with the use of substances regulated by the RMP rule. 2. A prevention program to help maintain and safely operate the processes containing more than a threshol d quantity of a regulated substance. 3. An emergency response program to help respond to accidental releases of regulated substances from covered processes. Information further describing these elements is provided in this Risk Management Plan (RMPlan), and the HCA Ammonia Refrigeration System Procedures Manual. This HCA facility and ammonia process have recently been upgraded, and meet or exceed the standards. The systems are continually monitored by a microprocessor, and can be remotely monitored and controlled, as required. The facility, equipment, systems, and controls were carefully designed, and constructed to reduce the likelihood of an accidental release. Industry and government standards are closely adhered to in the design, construction, and operation of the equipment. The safety program at HCA consists of a number of elements, only some of which are required by the RMP Rule. This RMPlan is primarily intended to describe those parts of the safety program at HCA that are required by the RMP Rule. 1.1 Accidental Release Prevention and Emergency Response Policies HCA is committed to safety, through the prevention of accidental releases of hazardous substances. HCA implements reasonable controls to prevent foreseeable releases of hazardous substances. These controls include; training for key employees to respond appropriately to an accidental release; coordination with the Eureka Fire Department (Hazardous Materials Response Team), local fire departments, the Humboldt County Division of Environmental Health, and other similar facilities, to help ensure that injuries and/or environmental damage will not occur if a release does occur; and establishing inspection and evaluation programs to identify potential hazards. In the event of an accidental release, HCA will assess the situation, and together with the local fire departments and the Hazardous Materials Response Team (HMRT), they will control and contain the releases in a manner that will be s afe for workers to help minimize injury to the public or the environment. HCA has designated an emergency response coordinator to oversee response activities, and will continue to coordinate its response efforts with the local fire departments and the HMRT. In order to effectively implement these policies, HCA established a management system headed by the Operations Manager to oversee safety-related activities. 1.2 HCAs Regulated Substances Handled and Source Information As part of the facilitys cooling and refrigeration systems, anhydrous ammonia is used and stored in sufficient quantities to be regulated by the Cal ARP Program, EPA RMProgram, and OSHA PSM regulations. The federal threshold quantity is 10,000 pounds of anhydrous ammonia, and the facility contains approximately 30,000 pounds. 1.3 Off-site Consequence Analysis HCA performed an off-site analysis to estimate the potential for an accidental release of anhydrous ammonia, which is a regulated substance that could ad versely affect the public or the environment. The off-site consequence analysis consisted of evaluating both worst-case release scenarios and alternative release scenarios. HCA does not expect a worst case release scenario to ever occur; therefore, alternative release scenarios were selected to assist in improving the emergency response plan. Alternative release scenarios represent a release that might occur at a facility like HCAs, and would result in the greatest potential off-site consequences if the release occurred. The main objective of performing the off-site consequence analysis is to determine the distance at which certain effects might occur to the public because of an accidental release (called the endpoint distance). The following effects could occur at the endpoint distance. At the distances less than the endpoint distance, the effects would be greater: at distances greater than the endpoint distance, the effects would be less. When considering the release of a to xic substance, most people at the endpoint distance would be able to walk away from the exposure without any long-term consequences, although some short-term consequences (e.g., strong eye or throat irritation) are likely. Some people who are particularly susceptible to the substances released could be impacted. 1.3.1 Worst Case Release Scenarios for the Program 3 Process LocationI.D. Scenario Description Amount Released and Duration Released Distance To End Point, Rural / Urban Comments on Modeling and Scenario Results Second Floor Mechanical Room worst-case release scenario for 15,000-lb Pressure Vessel 15,000-lb total release1,500 lb/min10-minute duration 1.9 miles or 10,378 ft/1.6 miles or8,176 ft This scenario was modeled as a direct release over a 10-minute period as required by the regulations. First Floor Mechanical Room worst-case release scenario for 10,000-lb Pressure Vessel 10,000-lb total release1,000 lb/min10-minute duration 1.6 miles or8,730 ft/1.3 miles or6,887 ft This scenario was modeled as a direct release over a 10-minute period as required by regulations. 1.3.2 Alternative Anhydrous Ammonia Release Scenarios LocationI.D. Scenario Description Release Rateand Duration Distance To End PointRural Urban Comments on Modeling and Scenario Results Mechanical Rooms Alternative Release Scenario for a liquid line leak or hole development in a tank.Based upon a = inch hole 337 lb/min45-minute duration 0.74 miles or 3,877 ftRefer to Table 5-7 0.60 miles or3,185 ft This scenario was modeled as a release from an orifice from the bottom of a horizontal cylindrical tank below the liquid level. The model predicts that the ammonia escapes as a mixture of gas and liquid (two-phase flow). Mechanical Rooms Alternative Release Scenario for a liquid line leak or from the tank truck hose protected by an excess flow valve.Flow based on the excess flow valve flow rating Release rate calculated by model based on hole size. Refer to Table 5-7 for resultsApp endix A Refer to Table 5-7 for results Appendix A This scenario was modeled as a release from an orifice from the bottom of a horizontal cylindrical tank below the liquid level. The size of the hole yields an initial release rate that can be used to simulate the rated flow of the excess flow rate. Alternative Release Scenarios (Continued) LocationI.D. Scenario Description Release Rateand Duration Distance To End PointRural Urban Comments on Modeling and Scenario Results Mechanical Rooms or Equipment Locations Alternative Release Scenario for gas piping or instrument connection failure.Small gas leak from gasket or seal failures, small or large breaches in piping, and small instrument orifices. Rate varies with size of hole Release rate calculated by model based on hole size and duration. Refer to Table 5-8 for results Appendix A Refer to Table 5-8 for results Appendix A This scenario was modeled as a release from the top of a horizontal cylindrical tank with a conservative heig ht of 8 feet. The ammonia escapes only as a gas. Mechanical Rooms or Equipment Locations Alternative Release Scenario for tank pressure relief valve failure or vapor leak from an excess flow valve protected vapor line.Flow based on the pressure relief valve or excess flow valve flow rating Release rate based upon rated flow from the actual relief or excess flow valve on tank and duration Refer to Table5-8 for results Appendix A Refer to Table 5-8 for results Appendix A This scenario was modeled as a release from the top of a horizontal cylindrical tank or truck above the liquid line level. The size of the hole yields an initial release rate that can be used to simulate the rated flow of relief valve or excess flow valve. The ammonia escapes only as a gas. Dump station and sump Alternative Release Scenario for dumping a tank that has been overfilled or prior to working on a tank or system. Liquid dumped; however, vapors are released.Flow based on hose size, all excess liquid that is dumped to the sump Release rate based upon quantity and depth of liquid dumped Refer to Table5-4 for results Appendix A Refer to Table 5-4 for results Appendix A This scenario was modeled as a release from a sump.The ammonia escapes only as a gas. 1.4 Mitigation Measures On-site mitigation measures include; a visible wind sock; ammonia sensors at the process and storage areas; sensors connected into a warning light system that is monitored in the control room (operators present 24 hours a day); a microprocessor monitors the process and equipment, and can be accessed by the control room operator and the maintenance supervisor; the maintenance supervisor can access and control vital operating parameters from his home; a newer facility in which much of the ammonia tanks and piping are located inside; a venting systems for pressure relief and for venting the storage areas (if required); an emergency dump control and large sump areas that will contain a large quantity of ammonia (when e mergency conditions exist); a facility that has properly secured equipment and piping; PPE equipment located at strategic areas; an experienced maintenance crew; employee training and establishing emergency response procedures; and have an outside agency, contractor, or emergency response team conduct periodic inspections of the facility and processes. Off-site mitigation measures include; a visible a wind sock, a portable ammonia sensor to assist the emergency responders; and coordinating with the local fire department and the HMRT, so they can respond to emergencies in a safe and efficient manner. Annual inspections of the processes and equipment will determined how to make the systems safer. 1.5 Accidental Release Program and Emergency Planning In June of 1999, HCA revised their Emergency Response Plan. Additionally, the RMP includes a specific Emergency Response Program for ammonia. HCA maintains a variety of technical documents that are used to help ensure safe operations o f the facility ammonia processes. These documents address the physical properties of hazardous substances handled at the HCA facility, operating parameters of the systems, and equipment operating procedures for these processes. HCA ensures that this process safety information is available. Material Safety Data Sheets (MSDSs) document the physical properties of hazardous substances handled at the HCA facility, including anhydrous ammonia (liquid and gas phases used in the ammonia processes at the facility. The MSDS information available for a hazardous substance typically includes;: 7 toxicity information and permissible exposure limits 7 physical data (e.g., boiling point, melting point, flash point 7 reactivity and corrosivity data 7 thermal and chemical stability data 7 hazards of mixing substances in the process MSDSs for the hazardous substance handled (anhydrous ammonia) are available so that the operators and employees have ready reference to this information. In addition, MSDSs are provided to the emergency response teams for use in helping formulate emergency response plans. The engineering design documents include the operating parameters and configuration of the equipment in each covered process (See Operations and Maintenance Manuals). When important information is not available from the design documents, it is developed through special projects or, in the case of operating parameters, during the process hazards analyses of the process. In June of 1999, HCA developed their Ammonia Refrigeration System Procedures Manual to help with the safe operation of the process. This document is used to train employees, to perform process hazards analyses, and to help maintain the equipment. 1.5.1 Process Hazard Analysis. HCA performs and periodically updates the Process Hazard Analyses (PHAs) of the covered processes, which will help identify process hazards and generate recommendations that might improve the safe operation of the process. A team comp osed of personnel with engineering, process operating experience, and a leader with process hazard analyses experience is assembled to analyze the hazards of the process. HCA primarily uses a PHA checklist to perform the analysis. In June of 1999, the PHA team prepared a written report describing the results of the analysis, including a list of recommendations. Responsibility to resolve the recommendations was assigned to unit personnel and, when appropriate, changes to enhance the safety of the processes will be implemented. 1.5.2 Operating Procedures. HCAs Operations Manager, Maintenance Supervisor, and maintenance crew work together to develop and maintain operating procedures to define how tasks related to process operations should be safely performed. The operating procedures are used to train employees and serve as reference guides for appropriate actions to take during both normal operation and process upsets. HCA personnel develop and maintain operating procedures that cover all phases of operations, including initial startup, normal operations, normal shutdown, emergency shutdown, and startup following a turnaround or emergency shutdown. 1.5.3 Training. HCA provides training for workers to safely and effectively perform their assigned tasks. The training program include both initial and refresher training that covers a general overview of the process, the properties and hazards of the substances in the process, and a detailed review of the process operating procedures and safe work practices. The maintenance personnel and operators are consulted annually at a safety meeting to evaluate the effectiveness and frequency of the training. Recommendations from the maintenance personnel and operators are reviewed, and changes to the training program are implemented as appropriate. 1.5.4 Mechanical Integrity. HCA maintains the mechanical integrity of process equipment to help prevent equipment failures that could endanger workers, the public, or t he environment. The mechanical integrity program includes; inspection and testing program to help identify equipment deterioration and damage before the equipment fails, and a quality assurance program to help ensure that new and replacement equipment meet the design standards required for service in each process. 1.5.5 Pre-startup Review. HCA performs a safety review of a new or modified process before the process is placed into service to help ensure that the process has been prepared to operate safely. A pre-startup review checklist is completed to document the review and to ensure that appropriate issues have been addressed. 1.5.6 Management of Change. The HCA management of change program evaluates and approves all proposed changes to chemicals, equipment, and procedures for a covered process to help ensure that the change does not negatively affect safe operations. Process changes that are determined to be a replacement in kind (e.g., replacing a valve with an identical v alve) are allowed without completing a full management of change program. All other changes must be confirmed through the full management of change program to help ensure that inadvertent consequences of process changes are prevented, safety consequences of changes are addressed, affected process safety information and procedures are updated, and affected employees are notified of the changes. 1.5.7 Compliance Audit. HCA audits cover the processes to be certain that the prevention program is effectively addressing the safety issues of the operations. HCA assembles an audit team that includes personnel knowledgeable in the RMP rule and in the process, and this team evaluates whether the prevention program satisfies the requirement of the RMP rule, and whether the prevention program is sufficient to help ensure safe operation of the process. The results of the audit are documented, recommendations are resolved, and appropriate enhancements are implemented. 1.5.8 Incident Investi gation. HCA investigates all incidents that could reasonably have resulted in a serious injury to personnel, the public, or the environment so that similar accidents can be prevented. HCA provides training to the employees to identify and report any incident requiring investigation. An investigation team is assembled, and the investigation is initiated within 48 hours of the incident. The results of the investigation are documented, recommendations are resolved, and appropriate process enhancements are implemented. 1.5.9 Employee Participation. HCA has developed an employee participation program for the covered process to help ensure that the safety concerns of the workers are addressed. HCA encourages active participation of personnel in the prevention program activities of the covered process at the facility. Employees are consulted and informed about specific aspects of the RMP, including PHAs and operating procedures. 1.5.10 Hot Work Permits. HCA established a hot work permit program to control spark or flame producing activities that could results in fires or explosions in covered process areas of the facility. OSHAs fire prevention and protection requirements in 29 CFR 1910.252(a) were reviewed, and a hot work permit form is included to comply with these requirements. Personnel who are to perform hot work are required to fill out the hot work permit form. The shift supervisor reviews the completed form before work can begin. Training in the use of the hot work permit form is included in the HCA safe work practices orientation. 1.5.11 Contractors. HCA established a program to help ensure that contractor activities at the facility process areas are performed in a safe manner. The program reviews the safety record of all contractors to help ensure that HCA hires contractors who can safely perform the desired job tasks. HCA explains to the contract supervisors the hazards of the process on which they and their employees will work, HCAs safe work practices, and the HCA emergency response procedures. The contractor supervisors are required to have trained employees that will work in and around the ammonia process areas. 1.6 Chemical-specific Prevention Steps In addition to the required prevention program elements, HCA has implemented safety features specific to the facility ammonia process areas. The following paragraphs describe some of these safety features. The facility has been updated and meets the requirements necessary for operating in a safety manner. When ammonia is needed for filling the system, it is transported into the facility, and is pumped to the storage container using all required handling procedures. When transporting, and filling the tanks, transfer procedures are strictly adhered to. Only trained personnel will complete the transfer process. Additionally, an HCA personnel is present during the filling process. PermaCold Engineering, Inc., (800)455-8585, provided the engineering design, drawi ngs, specifications, and operation manuals for specific ammonia processes. They have the necessary experience in designing systems that meet the applicable codes. Process Cooling (Vic Dervin (408)996-0595, provided piping and control system designs, and operational procedures for specific ammonia processes at the facility. They have the necessary experience in designing systems that meet the applicable codes. This company has a computer link to the HCA microprocessor control system, and can assist in operational problems. Hours meters were installed on specific equipment motors to assist in determining when maintenance and changes are needed. When equipment is found defective or worn, it is replaced. HCA has an experienced maintenance crew that keeps the facility and equipment running in a safe and efficient manner. Ammonia pressure vessels and associated equipment, piping, and valves, are generally located inside. Much of the equipment and processes are monitored by a micro processor and sensors. Ammonia detectors and alarms are provided in most areas containing anhydrous ammonia. Detectors have an audible alarm as well as having a light that goes on to warn workers entering that space. The control room has a light that is energized when one of the remote sensors or lights are energized, and the control room is occupied 24 hours per day. All tanks, piping systems, and supports have been designed and installed to meet the appropriate seismic requirements. The surrounding structures were also seismically designed. Flex connectors are used at locations where excessive movement can occur between the tank and the secured piping. The cylinders are located within areas that will secure them from large objects which could fall and damage the cylinders or supply systems. The cylinders are located inside a fire proof structure. 1.7 Five-Year Accident History There have been no accidents reported in the last five years, with regard to a significant relea se of anhydrous ammonia. If an incident occurs, then an investigation team will be assembled to follow the incident investigation protocol. The team will suggest improvements to the process and, if appropriate, improvements will be made. 1.8 Emergency Response Program HCA has established a written emergency response program to help safely respond to accidental releases of ammonia. HCAs emergency response plan complies with other federal contingency plan regulations (e.g., the OSHA regulations 29 CFR 1910.39(a) and has been communicated to the local emergency response team. HCA maintains a regular dialogue with the emergency response teams. 1.9 Planned Changes to Improve Safety HCA constantly strives to improve the safety of the ammonia processes at the facility, through both the incident investigation program and a through the process hazard analysis. The following changes to improve process safety are planed or have recently been completed. 7 HCA reviewed the ammonia conta inment and handling system processes 7 Ammonia equipment and systems are continuously maintained 7 Relief venting and area ventilation systems are maintained 7 Ammonia sensors and warning systems were reviewed. HCA purchased a hand held sensor for emergency response purposes, and is looking into improving their warning systems. 7 HCA has reviewed their training and emergency response programs and will continue to improve in these areas. 7 HCA will be training other personnel in the procedures for starting and stopping the systems, transferring fluids, and unloading systems to the sump area. |