Berkeley Farms, Inc. - Executive Summary |
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EXECUTIVE SUMMARY Description of Facility and Regulated Substance Handled: Berkeley Farms, Inc. processes milk products. The facility utilizes anhydrous ammonia as a refrigerant to maintain the proper temperature of products within the facility. Anhydrous ammonia is an effective refrigerant that has been used for many years by most food processing facilities. Ammonia is normally a gas at ambient temperatures but is handled as a gas liquefied under pressure. The refrigeration system consists of a high-pressure receiver, evaporators, compressors, piping, and valves. Accidental Release Prevention and Emergency Response Policies: Berkeley Farms, Inc. is committed to promoting safety for the plant, its employees and the surrounding area. The facility is complying with OSHA's Process Safety Management Standard (PSM), Title 29 Code of Federal Regulations (CFR) 1910.119, and EPA's Risk Management Program regulations (RMP), Title 40 CFR Part 68. The purpose of these programs is to ensure th at the refrigeration system is operated safely in order to prevent releases of ammonia from the system. In addition, these programs serve to develop procedures to minimize releases in the event that they do occur and to outline appropriate emergency response steps to take in the event of a release. Worst Case Release Scenario: EPA's "Risk Management Program Guidance for Ammonia Refrigeration" (November 1998) and the International Institute of Ammonia Refrigeration's (lIAR) Risk Management Guidelines (1998) were the primary documents used to develop the worst case release scenario. The worst case release is one that is unlikely to occur. The purpose of the worst case release analysis is to support a dialogue with the community on release prevention. It is a conservative analysis and is not to serve as a rational basis for actual emergency response planning. The worst case release scenario (as defined by EPA) is the release of the largest quantity of ammonia from a vessel or process li ne failure that results in the greatest distance to a toxic endpoint. The worst case release scenario for the refrigeration process is assumed to be a case where the total quantity of ammonia in a vessel is released. The release scenario was performed assuming that the vessel was filled to 20 percent of capacity, the greatest amount that would ever be placed in the vessel. Passive mitigation systems (enclosures) were considered in the analysis, since the vessel is located in the engine room. The toxic endpoint used for this scenario must be where the ambient concentration of ammonia is 0.14 mg/L. or less. This endpoint is a concentration below which nearly all individuals could be exposed to for one hour without serious health effects. Based on Exhibit 4-4 in EPA's guidance, a release from the vessel would result in a situation where public receptors would be within the distance to the toxic endpoint. Alternative Case Release Scenario: The alternative case release scenario selected i s one in which a pipe leak allows ammonia to discharge directly into the atmosphere. EPA's "Risk Management Program Guidance for Ammonia Refrigeration" (November 1998) and the International Institute of Ammonia Refrigeration's (lIAR) Risk Management Guidelines (1998) were the primary documents used to develop the alternative release scenario. The alternative release scenario is one that is more likely to occur then the worst case release scenario. The alternative release scenario must meet two criteria: 1) Must be more likely to occur than the worst case scenario, and 2) Must reach an endpoint off site, unless no such criteria exist. A possible release scenario is one in which a pipe leak or pump seal rupture allows ammonia to discharge directly into the atmosphere. The toxic endpoint used for this scenario must be where the ambient concentration of ammonia is 0.14 mg/L or less. Based on EPA's guidance, the alternative release scenario would result in a situation where public rec eptors would be within the distance to the toxic endpoint. Accidental Release Prevention Program and Chemical-specific Prevention Steps: As a part of its PSM Program Berkeley Farms, Inc. has established numerous programs that serve to prevent accidental releases of ammonia. These programs include: Process Safety Information Process Hazard Analysis Operating Procedures Training Mechanical Integrity Management of Change Pre-Startup Review Compliance Audits Incident investigations Employee Participation Hot Work Permits Contractor Safety Emergency Response Information: As a part of the PSM Program, the facility maintains an Emergency Response Plan that was prepared in order to improve responsiveness to an emergency incident, and to increase the reliability of actions taken during an incident. The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies as well as the public. In the event of an emergency involving the ammonia system, it is policy of the facility to request assistance as necessary by calling 911 which will notify the Hayward Fire Department In addition, the Hayward Fire Department has included Berkeley Farms, Inc. in its local emergency response planning. Five-Year Accident History: Berkeley Farms, Inc. has had an excellent record of preventing accidental releases over the last 5 years. Due to our stringent release prevention policies, there has been no accidental release during this period. Steps to Improve Safety: Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program. Revised Operating Procedures, updated maintenance process reviews, revised Standard Operating Procedures, and updated Pre-Startup Safety Reviews are some of the major steps taken to improve safety at our facility. These changes have been implemented by Berkeley Farms, Inc. In addition, the facility will continue to operate and maintain the system in accordance with IIAR Guidance and will continue to implement its OSHA PSM Program in conjunction with the Risk Management Program. |