California Spray Dry Company - Executive Summary |
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FEDERALLY MANDATED RMP SUBMISSION EXECUTIVE SUMMARY 1. Accidental Release Prevention and Emergency Response Policies This facility handles chlorine and ammonia (anhydrous), which are considered hazardous materials. The properties of both materials make it necessary to observe safety precautions in handling to prevent human exposure and to reduce the threat to the facility's workers and nearby members of the community. It is the facility's policy to adhere to all applicable Federal and State of California rules and regulations. Safety depends upon the safe procedures used to handle chlorine and ammonia; the safety devices and system designed and constructed into the facility; and the training of the pertinent personnel. 2. Stationary Source and Regulated Substances Handled Chlorine gas is used at three locations in the CSDS facility-at the digest scrubber for order control of the scrubbed gases and at the two dryer scrubbers to oxidize the odor-causing compounds in the scrubbed gases. Chlorine is delivered by the supplier for storage on a covered area on a concrete slab. A one-ton cylinder is changed approximately once a month at the digest scrubber and every 10 days at each of the two dry scrubbers. When the gas flow at each site falls to zero, the empty container is returned to the storage area with the forklift and a full container is brought back to the site. Anhydrous ammonia is used at the CSDS facility to charge the central refrigeration system, provide product cooling during processing in silos and tanks, produce ice for a ice bank used for the chilled water generation for process uses, and provide cooling and freezing areas in the cold storage warehouse. The majority of the anhydrous ammonia equipment is located in and around the Mechanical Equipment Room and the cold storage warehouse. The system is totally contained and the only losses of ammonia requiring delivery of makeup quantities are from small fugitive emissions at valve stems and pump seals, residual ammonia gas pumped out of a section of the system prior to maintenance or repair; small amounts of ammonia gas lost during manual purging of air and removal of oil from the ammonia, and discharges from relief valves. Operation of the system is automatic through controllers that sense level, temperature, and pressure at various points in the system. The receipt, storage, and handling of the subject substances are considered as part of one complete process. 3a. Worst Case Scenario The one-ton chlorine cylinder is the largest vessels in the chlorine system. The Worst Case release scenario to be modeled assumes that the full 2000 pounds of chlorine are released over a ten-minute period resulting in a release rate of 200 pounds per minute. The distance to the endpoint of .0087 mg/l for the Worst Case release scenario is 1.3 miles. This chlorine release will extend beyond the boundaries of the stationary source. The total charge of ammonia in the system is approximat ely 10 tons. The Worst Case release scenarios to be modeled assumes that 20,000 pounds of ammonia are released over a ten-minute period resulting in a release rate of 1100 pounds per minute. The distance to the endpoint of .14 mg/l for the Worst Case release scenario is 1.5 miles. This ammonia release will extend beyond the boundaries of the stationary source. 3b. Alternative Release Scenario The Alternative Release scenario for the one-ton cylinder of chlorine assumes a release from a leaking valve at the connector, resulting in the release of 2 pounds of chlorine over a one-hour period. The distance to the endpoint of .0087 mg/l for the Alternative Release scenario for chlorine is .1 mile. This release will not extend beyond the boundaries of the stationary source. The Alternative Release scenario for the anhydrous ammonia system assumes a release from a ruptured disk/relief valve failure, resulting in the release of 2 pounds of ammonia over a one-hour period. The distanc e to the endpoint of .14 mg/l for the Alternative Release scenario for ammonia is .1 mile. This release will not extend beyond the boundaries of the stationary source. 3c. Administrative Controls Administrative controls to limit the distances for each reported scenario exists to restrict to a minimum the amount of chlorine and ammonia released, if a release were to occur, and preferably to not have a release occur. This administrative control is inherent in the operational procedures for the chlorine and ammonia systems and the training provided to the chlorine and ammonia operators. 3d. Mitigation Measures Mitigation measures to limit the distances for each reported scenario exists to restrict to a minimum the amount of chlorine and ammonia released, if a release were to occur, and preferably to not have a release occur. The mitigation measures are based upon the design, inspection, testing, and maintenance of the chlorine and ammonia systems and its related equipment and c omponents. 4. General Accidental Release Prevention Program and Chemical Specific Prevention Steps The facility complies with all applicable federal and state codes and regulations. There are safety meetings and safety training. The Process Safety Management (PSM) program implemented at the facility for the ammonia related activities and equipment represents one of the facility's main active commitments to an accidental release prevention program. 5. Five Year Accident History There have been no incidents involving the release of ammonia or chlorine within the past five years at the facility. 6. Emergency Response Program The Emergency Response Program is based on alerting personnel at the facility of the need to evacuate the facility and await the arrival of responders from the City of Stockton Fire Department at the evacuation assembly location if a release occurs that causes the evacuation to be initiated. The San Joaquin County Office of Emergency Services incorporates thi s response into the County Area Plan for the Region 4 Local Emergency Planning Commission. 7. Planned Changes to Improve Safety There are commitments made under the Process Hazard Analysis element of the Process Safety Management (PSM) that are being implemented at this time for the next year. Current applicable codes and regulations are reviewed as part of the PSM to determine if other commitments need to be made to achieve increased operational safety for the regulated process system. These commitments will be prevention and mitigation measures for accidental releases of the regulated substance. |