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Home My WebLink AboutRISK MANAGEMENT CITY'of BAKERSFIELD "WE CARE" FiRE DEPARTMENT 2101 H STREET S. D. JOHNSON January 26,1993 BAKERSFIELD, 93301 FIRE CHIEF 326-3911 Mr. Dennis. Conley Regional Safety Manager Unocal Oil & Gas Division 1800 30th Street Bakersfield, CA 93301 Dennis: The CA Health & Safety Code Division 20, Chapter 6.95, Section 25534(h), requires Risk Management and Prevention Programs (RMPP) to be reviewed and revised as necessary at least once every three years. 25534(h) The handler shall review the RMPP, and shall make necessary revisions to the RMPP at least every three years, but, in any event, within 60 days following a modification which would materially affect the handling of an acutely hazardous material. Unocal's anhydrous ammonia RMPP was completed in February of 1989. The three year review is now overdue. Bakersfield Fire DePartment, Hazardous Materials Division requests that the review and revision of Unocal's anhydrousammonia risk management and prevention program (RMPP) be prepared and submitted by April 30, 1993. Please read the attached recommended qualifications for RMPP preparers. Submit a qualifications statement for the individuals who will be conducting the RMPP review prior to beginning work. Following is a list of topics which must be addressed in this RMPP review and revision. 1.' Verification of the adequacy and completeness of the existing hazard and operability study. A hazard analysis should be conducted for any modifications which have not been addressed by previous RMPP revisions. 2. Review all RMPP sections for any necessary changes, additions' or deletions. ' 3. Update equipment schedules as necessary. 4. provide a report of any accidents involving anhydrous ammonia which may have occurred since the RMPP was submitted. 5. A report specifying the age and condition of the ammonia handling equipment including schedules for maintenance was not included in the original RMPP. This information should be added in to the revised RMPP 6. Revise the off site 'consequence analysis to comply with the current CA Health and SafetY Code requirements, Chapter 6.95, Section 25534(d)2. Revi§e exhibit 1 to indicate the zones of offsite vulnerabilitY. These requirements are detailed in Bakersfield Fire's RMPP Preparation Guidelines. 7. Provide a schedule, if necessary, for the revised RMPP implementation. I have 'enclosed an excerpt from the CA Health and Safety Code which lists the' required elements of a RMPP and includes the code sections cited above. Please contact me at 326-3979 if I can be of assistance. Si'ncerely, Barbara Brenner Hazardous Materials Planning Technician cc: Ralph Huey i ~.800 30TI~I ST : ..." CITY of BAKERSFIELD · "WE CARE" FIRE DEPARTMENT 2101 H STREET D. S. NEEDHAM BAKERSFIELD, 93301 FIRE CHIEF 326-3911 Mr. Dennis Coniey Regionai Safety Manager Unocal Oil & Gas Oivs~ion 1800 30th Street Dear Mr. Conley, Thank you for the timely resoonse to the RMPP .inspection ?ollow-uo.. ~ll of the responses are acceptable actions to remedy the issues o? concern. One additional item needs attention. The hazardous materials business plan for Unocal has not been updated to reflect the change~ since the implementation of the RMPP. The inventory and site diagram reflect ammonia storage on the second floor. Please fill out the enclosed inventory-form, deleting the ammonia storage on the second floor eno addin9 the ammonia storage outdoors. .6void the use of symbols on the site diagram and just ~rite in the names of the required items. Please return the updated information ~ithin one month~ by November ~, 19~0. Call ~e at J~5-J~F~ if I can be of Sincerely, Barbara Brenner Hazardous Material~ Plann~ng Technician Oil & Gas Division Unocal Corporation 1800 30th Street, Suite 200 Bakersfield, California93301-1921 0CT 2 21990 Telephone (805) 322-7600 Ans'd ............ UNOCAL Dennis D. Conley n +- ~ ~,,,c,..o,.,e,. 18, 1990 Regional Safety Manager Western Region Barbara Brenner, Hazardous Material Planning Technician city of Bakersfield Fire Department 2101 H Street Bakersfield,- CA 93301 Dear Ms. Brenner: The six issues resulting from your inspection of our Drafting Departments's ammonia system on September 26, 1990 were addressed and actions were completed on all of them. The following is a summary of the actions taken: 1. An M.S.D.S. Display Station was mounted on the wall outside the entrance to the duplication area. All M.S.D.S. materials will be displayed there, and a review of the materials will be conducted by the Drafting Supervisor with each department employee. 2. Treatment Protocols for Ammonia Exposures and Safety and Health Protection publications were distributed to each employee, and also posted on the east wall of the duplication facility. 3. A lock-out hasp was welded to the main doors of the exterior ammonia storage bunker. A 5-pin alloy grade padlock was attached to the doors which should eliminate any chance of unauthorized entry. 4. Hazard identification signs conforming to UFC standard 79-3 were'prepared and posted at the north, south and west entrances of the Drafting Department, as well as the entrance to the duplication area. Also, a weather- proof sign was attached to the doors of the exterior ammonia storage bunker. Ms. Barbara Brenner October 18, 1990 Page 2 5. The paper recycling bins were moved out of the ammonia storage bunker and placed in the adjacent recyclables corral. Recyclers will be advised of same. 6. The action in item 5 resolves the training issue. Sincerely, Dennis D. Conley Regional Safety Manager DDC/mi cc: Brian W. G. Marcotte Casey K. Davis CITY of BAKERSFIELD "WE C,4 RE" 2101 H STREET FIRE DEPARTMENT BAKERSFIELD. 93301 D.S. NEEDHAM 326-3911 FIRE CHIEF SepLembe~ 26, ~990 Mr. Dennis Conley Regional Safety Manager UNOCAL North American Oil and Gas Division 1800 30th Street, Suite ZOO Bakersfield, CA 93301-19Zl Dear Mr. Conley, The inspection conducted on September Z6, 1990 confirmed that most Of the changes and mitigation~proposed by UNOCAL in the Risk· Management and Prevention Plan ~of February 1990 are in place or in the final planning stages. The following items are the only remaining areas of [' concern regarding full implementation of the RMPP and compliance with ! the 1988 Uniform Fire Code and the Health and.,Safety Code. ~1. All employees working in the'reprographics,area must be made aware of the location of the ammonia MSDS sheets So that they can readily access the information if it is needed. [ UFC 80.104(d)] 2. The.'publications "safety and Health Protection on the Job" and "Treatment Protocols':for Ammonia Exposure" .need to be posted in the' drafting department. (RMPP pg.4) 3. The exterior ammonia storage area must be secured against unauthorized entry. [UFC 80.303(c)2]. 4. Visible hazard identification signs,'as specified in U.F.C. Standard 79-3, must be placed at entrances to locations where hazardous materials are stored or used. Standard 79-3 is attached. [UFC 80.104(e)] 5. If fork lifts 'or Other vehicles are used to move the recyclable paper dumpsters, guard posts or other physical barriers must be provided to protect the ammonia cylinders from vehicular damage..DumpsterS which Will be lifted should not be located against the wall along which the ammonia line'runs. [80.301(u)] Page 6. Training must be provided regarding the hazards of anhydrous ammonia and the proper handling of cylinders for those employees who work in the ammonia storage area handling the recyclables. [Section 25504, CA Health and Safety Code] The items related to the RMPP must be in place by'February 1991. PlEase submit'a written summary of the actions planned tQ address all the items related to the Health and Safety Code and the Uniform Fire Code by October 26, 1990. Please call me at 326-3979 if you have any questions. Thank you for all of your cooperation. Sincerely, Barbara Brenner Hazardous Materials Planning Technician UNOCAL - 1800 30th Street, Suite RMPP INSPE(]TION CHECKLIST (RMPP ~ubmit~d 2-~0) September 28~ ~0 SYSTEM DESIGN: 1, F~mmonia bottles should be located at the side of the building in a 7 blo_.k enclosure, &O from .%hp bu.i, ldtr)g. _ . _ 2%ct Bottle~ are to be chai~]ed %o the wall ~i{h 2 - 1/2" ,.~~~ 2, (Pg. 2~ exhibit 5) :s o 5. 5n emergency shutoff valve should~ loc~%ad a% the be=inning 4. ~mmonia iS to be piped %o the building via a 1/2" braided stainless steel hose which connects ~o ~/4" bi, ack iron pipe, The iron pipe runs up ~building column to the attic of the third floor. (Pg. 5. ts ~he system operating at normal pressure ? Interior manifold pressure should be 25 psi or less, (exhibit 3) S, Have there been any neleases ? (Pg, 3) TRSINZN6: 7, 6ne tine publications, "Saee~y and Health Protection on Job" and" T~ea%ment P¢otocol. s for 6mmon.ta Exposune", pos%ed in the drafting department ? (Pg, 4)~ .~-~ ~ ~ 8. Is MSDS readily available ? (UFC 8rticle 80) · ~. Is documentation o¢ training being kept per exhibit Training is to be conducted annually in January 8tqd 8~ the time a new employee is hired. (Pg. 5)~ ~ ,~Onn~n ,Xh~a~'~-- ~. Is evacuation ~mairling being included in %he employee %maiming ? Where is %he evacuation amea located ? Which employees pam%icipate J.n %he evacua%J, or~ %raining ? (Pg. 5)