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HomeMy WebLinkAboutRISK MANAGEMENT FILE 10/26/1992Ad ~ ~6557 Ad type V Bas,et CENSOR Enteped By IOJANELL On 10/26/9~ at 11:55 ~op IOJA~ELL Account 3~63911BAN Class 397 Na~e HAZARD MATER. BAN. FIRE DEPTo Phone Addp 2130 G ST GB/PO LEGAL 20 Billing lines 1o~1 Inches Total. ~18o00 Adcost 18.00 LNe OUtFiT 7 CA. The RMPP gpa~s and ppeven% a hazardous =atepial ac- Divisio~ ~30 G S%.~ Bakepsfie~d~ R~PP. Octobep ~8, ~992 ¢6557) Enter'ed By IOCHARLETTE On 3/~/93 a~ 1~:~ Foe EO~ARLETTE ~ PU~ I C ~OT ] CE , 4' tion P~o~a~,, ¢R~~) ha~ bee~ . " ~5 G St. Ba~e~'sfield~ CA 9~30~. Con- CONFIDENTIAL Gist-brocades Food Ingredients Inc. M^N^G~M~NT AND (~~) DESCRIPTION AND RESULTS OF THE HAZARD AND OPERABILITY STUDY FOR ANHYDROUS AMMONIA CONFIDENTIAL Gist-brocades Food Ingredients Inc. RISK MANAGEMENT AND PREVENTION PROGRAM (RMPP) DESCRIPTION AND RESULTS OF THE HAZARD AND OPERABILITY STUDY FOR ANHYDROUS AMMONIA Prepared By Luft Environmental Consulting 3701 Pegasus Drive, Suite 121 Bakersfield, CA 93308 October, 1991 CONFIDENTIAL DESCRIPTION AND RESULTS OF THE HAZARD AND OPERABILITY STUDY PREFACE Gist-brocades Food Ingredients Inc.'s Bakersfield plant produces baker's yeast under the label of Eagle Baker's Yeast. The yeast is grown in batch fermentation tanks which are fertilized with phosphoric acid, sulfuric acid and ammonium hydroxide. In order to maintain the optimum growth temperature for the yeast, the fermentation tanks are .cooled with water from the cooling tower system. Chlorine, which is an acutely hazardous is utilized biocide in their The material, as a cooling towers. storage capacity of the chlorination system is greater than the levels specified in Section 25536 (a), California Health and Safety Code (H & S Code). Pursuant to Article 2, Chapter 6.95, Division 20, H & S Code, a Risk Management and Prevention Program (RMPP) for the chlorine system was prepared at the request of the Bakersfield City Fire Department. This RMPP was certified as complete on October 19, 1989. In November of 1991, Gist-brocades Food Ingredients Inc. will be adding an ammonia conversion system to the facility. This conversion system is based on anhydrous ammonia, which is also a listed acutely hazardous material. An addendum to the original RMPP was prepared to address the administrative and operational programs which are designed to prevent acutely hazardous materials accident risks associated with the anhydrous ammonia storage system. As a requirement of the RMPP, a Hazard and Operability Study (HazOp) for the ammonia conversion system was conducted. The HazOp study is the subject of this document. A summary of the HazOp is provided in the RMPP Supporting Document. I Gist-brocades/HazOp/Oct., 1991 Page I Luft Environmental Consulting ! I CONFIDENTIAL DESCRIPTION AND RESULTS OF THE HAZARD AND OPERABILITY STUDY The RMPP must, according to Section 25534 (d)(1) of the California Health and Safety Code (H & S Code), include the "results of a hazard and operability study which identifies the hazards associated with the handling of an acutely hazardous material due to operating error, equipment failure, and external events, which may present an acutely hazardous materials accident risk". A. HAZOP TECHNIQUE The HazOp technique that was used for the Gist-brocades Food Ingredients Inc. facility was a modified "guide word" approach for a Hazard and Operability Study. The basic guide word HazOp was chosen since it allows a systematic and thorough review of every part of the facility that handles AHMs. However, due to simplicity the ammonia conversion system, a "what analysis was the of if" incorporated into the guide word approach. Both of these approaches are described in the AlChE Guidelines for Hazard Evaluation Procedures1, which is referenced in Section 25534 (I), Chapter 6.95, Division 20, H & S Code. Other publications further describe the guide word approach, including A Guide to Hazard And Operabifity Studies2. B. PROCESS AND EQUIPMENT DESCRIPTION Gist-brocades Food Ingredients Inc. is currently purchasing ammonium hydroxide at a concentration of approximately 25 percent ammonia. The anhydrous ammonia storage tank and ammonia conversion system are being installed to provide an economical method of making ammonium hydroxide (aqua ammonia) on site. Anhydrous ammonia will be stored on site in a 15,325 gallon (water capacity) pressure vessel. Actual maximum storage capacity for anhydrous ammonia is 13,256 gallons, which is 86.5 percent of the tank capacity. 1 Guidelines for Hazard Evaluation Procedures, American Institute of Chemical Engineers, New York, 1985. 2A Guide to Hazard and Operability Studies, Chemical Industry Safety and Health Council of the Chemical Industries Association, London, 1985.~.1Li ~lD~ i'~,P,~u::::)~,~-~-~;~ _ ~ ~) ~1~ Gist-brocades/HazOp/Oct., 1991 ~'~ Page 2 Luft Environmental Consulting CONFIDENTIAL Ammonium hydroxide will be produced by mixing approximately 7 gallons per minute (gpm) of liquid anhydrous ammonia and approximately 15 gpm of water in the ammonia conversion system. Anhydrous ammonia is fed from the storage vessel to the ammonia conversion system via a one inch welded stainless steel pipeline, Water supply for the conversion system comes from the existing water softening system located at the plant. The ammonia conversion system consists of a reaction chamber and a heat exchanger. Inside the reaction chamber, the anhydrous ammonia is added to water through a jet type mixer to make ammonium hydroxide. Since this reaction is exothermic, the ammonium hydroxide will be cooled in a shell and tube heat exchanger using cooling water from the existing cooling tower. After cooling, the ammonium hydroxide will flow into an existing 20,000 gallon ammonium hydroxide storage tank. The existing ammonium hydroxide distribution system will be utilized to fertilize the fermentation tanks. Liquid ammonia flow to the conversion system will be controlled by a pneumatic control valve. This pneumatic control valve closes upon loss of air pressure. The air to this control valve will be fail closed electric solenoid supply governed by a valve. Anhydrous ammonia flow into the reaction chamber will be approximately 7 gpm. The ammonia flow will be controlled by two devices; a pressure regulator and a fixed orifice plate. Soft water flow to the reaction chamber will be regulated by a programmable logic controller (PLC) which will modulate a flow control valve. During processing, the PLC will monitor the ammonium hydroxide reaction temperature and the position of the flow control valve. If the ammonium hydroxide temperature leaving the reaction chamber is too high, the PLC will open the soft water control valve. Opening -the soft water valve reduces the ammonium hydroxide strength and lowers the heat of reaction in the chamber. Conversely, reducing the flow of soft water into the .reaction chamber increases the ammonium hydroxide concentration and the reaction temperature. Therefore, the PLC can maintain the proper concentration of ammonium hydroxide by maintaining the appropriate reaction temperature. A schematic overview of the system is shown in Figure 1. I Gist-brocades/HazOp/Oct., 1991 Page 3 Luft Environmental Consulting ! CONFIDENTIAL HAZOP REVIEW FOR GIST-BROCADES FOOD INGREDIENTS INC. A review of the ammonia conversion system was used to generate the following subsystems that were investigated. Item #1' Fill Connections for the Anhydrous Ammonia Storage Tank Item #2: Ammonia Tank Anhydrous Storage Item #3: Liquid Anhydrous Ammonia Line Item #4: Reaction Chamber A modified guide word approach was used to systematically identify the intended design and operation of the item in the system. Deviations from the intended operation and the potential for an anhydrous ammonia release from each piece of equipment were discussed on a "what if" basis. RESULTS OF HAZOP In order to meet the requirements of the statute, a HazOp study was conducted to identify the hazards associated with the handling of an acutely hazardous material. The potential hazardous events determined by the HazOp review are described briefly below. These events could be caused by operating error, equipment failure or external events (including earthquakes). From these events, the worst credible ammonia release was generated for input into the atmospheric dispersion model and 'offsite consequence analysis. Discussion of the offsite consequence analysis, based on the results of the worst case release events, is provided a separate in document. 1. Uncontrolled Tank Filling There are two methods of dispensing liquid ammonia from the delivery truck to the storage tank. In the first method, the vendor truck is equipped with an ammonia compressor which takes ammonia vapor from the client tank, compresses it, and pressurizes the vendor tanker with the compressed vapor. This pressure differential between the vendor tanker and the client's storage vessel enables the vendor to discharge the ammonia at a high flow rate. The normal flow rate for the ammonia vendor using this delivery method is about 90 gallons per minute (gpm). This is the delivery system that Gist-brocades Food Ingredients Inc. is currently planning to use. I Gist-brocades/HazOp/Oct., 1991 Page 4 Luft Environmental Consulting I CONFIDENTIAL The second method of transferring liquid ammonia to the storage tank is by a ammonia the ammonia tanker. The rate for liquid pump on typical delivery this type of system is approximately 75 gpm. In both delivery systems, the vendor's tanker is equipped with excess flow valves that will shut off immediately if normal delivery rates are exceeded. These valves are designed to automatically operate in the event of a hose or pipe fitting failure downstream of the excess flow valve. Figure 2 is a schematic drawing of an excess flow valve. An excess flow valve is a normally open valve which allows fluid flow in both directions. The valve is held open by the force of the valve spring shown in Figure 2. Although fluid can flow in both directions, the valve will operate and shut off flow in only one direction. Fluid will pass through the excess flow valve (in the direction of the flow arrow) at any rate of flow up to and including the specified maximum flow rate of the valve. As the flow through the valve increases, the fluid drag on the valve head increases until the specified maximum flow rate is reached. If the specified maximum flow rate is exceeded, the fluid drag on the valve head will exceed the force of the spring and the valve head will close against the valve seat shutting off the flow. ! Seat I Direction of Flow Figure 2 Excess Flow Valve Once the excess flow valve operates, the upstream pressure from the tank will keep the valve closed until the pressure across the valve head can be equalized. Since the excess flow valve is designed with a very small orifice in the valve head, the pressure across the valve head will equalize when the I Gist-brocades/HazOp/Oct., 1991 Page 5 Luft Environmental Consulting I CONFIDENTIAL downstream line failure is isolated. As the differential pressure across the valve head decreases, the closing force on the valve head drops. When the closing pressure drops below the valve spring pressure, the excess flow valve will open. There are three excess flow valves in the anhydrous ammonia storage system. Two of these excess flow valves are in liquid service and one is in vapor service. A three inch excess flow valve set at 225 gallons per_..~_j.~te (gpm~ is t. hr.e. aded directly into the ammonia sto_0~a_~--~_~ank. -'~his valve p-~vents the uncontroll--iF&'d-~J-~ase' of"the Contents of the ammonia storage tank in the event of a catastrophic liquid line rupture downstream of the excess flow valve. The second liquid line excess flow valve is a one inch valve, set at 24 gpm, installed in the liquid ammonia pipeline that supplies the ammonia conversion system. This valve was installed to prevent an uncontrolled release from the ammonia supply line and ammonia conversion system in the event of a catastrophic failure in the pipeline or reaction chamber. A schematic diagram of the excess flow valve arrangement is shown in Figure 3~ Vapor Return Line Excess Flow Valve- 2 inch ~ Liquid Ammonia Line [~ ~ Excess Flow Valve - 3 inch Liquid Ammonia Line ~' To Ammonia Excess Flow Valve- 1 inch Conversion System Figure 3. Arrangement of excess flow valves I Gist-brocades/HazOp/Oct., 1991 Page 6 Luft Environmental Consulting I CONFIDENTIAL The excess flow valve that is installed in the ammonia vapor return line is set at 95 gpm. This flow rate is equivalent to approximately 119 cubic feet per minute (at 70°F) or 54 pounds of ammonia per minute. A release during the tank filling operation could occur if the tank operator could not shut the delivery system down for any reason, and the ammonia delivery tanker had sufficient product to overfill the storage tank. This event could happen if the ammonia delivery truck operator becomes incapacitated for any reason, such as suffering a hea~mg the ammonia delivery. .............. When the storage tank completely hlls, the hqu~d ammonia w~ll flow ~nto the storage tank vapor return line and attempt to flow to the tanker. However~-'~ .~'he excess flow valve on the vapor return line is set at 95 gpm of Ii(laid / ammoma. Since the discharge rate from the ammonia tanker is typic~ around 90 gpm, the excess flow valve on the vapor return line could clos~ ~---i~med~ately and stop the flow out of the storage tank. If the ammonia is delivered via liquid pump, an immediate release would not occur since the typical delivery pump does not generate sufficient pressure to operate the pressure relief valve on the storage tank. When the vapor line excess flow valve operates, the liquid ammonia pump would bypass the flow back to the tanker. A release may occur a little later due to the thermal expansion of the liquid ammonia forcing the storage tank pressure relief valve to operate. The release rate due to thermal expansion of the liquid ammonia would be less than the release rate of hose failure event discussed in #3 below. If the ammonia is delivered utilizing an ammonia compressor on the tanker, the possibility of an immediate release exists. The compressor on the ammonia tanker can generate enough pressure to lift the pressure relief valves on the storage tank if the vapor return line excess flow valve closed due to an ovedill situation. Under these circumstances, a release equivalent to the delivery rate of the ammonia tanker, approximately 90 gallons per minute (7.6 pounds per second) could develop. However, since the tankers carry approximately 7,900 gallons of ammonia and the system capacity is 13,256 gallons, it would be impossible to overfill Gist-brocades/HazOp/Oct., 1991 Page 7 Luft Environmental Consulting CONFIDENTIAL the tank if the order is placed when the ammonia storage capacity is below 5000 gallons. _In order to ensure that this type of release does not occur, ammonia will only be ordered when the tank contains less than 4000 gallons. Storage Tank Line Failure As discussed previously, the anhydrous ammonia storage tank is equipped with three excess flow valves as shown in Figure 3. There is a three inch ~ess_fLow v_alve s.et at 225~gp~located whe_rre the liq_uid line is threaded into_.._~the storage t_..ank. This valve prevents an uncontrolled release through the liquid ammonia delivery line. Additionally, there is a check valve installed in liquid ammonia delivery line to prevent the reverse flow of ammonia during a delivery. Since this check valve is installed in the short section of piping between the delivery bulkhead and the excess flow valve, the likelihood of a significant release from the 2 inch liquid line is very Iow. A one inch excess flow valve, set at 24 gpm, is installed at the beginning of~ the one inch liquid ammonia supply line that feeds the conversion system.~ The maximum release from a rupture of this one inch liquid ammonia line would be limited to the excess flow valve rating. '[. The third excess flow valve in the ammonia conversion system is installed where the vapor return line connects to the anhydrous ammonia storage tank. The excess flow valve is set for 95 gpm. This flow rate is equivalent to approximately 119 cubic feet per minute (at 70°F) or about 51 pounds of ammonia per minute. All of the above release events are below the hose failure event discussed in event #3 below. I 3. Hose Failure With the mitigation measures taken into account in event #1 and event #2 above,~h~-worst cred~ld involy_e_a_failure in the tw...o ig~h ammonia Ioadin. g ho. Ac. Two types of hose failures were investigated; a complete failure of a hose and a partial failure of a hose. I Gist-brocades/HazOp/Oct., 1991 Page 8 Luft Environmental Consulting I CONFIDENTIAL If the hose completely failed, the excess flow valve on the delivery truck would close immediately. It was assumed that the excess flow valve would operate properly. In this release event, only the contents of the loading hose would be released. A worst case release event would be that of partial failure of the hose. In this case, a failure of the hose near the fitting was reviewed. The failure was assumed to occur near the hose end fitting where the pressure stresses are compounded by the mechanical connection stresses. For a worst case release event, the resultant flow through the excess flow valve on the delivery truck would be just below the operating set point of the valve. Since the excess flow valve settings vary slightly between ammonia delivery companies, it was assumed that the operating set point was equivalent to the excess flow valve on the storage tank. It should be noted that the anhydrous ammonia storage tank at Gist-brocades was previously a cargo carrier and was built to United States Department of Transportation specification MC 331. For the ammonia release calculations, a worst case release rate of 200 gpm was assumed. This rate is approximately 90 percent of the excess flow valve setting. If the liquid ammonia delivery pressure is approximately 145 psig (30 psig greater than normal storage pressure), about 20.7 percent of the liquid ammonia would flash to the vapor phase as soon as it was release to the atmosphere. Therefore, the worst credible release was calculated as 3.44 pounds per second of vapor and 13.16 pounds per second of liquid ammonia. Since the ammonia delivery trucks are equipped with manually-operated emergency shut down valves, two versions of this release event were reviewed. In the first case, the ammonia truck operator or a plant operator would respond to the release and operate the emergency shut down valve. Response to the hose failure and shut d0w_n of the~.~ery, ssy~m by one of these operators was assumed to occur ~w~tO-s-~conds. -'~__.._.._ The net release from this 10 second release event would be 34.4 pounds (3.44 pounds per second for 10 seconds) of vapor ammonia and 131.6 I Gist-brocades/HazOp/Oct., 1991 Page 9 Luft Environmental Consulting I CONFIDENTIAL pounds (13.16 pounds per second for 10 seconds) of liquid ammonia. The I 34.4 pounds of ammonia vapor represents an instantaneous release to the atmosphere while the 131.6 pounds of liquid ammonia must evaporate over I a pedod of time. In the second case, it was assumed that the truck driver and/or operator could be ammonia and not be able to respond to overcome by vapors may the ammonia release. This case would result in a "continuous" release of i 16.6 pounds per second of ammonia. Gist~brocades Food Ingredients Inc has several Self Contained Breathing Apparatus (SCBA) on site for_ emergency response. As such, plant personnel would be able to don the I SCBAs and operate the emergency shut down valve within a~few minuteS~_ Therefore, a continuous release of 16.6 pounds per second was modeled as a wo~_~~~nt. I 4. Fitting Leak I The available leak flow area for all valves and threaded fittings on the ammonia system would be less than the area of the modeled hose failure. i Although a valve packing is one of the most likely release events, the smaller flow area would result in a release well below the hose failure event. I Gist-brocades/HazOp/Oct., 1991 Page 10 Luft Environmental Consulting I I I I I I I I I I I I I I I I I I I APPENDIX A HAZARD AND OPERABILITY STUDY MATRIX . GIST-BROCADES FOOD INGREDIENTS, INC.-HAZOP REVIEW SUMMARY 1 _Fill /' No ...r~O Flow Fill valve closed or blocked Will relieve thru truck Vendor trucks are equipped with recirculation Co nnectionsI~_~ systems to prevent overpressuring piping. PSV on NH3 receiver is set @ 265 psig. Delivery hoses are tested once per year at twice the receiver pressure or at least 500 psig. SG**-Relief system on vendors truck SG-Operator training **SG=Safeguard System isolated with liquid ammonia Thermal expansion of ammonia fails pipelin SG-Operator training trapped in pipeline due to hydraulic pressure SG-Thermal relief valves install in pipelines wherever liquid ammonia could be trapped. SG-SCBA on site for emergency response ~More More Flow Safety valve fails Maximum flow through PSV Very rare incident Hose failure, truck pulls away Release contents of hose. Back check SG-Back check valve installed in liquid ammonia without disconnecting valve prevents ammonia leak from receiver delivery line. SG-Truck is equipped with excess flow valve. SG-Back check valve installed on fill hose SG-SCBA on site for emergency response SG-Gist-brocades personnel witness loading SG-Installation is fenced and locked. Gist personnel have key, not ammonia vendor. SG-Operator Training Delivery truck hits delivery valves Release through fill lines SG-vehicle barriers installed around tank and piping Operator opens open-ended Max release thru orifice SG-AII open ended valves are plugged or capped valve SG-Operator Training Less Less Flow Partially plugged or blocked line Slow product transfer. Worst case, delivery No public consequence system relieves back to truck. SG-Opsrator Training SG-Delivery truck relief system Reverse Reverse Flow Delivery pump fails Flow could be back to delivery truck No public consequence SG-Back check valve installed on liqiud ammonia delivery pipeline. Page 1 '1 I I I I I I ! ! ! I ! ! 1 ! I GIST-BROCADES FOOD INGREDIENTS, INC.-HAZOP REVIEW SUMMARY 1 Fill More More Pressure Vendor tanker overfills storage tank '.Worst case, PSV may lift.' SG-Gist-brocades staff always witnesses ammonia Connections loading. (Cont.) SG-Gist-bmcades has established maximum order point for ammonia storage tank to prevent ordering more than tank can hold. SG-Differential pressure gauge installed to determine level of NH3 in storage tank SG-PSV relieves to prevent damage to equipment SG-Ope rator Training Less Less pressure Vendor truck pump failure - No product transfer No public consequence insufficient pressure 2 Storage Tank No No Flow System idle System idle No public consequence More More Flow Relief valve fails-lifts Maximum flow through PSV Very rare incident Opening of open ended valves Max release through piping SG-AII open ended valves are plugged SG-Excess flow valves installed on all tank lines SG-Operator Training _ __-~7 Gauge failure Discharge until system can be isolated SG-Pressure gauges have isolation valves -~ SG-SCBA on site for emergency response SG-Operator Training SG-Minimum orifice on fitting reduce flow Less Less flow Liquid line plugged or blocked Less ammonium hydroxide production. SG-Flow switch on liquid ammonia line. Soft water valve will close to maintain SG-Low ammonium hydroxide reaction temperature reaction temperature. System may shut will shut system down down on Iow reaction temperature More More Pressure Overfilling Worst case, PSV maY lift. SG-Gist-brocades staff always witnesses ammonia loading. SG-Gist-brocades has established maximum order point for ammonia storage tank to prevent ordering more than tank can hold. SG-Differential pressure gauge installed to determine level of NH3 in storage tank SG-PSV relieves to prevent damage to equipment SG-Operator Training Page 2 GIST-BROCADES FOOD INGREDIENTS, INC.-HAZOP REVIEW SUMMARY 2 Storage Tank More More Pressure Fire nearby Radiant heat may cause tank pressure to SG-There is very little combustible material near the (Cont.) rise anhydrous ammonia storage tank SG-Fire Hydrants located in several areas near the storage tank SG-Gist-brocades fire prevention program - Less Less Pressure Cold temperatures with very little During batch process, soft water may enter No public consequence. anhydrous ammonia in the tank anhydrous ammonia line SG-check valve in soft water line to prevent reverse flow. More More Temperature Extreme summer heat System Designed for high temperatures No public consequence. ~-~ SG-Tank is never filled more than 85 percent~ order to account for thermal exp~nsion.~~_~ SG-PSVs on storage tank J( -- Fire nearby Radiant heat may cause tank pressure to SG-There is very little combustible material r~e"a~r the rise anhydrous ammonia storage tank SG-Fire Hydrants located in several areas near the storage tank prevention program SG-Gist-brocades fire Less Less Temperature Cold temperatures with very little During batch process, soft water may enter No public consequence. anhydrous ammonia in the tank anhydrous ammonia line SG-check valve in soft water line to prevent reverse flow. Other Maintenance System repair or cleaning System was designed with isolation valves SG-Operator Training to facilitate maintenance. SG-Isolation valves installed in system for maintenance. 3 Uq. Ammonia No No Flow Une blocked, or isolated If liquid NH3 line, pressure would increase SG-Operator Training line in line due to liquid expansion SG-Pipelines equipped with thermal relief valves SG-SCBA on site for emergency response More More Flow Leak in pipelines, valves Discharge until leak isolated SG-Pipelines pressure tested prior to start up. Low volume leaks, odor easily detected SG-SCBA on site for emergency response SG-Operator Training Page 3 GIST-BROCADES FOOD INGREDIENTS, INC.-HAZOP REVIEW SUMMARY 3 Liq. Ammonia More More Flow Pipe failure Ammonia release corresponding to SG-Pipelines pressure tested prior to start up. line (Cont.) size of opening SG-SCBA on site for emergency response Worst crediblb case, liquid phase release.~ SG-Operator Training ~,D~,~ ~ \JLC75 ~ ~-~LC.~ SG-Excess flow valves installed in all anhydrous ~,,0~ %,'~ ~;~:-' ammoniapipolinos. Less Less Flow Liquid line plugged or blocked Less ammonium hydroxide production. SG-Flow switch on liquid ammonia line. Soft water valve will close to maintain SG-Low ammonium hydroxide reaction temperature reaction temperature. System may shut will shut system down down on Iow reaction temperature More More Pressure Liquid line is isolated (blocked on If liquid NH3 line, pressure would increase SG-Operator Training both ends) with line full of liquid in line due to liquid expansion SG-Pipelines equipped with thermal relief valves ammonia SG-SCBA on site for emergency response NOTE: THE AMMONIA CONVERSION SYSTEM DOES NOT HANDLE ACUTELY HAZARDOUS MATERIALS AFTER THE REACTION CHAMBER. HOWEVER, THE BALANCE OF THE CONVERSION SYTEM WAS REVIEWED DURING THE HAZOP STUDY, 4 Reactor More More Flow Water Control valve opens too much Dilute ammonium hydroxide solution No public consequences Chamber SG-Reactor temperature monitored by PLC SG-Shut down sequence for Iow reactor temperature Less Less Flow Water control valve doses too much Strong ammonium hydroxide solution No public consequences SG-Reactor temperature monitored by PLC SG-Shut down sequence for high reactor temperature Reverse Reverse Flow Too Iow pressure on water line Ammonium hydroxide formed in water SG-Water line is equipped with check valve and pipeline, fail closed control valve SG-Ammonia line is equipped with pressure regulator More More Pressure Discharge valve closed or line blockec Pressure increases until reaction stops No public consequence. SG-PSV on reactor vessel Less Less Pressure Insufficient water supply pressure May not flow sufficiently to satisfy water No public consequences flow permissive. No product made. SG-Water flow permissive SG-Reactor temperature monitored by PLC SG-Shut down sequence for high reactor temperature Insufficient ammonia supply pressure Weak or no ammonium hydroxide solution No public consequences SG-Reactor temperature monitored by PLC SG-Shut down sequence for Iow reactor temperature Page 4 GIST-BROCADES FOOD INGREDIENTS, INC.-HAZOP REVIEW SUMMARY 4 Reactor More More Temperature Insufficient soft water supply Strong ammonium hydroxide solution No public consequences Chamber May not flow sufficiently to satisfy water SG-Reactor temperature monitored by PLC (Cont.) flow permissive. SG-Shut down sequence for high reactor temperature Less Less Temperature Too much Water, or too little ammonia Weak or no ammonium hydroxide solution No public consequences SG-Reactor temperature monitored by PLC SG-Shut down sequence for Iow reactor temperature 5 Shell and More More Flow Cooling water control valve opened Ammonium hydroxide cooled to much No public consequences tube heat (Cooling Water) too far SG-Local temperature gauges exchanger SG-Operator Training Tube failure in heat exchanger Ammonium hydroxide diluted No public consequences SG-Testing of ammonium hydroxide with hydrometer SG-Operator Training Less Less Flow Cooling water control valve closed Ammonium hydroxide not cooled. Possible No public consequences too far physical hazard to operator from hot tank. SG-Local temperature gauges SG-Operator Training 6 Ammonium More More Level Conversion process not terminated Overflow ammonium hydroxide tank SG-Differential pressure level transmitter hydroxide SG-Local sight glass tank SG-Operator training Page 5 I I ! I I I I I I I I I I I I I I I CONFIDENTIAL Gist-brocades Food Ingredients, Inc. Bakersfield, California OFFSITE CONSEQUENCE ANALYSIS for Anhydrous Ammonia October 1991 Prepared by Luff Environmental Consulting 3701 Pegasus Drive, Suite 121 Bakersfield, CA 93308 CONFIDENTIAL OFFSlTE CONSEQUENCE ANALYSIS Section 25534 (d)(2), Division 20, California Health and Safety Code states that "[t]he RMPP shall consider... [flor the hazards identified in the hazard and operability studies, an offsite consequence analysis which, for the most likely hazards, assumes pessimistic air dispersion and other adverse environmental conditions." Additionally, added to the effective Section 25534.1 that as statute, January 1, 1990, requires "[e]very RMPP... shall give consideration to the proximity of the facility to schools, residential areas, general acute care hospitals, long-term health care facilities, and child day care facilities." This document addresses these requirements. For the release cases identified in the HazOp study, an air dispersion model was performed for the HazOp release events utilizing adverse (pessimistic) and average meteorological conditions. Both sets of meteorological data were used to provide a basis for evaluating the offsite consequences of the release events. The air dispersion model and its results are discussed in this document. A. GENERAL MODEL INFORMATION The pollutant dispersion results were generated by the CAMEO~3.0-ALOHA 5.0 model developed by the Hazardous Materials Response Branch of the National Oceanic and Atmospheric Administration (NOAA). CAMEOTM is the Computer- Aided Management of Emergency Operations program which was designed to help emergency planners and first responders both plan for, and safely handle, chemical accidents. ALOHA stands for Areal Locations Of Hazardous Atmospheres and serves as a tool for estimating the movement and dispersion of an atmospheric pollutant. NOAA recently updated ALOHA to include both a Gaussian dispersion model and a heavy gas model. Tho Gaussian dispersion model plots the distribution of a pollutant gas from a series of Gaussian equations as described by Turner in the "Workbook of Atmospheric Dispersion Estimates"1. The Gaussian equation describes a bell- shaped or normal curve. Concentration distribution at ground level is calculated and the bell-shape spreads out and gets wider and flatter as the pollutant drifts downwind. 1Turner, D. Bruce, 1974. Workbook of Atmospheric Dispersion Estimates. National Technical Information Service, Springfield, Virginia. Gist-brocades/Offsite Consequence/October, 1991 Page 1 Luft Environmental Consulting I I CONFIDENTIAL I The heavy gas dispersion model uses calculations found in the widely accepted DEGADISa model. The model has been simplified to provide quicker results I during emergency use, but is still accurate to within ten percent of the original DEGADIS model. I In both models, the pollutant concentration to be calculated is set to a particular numerical value such as parts per million (ppm), or can be the value of a I toxicological parameter such as those set in the Emergency Response Planning Guidelines issued by the American Industrial Hygiene Association3. I The models will give results using either an instantaneous source release, when the release of the pollutant occurs during one short time period; or a continuous I source release, when the pollutant is being released over a longer period of time. Both releases result in a concentration curve termed a footprint (see Figure 1). The area inside the curve is the region that is predicted to have ground level I concentrations above the limit set by the modeler. I Pollutant Source ! FIGUFI£ 1 - Footpdnt from a Gontinuous or Instantaneous Source Spill ! i The ALOHA model incorporates several assumptions regarding chemical source, meteorological data and terrain. In the heavy gas model, the chemical spill is assumed to have occurred at ground level. The Gaussian model has the option I of using elevated sources. For both models, all concentrations are calculated at ground level. I 2Spicer, Tom and Jerry Havens, 1989. Users Guide for the DEGADIS 2.1 Dense Gas Dispersion Model, EPA-450/4-89-019. U.S. EPA, Cincinnati, Ohio. I 3American Industrial Hygiene Association, October, 1988: Emergency Response Planning Guidelines. AIHA ERPG Committee, 475 Wolf Ledges Parkway, Akron, OH 44311. Gist-brocades/Offsite Consequence/October, 1991 Page 2 Luft Environmental Consulting ! CONFIDENTIAL Meteorological data includes atmospheric stability, wind speed and wind direction. Atmospheric stability classes are measured from A to F with class A being the most unstable and class F the most stable. Unstable conditions result in a large amount of mixing of the atmosphere, causing the pollutant chemical to produce a shorter threat distance but a wider plume. However, this condition also includes more variable wind directions, resulting in a threat zone that may tend to meander. Stable conditions give opposite results. The stability can be influenced by both heating and mechanical stirring of the atmosphere. Heating of the surface layer of the atmosphere leads to unstable conditions and ground cooling results in more stable conditions. Mechanical stirring is caused by the winds, with strong winds tending to cause neutral stability (classes C and D). Wind speed and wind direction are input directly by the modeler; although the air model checks that wind speeds are consistent with the stability class chosen. If the wind speed and stability class are inconsistent, no plume dispersion is calculated. The turbulence caused as the wind flows over and around obstacles is included in the model and termed ground roughness. The model adjusts for mixing consistent with stability class by allowing for either rural ground roughness, a terrain with few obstacles, or an urban ground roughness, characterized by many obstacles. The effects of terrain the and direction of the not on speed plume are included in the model. The model assumes that the winds are uniform throughout the plume. I B. LIMITATIONS OF ALOHA DISPERSION MODEL i Even with all the above mentioned factors included in the plume concentration calculations, as with all dispersion models, the ALOHA model does have several limitations. It is important to remember that the model has a nominal accuracy of a factor of 2, so a predicted concentration of 50 ppm may actually be in the range of 25 to 100 ppm. This degree of accuracy is consistent with other dispersion models. The model also does not accurately represent several conditions which are discussed below. As mentioned earlier, the ALOHA model does not include terrain steering effects caused by topography or wind shifts and the model assumes that all winds are Gist-brocades/Offsite Consequence/October, 1991 Page 3 Luff Environmental Consulting ! CONFIDENTIAL I constant throughout the plume. Wind variation can reduce the accuracy of the results when the plume travels more than a mile from the source. The model will only calculate plume dispersion results at distances less than 6.4 miles (10 km). I Also, dispersion models are not accurate at Iow wind speeds (less than 1 mile per i hour) or at very stable atmospheric conditions, which produce these Iow wind speeds. ALOHA does not allow a wind speed of less than one meter per second (2.237 miles per hour). I Another situation not handled well by ALOHA (or air models in general) is concentration patchiness in the area 50 to 100 yards from the source. In this I vicinity, the pollutant may meander and be more patchy than the model can predict. After about 100 yards, a plume will have experienced enough mixing I eddies to reduce the irregular concentrations within the plume. At this point, the model will predict the pollutant concentrations within the accuracy of the model. ! C. MODEL PARAMETERS FOR GIST-BROCADES' I For the release cases identified in the HazOp study, an air dispersion model was used to evaluate the offsite consequences of the release events. The air I dispersion modeling was performed utilizing average both adverse and meteorological conditions. By applying both sets of data to the release events, i the modeling results provide qualitative information to help evaluate the offsite consequence associated with the worst credible release events. ~ I Anhydrous ammonia is a of three and one gas composed pads hydrogen part nitrogen (NH3). It has a molecular weight of 17.03 and is lighter than air. When i stored under sufficient pressure at ambient temperature, ammonia is liquefied. Ammonia exists in both liquid and vapor phases in the storage tank. Anhydrous ammonia is shipped as a nonflammable gas and is an irritant to the eyes, skin I and mucous membranes. Ammonia has a perceptible odor as Iow as 5 ppm and is readily detectable at 10 ppm. I A release of anhydrous ammonia vapors under pressure may result in the formation of an aerosol mist which behaves as a heavy gas (heavier than air). However, the ammonia behaves in a normal Gaussian distribution once the concentrations in air drop to about 10,000 ppm. For a small release, this will I Gist-brocades/Offsite Consequence/October, 1991 Page 4 Luft Environmental Consulting ! I I CONFIDENTIAL i occur within the first 50 yards from the source. Because of this dual behavior, both the heavy gas and Gaussian models were used to .predict plume dispersion. I If anhydrous ammonia is released as a liquid, a portion of the liquid will flash to the vapor phase immediately. The amoun~uid ammonia that will flash to the_ vapor phase is dependent on t~e Stor~ge pressure ~o t~e ;'elease. For each I release of liquid ammonia, the percentage of ammonia flashing to the vapor phase was calculated. The balance of the release would form a liquid pool that I would evaporate over a period of time depending on ambient conditions. The air dispersion model calculates the evaporation release rate based on the input meteorological parameters. Therefore, a release of liquid anhydrous ammonia I would generate two vapor dispersion models; one for the initial flash of the release and the second for the evaporation of the liquid pool. I Results were modeled for concentrations set at 50 ppm and 500 ppm as specified in the "Outline of RMPP Requirements", prepared by the Bakersfield City Fire I Department Hazardous Materials Division. The 50 ppm value is the EPA Level of/) Concern (LOC) concentration at which there should be no discomfort orl i impairment of health for a prolonged exposure of more than 30 minutes. An ambient concentration of ammonia of 500 ppm is considered as Immediately I Dangerous to Life or Health (IDLH). At 500 ppm, there is severe irritation of the eyes, nose and throat, but there are no lasting effects for a short exposure of less than 30 minutes. Since ammonia has a perceptible odor as Iow as 5 ppm, it is I unlikely that a person would become unknowingly overexposed.4 I The meteorological conditions used to determine maximum impact distances and times were based on data collected by the U.S. Weather Service at Meadow Fields Airport in Bakersfield, California. The data in Table 1 summarizes the I meteorological data for both average and adverse conditions. I On an annual basis, the predominant meteorological conditions are with a wind direction from the north-northwest at 6.4 miles per hour. A chemical release during these average atmospheric conditions represents the most likely offsite I consequence resulting from the release. For modeling purposes, however, winds from the south-southeast at 5.0 miles per hour were also considered because I 4American Industrial Hygiene Association, October, 1988: Emergency Response Planning Guidelines. AIHA ERPG Committee, 475 Wolf Ledges Parkway, Akron, OH 44311. I Gist-brocades/Offsite Consequence/October, 1991 Page 5 Luft Environmental Consulting ! TABLE 1 MEADOWS FIELD MET DATA MONTH WIND SPEED WIND DIRECTION (MPH) (FROM) JAN 5.20 NW FEB 5.80 ENE MAR 6.50 NW APR 7.10 NW MAY 7.90 NW JUN 7.90 NW JUL 7.20 NW AUG 6.80 NW SEP 6.20 WNW OCT 5.50 NW NOV 5.10 ENE DEC 5.00 ENE AVERAGE 6.40 NW ! CONFIDENTIAL they represent the worst case or "pessimistic" atmospheric conditions. Modeling Ireleases with these adverse weather conditions would present an of f site consequence that would potentially have the greatest affect on sensitive I populations. The Gist-brocades facility is located on District Blvd. in a commercial/light I industrial area. Pursuant to Section 25534, California Health and Safety Code, "[e]very RMPP... shall give consideration to the proximity of the facility to schools, i residential areas, general acute care hospitals, long-term health care facilities, and child day care facilities." Sensitive population sites considered in this offsite consequence analysis included residences, schools, emergency and health care I facilities. Figure 2 shows an overview of the sensitive population sites near the plant. The distances between the Gist-brocades facility and the sensitive i populations are summarized in Table 2. The nearest residences are approximately a third of a mile north and, also, a third of a mile to the southeast of the Gist-brocades facility. There is a hospital to the north of the Gist-brocades I facility, approximately a quarter of a mile away. The nearest school is roughly 1.07 miles to the northeast of the plant. A Bakersfield City Fire Department station is located 2.13 miles northwest of the Gist-brocades facility. ! Most of the ALOHA limitations discussed previously have minimal effects on the I model results. The ALOHA limitation regarding terrain steedng effects and wind shifts caused by topography is not a problem in the area being modeled because the terrain is generally flat and unobstructed by large hills or valleys. The ground I roughness of the area is-determined to be~u~rban-')terrain.. The effects of concentration patchiness within the first 50 to 100 yards from the source will be I minimal because there are no resident populations within this pre-Gaussian area. .D. RESULTS OF THE ALOHA DISPERSION MODELING ! lhe HazOp study generated release events for the ammonia system based on i the design of the facility, potential operator error and external events, such as an earthquake. These release events were reviewed to determine whether there was a high likelihood of occurrence or a significant offsite consequence if the I release were to occur. The releases associated with likelihood of a high occurrence were very Iow release rates resulting in an insignificant offsite i consequence. . During theHazOp study one release event was identified as-having offsite~ Gist-brocades/Otfsite Consequence/October, 1991 Page 6 Luft Environmental Consulting ! ~IST-BROCADES FOO~_ INGREDIENTS, INC. . ~ MING AVE ° o ~] .~IST-BROCADES PLANT DISTRICT BLVD ~ =~ ~ACHECO ROg PANAMA LANE LEGEND ~ ~rh - School ~ - Nearest Residence I Inch -- 0.5 Miles '. I '. ' Railroad ~ - Hospital r~ - Fire station FIGURE 2 - Map shows the sensitive population sites near the Gist-Brocades plant. i I GIST-BROCADES/LEC/9-91 TABLE 2 GIST-BROCADES PLANT SENSITIVE POPULATION SITES DISTANCE CRITICAL SITE FROM PLANT WIND DIRECTION (Miles) (Wind From) Nearest Hospital 0.24 South Nearest Residence 0.34 South or Northwest Nearest School 1.07 Southwest Nearest Fire Station 2.13 Southeast m m CONFIDENTIAL m consequences that warranted air dispersion modeling. This release was due to the failure of the ammonia delivery hose during a delivery. Air dispersion modeling was performed for the delivery hose failure (for two different release m durations). The release associated with the delivery hose failure has the potential to occur on an infrequent basis when ammonia is delivered to the plant periodically to recharge the ammonia system. Only during ammonia delivery m could the delivery hose failure release event develop. m As mentioned earlier, a release of liquid anhydrous ammonia would result in a portion of the liquid flashing to the vapor phase immediately, depending on the storage pressure prior to the release. For the liquid ammonia release cases that m were modeled, the percentage of ammonia flashing to the vapor phase was calculated and modeled as a vapor release. The balance of the release would m form a liquid pool that would evaporate over a period of time depending on ambient conditions and the size of the pool. The air dispersion model calculates the evaporation release rate based on the input meteorological parameters and m the surface area of the pool. m in general, the larger the surface area of the spill the greater the evaporative release rate. This situation would generate a larger plume in the offsite consequence analysis, but the duration of exposure would be significantly m shorter, conversely, the smaller the sudace of the the smaller the area spill, dispersion plume and the longer the duration of exposure. [ne nose release the assumed ammonia surface are,:,I Iwas 150 square feet.due to the duration of the events. This surface area was( m ~ for both the 10 second and the 1 minute hose failure release events. m The results of the ALOHA plume dispersion modeling are summarized in Tables 3 and 4 and shown in Figures 3 through 10. Tables 3 and 4 give the total plume distance travelled for both the Gaussian and heavy gas models using average m and adverse meteorological conditions. Additionally, the duration of the evaporation release from the liquid pools is given for both sets of meteorological m conditions. The figures show the direction the plume would most likely travel when using the actual meteorological data from Table 1. m For the hose rupture release event of 10 seconds shown in Table 3 and Figures 3 through 6, the 500 ppm plume travels just over one hundred yards under adverse m Gist-brocades/Offsite Consequence/October, 1991 Page 7 Luft Environmental Consulting m TABLE 3 GIST-BROCADES FOOD INGREDIENTS, INC. PLUME DISPERSION RESULTS FOR AMMONIA DELIVERY HOSE RUPTURE VAPOR RELEASE OF 3.44 LBS/SEC AMMONIA-FOR 10 SECONDS LIQUID RELEASE OF 13.16 LBS/SEC OF AMMONIA-FOR 10 SECONDS ATMOSPHERIC MODELING CONDITIONS ATMOSPHERIC MODELING RESULTS CONDITION AVERAGE ADVERSE PLUME DISTANCE OF PLUME TRAVEL CONCENTRATIOI~ VAPOR RELEASE LIQUID RELEASE (PPM) GAUSSIAN HEAVY GAS GAUSSIAN TEMPERATURE 95°F 40°F MODEL MODEL MODEL AVERAGE HUMIDITY 25% 50% CONDITIONS 6 minute evaporation release CLOUD COVER 10% 70% 50 159 yards 316 yards 140 yards WIND SPEED 6.4 MPH 5.0 MPH 500 51 yards 70 yards 44 yards WIND DIRECTION NW ENE ADVERSE RELEASE DATE Summer Winter CONDITIONS 7 minute evaporation release RELEASE TIME 4:00 P.M. 8:00 P.M. 50 233 yards 470 yards 177 yards STABILITY CLASS B-Unstable C-Unstab/Neut 500 74 yards 112 yards 55 yards Gist-brocades Luff Environmental Consulting TABLE 4 GIST-BROCADES FOOD INGREDIENTS, INC. PLUME DISPERSION RESULTS FOR AMMONIA DELIVERY HOSE RUPTURE VAPOR RELEASE OF 3.44 LBS/SEC AMMONIA-FOR 1 MINUTE LIQUID RELEASE OF 13.16 LBS/SEC OF AMMONIA-FOR 1 MINUTE EVAPORATION POOL SURFACE AREA = 150 SQUARE FEET ATMOSPHERIC MODELING CONDITIONS ATMOSPHERIC MODELING RESULTS CONDITION AVERAGE ADVERSE PLUME DISTANCE OF PLUME TRAVEL CONCENTRATION VAPOR RELEASE LIQUID RELEASE (PPM) GAUSSIAN HEAVY GAS GAUSSIAN TEMPERATURE 95°F 40°F MODEL MODEL MODEL AVERAGE HUMIDITY 25% 50% CONDITIONS 36 minute evaporation release CLOUD COVER 10% 70% 50 375 yards 915 yards 130 yards WIND SPEED 6.4 MPH 5,0 MPH 500 124 yards 258 yards 41 yards WIND DIRECTION NW ENE ADVERSE RELEASE DATE Summer Winter CONDITIONS 42 minute evaporation release RELEASE TIME 4:00 P.M. 8:00 P.M, 50 576 yards 1236 yards 172 yards STABILITY CLASS B-Unstable C-Unstab/Neut 500 181 yards 287 yards 54 yards Gist-brocades Luft Environmental Consulting CONFIDENTIAL weather conditions and would not impact any sensitive population sites. The 50 travels few hundred under adverse weather conditions. ppm plume only a yards The majority of the offsite consequence is associated with the flashing vapor release, instead of the evaporation of the pool. It is unlikely that the 50 ppm plume would reach the nearest sensitive population site (Charter Hospital) because the wind generally blows away from this site. However, should the wind take the plume to the north, the duration of the sensitive population is exposure very short, lasting only 7 minutes under adverse meteorological conditions. The hose rupture case with a release duration of one minute is shown in Table 4 and Figures 7 through 10. There are no sensitive populations within the 500 ppm plume dispersion. The 50 ppm model run shows that the plume could travel up to 0.70 miles from the plant. Sensitive population exposure from the vapor release would only be for a few minutes. Local businesses within a few hundred yards of the facility could be exposed to the lower concentration plume (50 ppm) for up to 42 minutes. In all of the release events modeled above, the majority of the offsite consequence is associated with the flashing vapor release, instead of the evaporation of the pool: This means that the sensitive population exposures would be of minimal duration. The evaporative pool releases, although longer in duration, result in a lower release rate than the vapor release. As such, evaporative pool releases disperse much quicker and do not travel as far as the vapor releases. I Gist-brocades/Offsite Consequence/October, 1991 Page 8 Luff Environmental Consulting ! GIST-BI~ADES FOOD INGREDIEI~[~_L~._C.. DISPERSION OF AMMONIA RELEASE FROM DELIVERY HOSE FAILURE 3.44 lbs/sec VAPOR-13.16 lbs/sec LIQUID 10 SECOND RELEASE AVERAGE WEATHER CONDITIONS 50 PPM PLUME CONCENTRATION m~ MING AVE © '" ° '" ~ GIST BROCADES DISTRICT BLVD - .,~,~ PLANT % PACH~OO R03 PANAMA LANE LEGEND I N~ ~rh - School 1~ - Nearest Residence I Inch = 0.5 Miles ', ', ,, - Railroad ~ - Hospital ['~ - Fire Station m FIGURE 3 - Map shows the impact on the sensitive population sites from subject ammonia release case. Va_oor Source: 3.44 lbs/sec Ammonia-10 sec Average Weather Conditions Modelled m Liauid Source: 13.16 lbs/sec Ammonia-10 sec Stability_ Class: B Total Disoersion Distance for 50 ODm Plume: Wind S.oeed: 6.4 mph I Vaoor Release: 316 yards Wind Direction: From the Northwest Liauid Release: 140 yards (shaded plume) Tem_oerature: 95°F m LEC/GIST-B ROCADES/9-91 GIST-BI~CADES FOOD INGREDI~ INC DISPERSION OF AMMONIA RELEASE FROM DELIVERY HOSE FAILURE 3.44 lbs/sec VAPOR-13.16 lbs/sec LIQUID 10 SECOND RELEASE AVERAGE WEATHER CONDITIONS 500 PPM PLUME CONCENTRATION r~ MING AVE ° I~ .~GIST BROCADES DISTRICT BLVD ,~ PLANT ~:) Liquid.plume is too small to plot. ~ACHECO RD/ PANAMA LAN! I ~ LEGEND N ~rh - School l~ - Nearest Residence I I Inch = 0.5 Miles , , , - Railroad ['~ - Hospital ~ - Fire StaUon i FIGURE 4 - Map shows the impact on the sensitive population sites from subject ammonia release case. .V~~: 3.44 lbs/sec Ammonia-10 sec Average Weather Conditions Modelled I Lio. uid Source: 13.16 lbs/sec Ammonia-10 sec Stabili~ Clas~: B Total Disoersion DiStance for 500 oorq plume: Wind Soeed: 6.4 mph I Vaoor Beleas{t: 70 yards Wind Directigr~: From the Northwest Lio_uid Release: 44 yards (too small to plot) Tem.oerature: 95°F m LEC/GIST-BROCADES/9-91 I DISPERSION OF AMMONIA RELEASE FROM DELIVERY HOSE FAILURE 3.44 lbs/sec VAPOR-13.16 lbs/sec LIQUID m 10 SECOND RELEASE ADVERSE WEATHER CONDITIONS 50 PPM PLUME CONCENTRATION  MING AVE I ! ° miiiiii lllllll~lll I1'.'.'.1111111 '. '. '. I I I ~ PACHECO RO,a ! I PANAMA LANE m ~ LEGEND N ~rh - School l~ - Nearest Residence m 1 inch = 0.5 Miles I I l - Railroad ~ - Hospital ~ - Fire Station FIGURE 5 - Map shows the impact on the sensitive population sites from subject ammonia release case. ! Va_~or Source: 3.44 lbs/sec Ammonia-10 sec Adverse Weather Conditions Modelled m jjquid Source: 13.16 lbs/sec Ammonia-10 sec Stabi{i _[y Class: C Total Dispersion Distance for 50 00m Plume: ~: 5.0 mph m v _ai3or Release: 470 yards Wind Direction: From the East Northeast Li0uid Release: 177 yards (shaded plume) Temoerature: 40°F m LEC/GIST-BROCADES/9-91 GIST-BII~CAOES FOOD INGREDIEIJ~_.~, DISPERSION OF AMMONIA RELEASE FROM DELIVERY HOSE FAILURE 3.44 lbs/sec VAPOR-13,16 lbs/sec LIQUID 10 SECOND RELEASE ADVERSE WEATHER CONDITIONS 500 PPM PLUME CONCENTRATION ~] MING AVE ._1 ° '" ~ WH'TE LANE ,ST BROCADES DISTRICT BLVD ~ PLANT {~ Liquid release is too small to plot. I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I i , ~ i , , , , , , i , ,~ ................. ~ACHECO ROA PANAMA LANE LEGEND I N~ ~rh - School 1~ - Nearest Residence I Inch = 0.5 Miles ~ , ,- Railroad ~ - Hospital ~] - Fire Stal~on I FIGURE 6 - Map shows the impact on the sensitive population sitesfrom subject ammonia release case. Vaoor Source: 3.44 lbs/sec Ammonia-10 sec Adverse Weather Conditions Modelled I LiQuid Source: 13.16 lbs/sec Ammonia-10 sec . Stability_ Class: C Total Dis,Dersion Distance for 500 _Dom Plume: Wind S,Deed: 5.0 mph i Va,Dor Release: 112 yards Wind Direction: From the East Northeast LiQuid Release: 55 yards (Too small to plot) Tem,Derature: 40°F i LEC/GIST-BROCADES/9-91 GIST-BJ~ICADES FOOD INGREDIEI~_.,_L~, DISPERSION OF AMMONIA RELEASE FROM DELIVERY HOSE FAILURE 3.44 lbs/sec VAPOR-13.16 lbs/sec LIQUID I MINUTE RELEASE AVERAGE WEATHER CONDITIONS 50 PPM PLUME CONCENTRATION r~ MING AVE ° 0 W,,T LANE ~ GIST BROCADES DISTRICT BLVD '~. '~ PI-ANT I I I I I I I I I I I I I I~I I~ I I I I I I I I I I I I '"" I I I I I I I I I I I I I I 'l~l I I I I I I f ' ' ' ' ' ' ' ' aACHECO ROA PANAMA LANE LEGEND I N~ ~rh - School 1~ - Nearest Residence I Inch = 0.5 Miles ~ ~ ,,- Railroad ~ - Hospital ~ - Fire Station i FIGURE 7 - Map shows the impact on the sensitive population sites from subject.ammonia release case. .~aJ~3L~.~B~: 3.44 lbs/sec Ammonia-1 minute Averat3e Weather Conditions Modelled I Lic~uid Source: 13.16 lbs/sec Ammonia-1 minute Stabili _ty Class: B Total Disoersion Distance for 50 DDm Plum~: Wind S_Deed: 6.4 mph Va~r Release: 915 yards Wind Direction: From the Northwest I LJ~: 130 yarcls(shaded plume) Temperature: g5°F I LEC/GIST-BROCADES/9-91 m GIST-B _I~CADES FOOD INGREDIE _1~, INC, DISPERSION OF AMMONIA RELEASE FROM DELIVERY HOSE FAILURE : 3.44 lbs/sec VAPOR-13.16 lbs/sec LIQUID m 1 MINUTE RELEASE ADVERSE WEATHER CONDITIONS 50 PPM PLUME CONCENTRATION m'~ MING AVE ! '" I ~ WHITE LANE ~ P-IST BROCADES I DISTRICT BLVD/~' · ~,~PLANT =~ PACHECO ROA I PANAMA LANE LEGEND m N~ ~h - School ~ - Nearest Residence I Inch = 0.5 Miles I I I- Railroad ~ - Hospital ~ - Fire Station m FIGURE 9 - Map Shows the impact on the sensitive population sites from subject ammonia release case. Vaoor Source: 3.44 lbs/sec Ammonia-1 rain Adverse Weather Conditions Modelled m ~: 13.16 lbs/sec Ammonia-1 min Stability_ Class: C Total Dis0ersion Distance for 50 DDm Plum~: Wind SBeed: 5.0 mph m ~3J;laLJ3~J~: 1236 yards Wind Direction: From the East Northeast LiQuid Release: 172 yards (shaded plume) Temperature: 40°F m LEC/GIST- B ROCADES/9-91 DISPERSION OF AMMONIA RELEASE FROM DELIVERY HOSE FAILURE 3.44 lbs/sec VAPOR-13.16 lbs/sec LIQUID I MINUTE RELEASE AVERAGE WEATHER CONDITIONS 500 PPM PLUME CONCENTRATION r~ MING AVE a: ~h a: ° r~ GIST BROCADES · PLANT DISTRICT BL VD ~ Liquid release is  too small to plot. ' ''' '~ ' I I I I I I I I' ' ' '''' PACHECO RO~ PANAMA LANE LEGEND I N~ ~rh - School ~' - Nearest Residence I I Inch = 0.5 Miles ~ ~ ~ - Railroad ~] - Hospital r~ - Fire station i FIGURE 8 - Map shows the impact on the sensitive population sites from subject ammonia release case. VaDor Source: 3.44 lbs/sec Ammonia-1 minute Average Weather Conditions Modelled I Liauid Source: 13.16 lbs/sec Ammonia-1 minute Stability_ Class: B Total Dis_oersion Distance for 500 DDm Plume: Wind SDeed: 6.4 mph i Vapor Release: 258 yards Wind Direction: From the Northwest Lk~uid Release: 41 yards (Too small to plot) Temperature: 95OF i LEC/GIST-BROCADES/9-91 DISPERSION OF AMMONIA RELEASE FROM DELIVERY HOSE FAILURE 3.44 lbs/sec VAPOR-13.16 lbs/sec LIQUID I MINUTE RELEASE ADVERSE WEATHER CONDITIONS 500 PPM PLUME CONCENTRATION  MING AVE 0 0 a: ~l~ a: ° ~-) GIST BROCADES · PLANT DISTRICT BLVD ~ Liquid release is , too small to plot. i i i i i I i i ~ i i I I I I I I I I I I I ! i i i i I I I I I I I I I I I I I I I I I I I I I I I I~ I I I I I I ........... ~AOHEO0 RO,a PANAMA LANE m j~ LEGEND N ~rh - School ~ - Nearest Residence m inch = 0.5 Miles ,, ,, ,, - Railroad [] - Hospital r~ - Fire station m FIGURE 10 -Map shows the impact on the sensitive population sites from subject ammonia release case. Vapor Source: 3.44 lbs/sec Ammonia-1 min Adverse Weather Conditions Modelled m J.L~: 13.16 lbs/sec Ammonia-1 min Stability_ Class: C Total DisDersion Distance for 500 .opm Plume: Wind Speed: 5.0 mph m vapor Release: 287 yards Wind Direction: From the East Northeast LiQuid Release: 54 yards (Too small to plot) Temperature: 40°F m LEC/GIST-BROCADES/9-91 "WE CARE" FIRE DEPARTMENT 2101 H STREET S. D. JOHNSON December 20, 199 I BAKERSFIELD, 93301 FIRE CHIEF 326-3911 Mr. Karl Luft Luft Environmental Consulting 3701 Pegasus Drive, Suite 121 Bakersfield, CA 93308 Karl: Having reviewed the hazard analysis submitted for the Gist- brocades anhydrous ammonia conversion facility, the following questions remain regarding the scope of this study. I have outlined the points of concern below. 1. The hazard analysis addresses the catastrophic failure of the 3" and 1" liquid ammonia ~lines downstream of the excess flow valves. At what rate would the liquid ammonia storage tank evacuate if a lesser failure, such as a crack (larger than a fitting leak), occurred in a line or equipment downstream of the excess flow valves? Address failUres which could occur that would cause an anhydrous ammonia release at a rate less than 225 gal/min from the 3" line and 24 gal/min from the 1" line. 2. Event one, the 90 gallon/minute release due to storage tank overfill, cannot be dismissed based on the inventory control program. Human error or negligence in implementing the inventory control program is a real possibility, therefore this event remains a credible event. The phase of the release and the duration of the release need to be defined. 3. Provide the calculations used to determine the percentages of liquid 'ammonia expected to flash to vapor upon release to the atmosphere. 4. The Haz-Op, page 2, indicates that a gauge failure would cause a discharge from the ammonia storage tank until it could be isolated. This release rate has not been defined in the hazard analysis 5. Is the storage tank adequately braced to prevent toppling in the event of a strong earthquake? 6. What are the consequences of a failure of the "water flow permissive" which prevents the flow of ammonia to the reactor in absence of dilution water? What are the consequences associated with other possible failures of-the programmable logic controller? The offsite consequence analysis submitted does not appear · valid for the reasons stated below. 1. Because the hazard analysis did not define all of the ammonia release scenarios identified in the Haz-Op matrix (items 1 & 2 above), it is unclear which event represents the worst credible scenario. 2. The duration described for several of the credible ammonia release scenarios is dependant upon the amount of time that it would take Gist-brocades personnel to identify the problem, don SCBA and protective clothing and isolate the leak. The hazard analysis (pg. 10) indicates that it would take. plant personnel a "few minutes" to respond with the proper personal protective equipment.' The release duration modeled, one minute, is inadequate. Scenarios which depend upon response by plant personnel are not the worst credible. These individuals are not professional emergency responders with a sworn commitment to public safety. It is credible and reasonably likely that plant or deliverY personnel could panic or have second thoughts regarding.their personal safety and fail to preform emergency shutdown operations. 3. The use of the urban~terrain parameter is inappropriate given the wide open spaces adjacent to this facility. 4. A computer print 'out of the air dispersion model input parameters and output were not submitted. As noted in our RMPP Preparation Guidelines, it is advisable to discuss the worst credible case with us prior to modeling in order to avoid disagreements which cause extra work. In this case, please submit the information required to complete the hazard analysis. We can .then agree upon an appropriate worst case scenario to be used to estimate offsite consequences, i~. Bakersfield Fire cannot make a determination regarding the sufficiency of a RMPP until questions regarding preliminary analyses have been resolved. A RMPP~cannot be certified complete based on incomplete hazard and consequence analyses. Therefore, we are returning the RMPP Addendum submitted for Gist-brocades ammonia conversion equipment. Once the completed hazard and consequence analyses have been reviewed, the RMPP, certified as complete, may be submitted. Sincerely, Barbara Brenner Hazardous Materials Planning Technician cc: Ralph Huey Robert Deedy CITY of BAKERSFIELD "WE CARE" FIRE DEPARTMENT r 2101 H STREET S. D. JOHNSON November 2 6, 1 9 9 1 BAKERSFIELd, 93301 FIRE CHIEF 326-3911 Ashok Pandya Gist-brocades Food Ingredients, Inc. 5455 District Blvd. Bakersfield,. CA 93313 Mr. Pandya: I have received the hazard analysis and RMPP, for the anhydrous ammonia tank and mixing system, from Luft Environmental. However, I have not received the amendments to the plans which we discussed during my inspection on 10-18-91. These changes must be submitted and approved ~prior to the Fire Department's final~ approval of this project. The items listed below need to be addressed regarding the alterations to the original plan. 1. Fittings around the excess flow valves which cannot be welded as well as any other joints or fittings which cannot by welded 2. Addition of flow switches which were not indicated on the approved plans 3. The failure to vent any of. the pressure relief valves to a scrubber system I have attached a copy of the letter from Level Technologies which details the plans relating to the above item number three. Please call me if you have any questions, regarding the submittal of these changes to your plans. Sincerely, Barbara Brenner. Hazardous Materials Planning Technician cc: Ralph Huey LUFT ENVIRONMENTAL CONSULTING 3701 Pegasus Drive, Suite 121 · Bakersfield, California 93308· (805) 399-5838 December 6, 1991 RECEIVED Barbara Brenner .{)lC 1 0 1991 Hazardous Materials Planning Technician Bakersfield City Fire Department HAT_. MAT. DIV. 2101 "H" Street Bakersfield, CA 93301 Ms. Brenner: Pursuant to your August 13, 1991 letter requesting a RMPP for the sulfuric acid system, Gist-brocades Food Ingredients Inc. has requested that Luff Environmental Consulting prepare the sulfuric acid system RMPP. As you are aware, Gist-brocades' original RMPP for the chlorine system will be reviewed during 1992 for any necessary revisions pursuant to Section 25534 (h). During this RMPP review, Gist-brocades intends to incorporate the ammonia, chlorine, and sulfuric acid system RMPPs into one document. We have also enclosed a summary of qualifications for the preparation of RMPPs. If you have any questions concerning the enclosed, please contact me at your convenience. _ ~ £ ~ Kad W. Luff Principal Mechanical Engineer cc: Bob Deedy LEC-91-0362 GB-01 SUMMARY OF QUALIFICATIONS FOR THE PREPARATION OF RISK MANAGEMENT AND PREVENTION PROGRAMS Luff Environmental Consulting has prepared and certified Risk Management and Prevention Programs (RMPPs) for a variety of industries in various jurisdictions throughout California. The following Luff Environmental Consulting personnel are proposed for the Gist- brocades RMPP. This team from Luff Environmental Consulting will augment the expertise of the HazOp team from Gist-brocades. Gist-brocades' team members will in I 13rni"'~f e~nir~,', . _ ~ cude the-,_._, ..... o ...... v .... -~ ....,_,, maintenance engineer (Lloyd Fry), and the plant manager (Bob Deedy).~-~"~5 }~.~ ~;,~c~, /~/~-,~--~H7''~' ~ ~/5/72._~// Karl Luff Mr. Luft is a registered mechanical engineer and registered environmental assessor in the State of California. He has eight years of design and project management experience in the petroleum and cogeneration industries and three years of environmental work experience. Environmental work experience includes the preparation and certification of RMPPs. Mr. Luff has conducted Hazard and Operability (HazOp) studies (as team leader) for numerous coal, coke, and gas fired cogeneration facilities, several cold storage and food processing facilities, an industrial compressed gas facility, and a wood preserving facility. Additionally, Mr. Luff has participated in and provided third party review of HazOps conducted for a Process Safety Management program at a major refinery. Mr. Luff will be the HazOp team leader and will certify as "qualified person". Sue Luff Ms. Luff is an industrial engineer, certified hazardous materials manager, and registered environmental assessor. She has over twelve years of environmental regulatory experience which includes regulatory agency and petroleum industry experience. Ms. Luff has extensive experience in working with the federal, state, and local regulatory agencies. Ms. Luff has participated in HazOp studies as recorder in addition to preparing several RMPPs. Ms. Luff will be responsible for quality control for the RMPP. Mr. Beck is a chemical engineer and may participate as a HazOp team member. He is currently working on a Process Safety Management program for a refinery. John Haley Mr. Haley is a mechanical engineer and may participate as a HazOp team member. He has participated in RMPPs for facilities which handle anhydrous ammonia and chlorine. Todd Rook Mr. Rook is a mechanical engineer and may participate as a HazOp team member. He has participated in RMPPs for facilities which handle anhydrous ammonia, He is currently working on a Process Safety Management program for a refinery. Debbie Anderson Ms. Anderson is a biologist/zoologist with over eleven years of environmental work experience with an emphasis in air modeling. She has performed air dispersion modeling and offsite consequence analysis for ammonia and chlorine releases in numerous RMPPs. Ms. Anderson will perform the air dispersion modeling and offsite consequence analysis. The Acutely Hazardous Materials handled by Gist-brocades are anhydrous ammonia, chlorine and sulfuric acid. RMPPs for the anhydrous ammonia system and chlorine system have already been prepared and submitted to the Bakersfield City Fire Department. Luff Environmental Consulting is proposing the following plan for the risk analysis. 1. Estimation of the probability of equipment failure will be based on good e..~_ngineering judgement. ~. =xmrna~ evems ~o De eva~ua~ea ino~uae earthquake and fire fromm'Within the plant. Additional events that may be reviewed are motor vehiole accidents and power failures (the HazOp will identify if an analysis of these events is warranted). 3. The factors that will be used for the offsite consequence analysis will include the worst credible release of each AHM coupled with pessimistic air dispersion modeling directed at the nearest and/or most sensitive receptor. Additionally, the worst credible release of the AHM will be modeled for the most likely atmospheric conditions. Results will be modeled for concentrations set at 50 ppm and 500 ppm as specified in the "Outline of RMPP Requirements", prepared by the Bakersfield City Fire Department Hazardous Materials Division. 4. The pollutant dispersion results will be generated by the CAMEOS-ALOHA model developed by the Hazardous Materials Response Branch of the National Oceanic and Atmospheric Administration. CAMEOTM is the Computer-Aided Management of Emergency Operations program which was designed to help emergency planners and first responders both plan for, and safely handle, chemical accidents. ALOHA stands for Areal Locations of Hazardous Atmospheres and serves as a tool for estimating, the movement and dispersion of an atmospheric pollutant. CAMEO version 3.0and ALOHA version 5.0 will be used for the modeling. 5. Estimations of human error (operator error) will be made based on operational history of this and similar facilities, site specific training program analysis and sound judgement. 6. The probability of operating errors will be determined by the HazOp team. HazOp team members will include operating personnel from Gist-brocades. ~ I^ t'~-l"~"i(' c,-.(1 LUFT ENVIRONMENTAL CONSULTING 3701 Pegasus Drive, Suite 121 * Bakersfield, California 93308 · (805) 399-5838 November 18, 1991 Barbara Brenner R E C E I V E 13 Hazardous Materials Planning Technician I~OV ! 9 lg§l Bakersfield City Fire Department 2101 "H" Street /~ns'd ............ Bakersfield, CA 93301 Ms. Brenner: Enclosed for your review are the Hazard and Operability Study, Offsite Consequence Analysis, and the Addendum to the Risk Management and Prevention Program (RMPP) for Gist-brocades Food Ingredients Inc. As discussed previously, the Addendum to the RMPP cohtains only the sections that were affected by the installation of the anhydrous ammonia conversion system. Sections of the original (chlorine) RMPP that were not affected by the installation of the ammonia conversion system were not changed. Hence, the addendum to the RMPP should be incorporated into the original RMPP by placing it at the end of the odginal RMPP. If you have any questions concerning the enclosed, please contact me at your convenience. Karl W. Luff Principal Mechanical Engineer cc: Bob Deedy LEC-91-0349 GB-04 This Addendum to Gist-brocades Food 'Ingredients 'lnc.'s Risk Management and Prevention Program contains only the sections that were affected by the installation of the anhydrous ammonia conversion system. Sections of the original (chlorine) RMPP that were not affected by the installation of the ammonia conversion system were not changed. Hence, this addendum to the RMPP should be incorporated into the original RMPP by placing it at the end of the original RMPP. PKCEIVED OCT 2 2. 1990 LUFT ENVIRONMENTAL CONSULTING ............ 3701 Pegasus Drive, Suite 121 · Bakersfield, California 93308 · (805) 399-5838 October 18, 1990 Ra,!ph Huey Hazardous Materials Coordinator Bakersfield City Fire Department 2130 "G" Street Bakersfield, CA 93301 Mr. Huey: 'In response to your October 1, 1990 letter to Gist-brocades, Luft Environmental Consulting is forwarding the enclosed summary of qualifications for preparing the RMPP for Gist-brocades Food Ingredients, Inc.'s new anhydrous ammonia system. If you have any questions concerning the enclosed, please contact me at your convenience. Kad W. Luff Principal Mechanical Engineer cc: Ashok Pandya- Gist-brocades LEC-90-0369 GB-04 SUMMARY OF QUALIFICATIONS FOR THE PREPARATION OF RISK MANAGEMENT AND PREVENTION PROGRAMS Luft Environmental Consulting has prepared and certified Risk Management and Prevention Programs (RMPPs) for a variety of industries in various jurisdictions throughout California. The following Luft Environmental Consulting personnel are proposed for the Gist- brocades FIMPP. This team from Luft Environmental Consulting will augment the expertise of the HazOp team from Gist-brocades. Gist-brocades' team members will include the project engineer (Ashok Pandya), maintenance engineer (Lloyd Fry), and the plant manager (Bob Deedy). Karl Luff Mr. Luff is a registered mechanical engineer in the State of California. He has eight years of design and project management experience in the petroleum and cogeneration industries and two years of environmental work experience. Environmental work experience includes the preparation and certification of RMPPs. Mr. Luft has conducted Hazard and Operability (HazOp) studies (as team leader) for several coal, coke, and gas fired cogeneration facilities, cold storage and food processing facilities, an industrial compressed gas facility, and a wood preserving facility. Mr. Luff will be the HazOp team leader and will certify as "qualified person". Sue Luff Ms. Luff is an industrial engineer, certified hazardous materials manager, and registered environmental assessor. She has over ten years of environmental regulatory experience which includes regulatory agency and petroleum industry experience. Ms. Luff has extensive experience in working with the federal, state, and local regulatory agencies. Ms. Luff has participated in HazOp studies as recorder in addition to preparing several RMPPs. Ms. Luff will be responsible for quality control for the RMPP and will also certify as "qualified person". Mark Meier Mr, Meier is a chemical engineer and will participate as a HazOp team member. His previous experience in RMPPs includes being a recorder in a HazOp. He is currently participating in RMPPs for facilities which handle anhydrous ammonia and chlorine. Mr. Meier will be a HazOp team member. John Halev Mr. Haley is a mechanical engineer and will participate as a HazOp team member, He is currently participating in RMPPs for facilities which handle anhydrous ammonia and chlorine; Mr. Haley will be a HazOp team member. Debbie Anderson Ms. Anderson is a biologiSt/zoologist with over ten years of environmental work experience with an emphasis in air modeling. She has performed air dispersion modeling and offsite consequence analysis for ammonia and chlorine releases in numerous RMPPs. Ms. Anderson will perform the air dispersion modeling and offsite consequence analysis. The Acutely Hazardous Materials handled by Gist-brocades are anhydrous ammonia and chlorine. An RMPP for the chlorine system has already been prepared and submitted to the Bakersfield City Fire Department, Luff Environmental Consulting is proposing the following plan for the risk analysis. 1. Estimation of the probability of equipment failure will be based on good engineering judgement. 2. External events to be evaluated include earthquake and fire from within the plant. Additional events that may be reviewed are motor vehicle accidents and power failures (the HazOp will identify if an analysis of these events is warranted). 3. ~ The factors that will be used for the offsite consequence analysis will include the worst credible release of each AHM coupled with pessimistic air dispersion modeling'directed at the nearest and/or most sensitive receptor. Additionally~,~' the worst credible releaSe of the AHM will be modeled for the most likelY .atmospheric conditions. The Emergency Response Planning Guidelines (EPRG) concentration levels, ERPG-2 and ERPG~3, will be modeled. 4. The pollutant dispersion results will be generated by the CAMEO~II-ALOHA model developed by the Hazardous Materials Response Branch of the National Oceanic and Atmospheric Administration. CAMEO~II is the Computer-Aided Management of Emergency Operations program which was designed to help emergency planners and first responders both plan for, and safely handle, chemical accidents. ALOHA stands for Areal Locations of Hazardous Atmospheres and serves as a tool for estimating the movement and dispersion of an atmospheric pollutant. 5. Estimations of human error (operator error) will be made based on operational history of this and similar facilities, site specific training program analysis and sound judgement. 6. The probability of operating errors will be determined by the HazOp team. HazOp team members will include operating personnel from Gist-brocades. CITY of BAKERSFIELD "WE CARE" FIRE DEPARTMENT 2~01 H STREET S. D. JOHNSON November 12, 1991 BAKERSFIELD, 93301 FiRE CHIEF 326-3911 Mr. Lloyd Fry Maintenance Engineer Gist-brocades Food Ingredients Inc. 5455 District Blvd. Bakersfield, CA 93313 Mr. Fry: Per your request, I have revieWed the request which Bakersfield Fire made of Gist-brocades regarding preparation of a risk management and.prevention plan fOr storage and handling of up to 500 gallons of concentrated sulfuric acid. The California Health and Safety Code requires Administering Agencies to request a risk management plan from facilities which handle greater than the threshold planning quantities of acutely hazardous materials (AHM) unless the agency finds that the use or storage of the .materials poses no significant risk. Bakersfield Fire uses a facility index questionnaire to preliminarily evaluate each use of an acutely hazardou~ material.. For those facilities which .score greater than 20 on the index, a RMPP is usually requested. For the facilities which score less than 20, additional inspections are performed and a determination is then made whether.the risk from a release is significant, warranting preparation of a RMPP. Based on the facility index questionnaire completed by Mr. 'Deedy, Gist- brocades uSe of sulfuric acid scored 23.5. Bakersfield Fire's request for a RMPP regarding the use of concentrated sulfuric acid at Gist-brocades is consistent with our treatment, of similar' facilities in Bakersfield. All of the facilities which store or use over 1000 lbs of concentrated sulfuric acid have been asked to prepare risk management plans. Several of these businesses have opted to eliminate the sulfuric acid and substitute an acid which is not an acutely hazardous material. The elimination of an AHM is an acceptable risk management technique. From our discussions, it is my understanding that the process at Gist-brocades is such that substitution of another acid is not possible. The .threshold planning quantity, 1000 lbs, of sulfuric acid is approximatel~ equal to 65' gallons. In order to eliminate the requirement for completion of a RMPP, Gist may elect to reduce the quantity.of sulfuric acid on site at any one'time to less than 65 gallons. In preparation of this response to your questions, I reviewed Gist-brocades file'and found that the hazardous materials business plan is incomplete in several areas. Release prevention has been referred to the attached environmental incident plan. Fire 'Department .emergency responders do not have access to your environmental incident plan at the'time of an emergency. Only the haz-mat business plan is available to responders on the computer in the haz-mat response vehicle. It will be necessary for you to paraphrase the incident plan and to provide the pertinent information on your business plan. Ralph Huey asked for this same information in June of 1991 and we have not yet received it. I did review the environmental incident plan which We have on file and found no information regarding handling of a sulfuric acid spill. Further, the quantity of sulfuric acid reported by Mr. Deedy , 500 gallons, is inconsistent with the amount declared on the inventory, 700 gallons. The risk index score of 23.5 is based on the 500 gallon amount. In response to Your concern that our request of an RMPP for the. sulfuric acid is an unnecessary burden on Gist-brocades, I 'find that there is very little, documentation regarding the management of. this material. It does not appear that the RMPP will duplicate any previous reporting or risk ~valuations. As I stated before, this request for a RMPP is consistent with our treatment of all similar facilities. If Gist-brocades elects to continue the storage of greater than 65 gallons of concentrated sulfuric acid, the RMPP may be provided as an addendum to the previous RMPP documents prepared regarding the use of chlorine and anhydrous ammonia. The sulfuric acid .RMPP 'may also be prepared independently of the other two if that is more convenient. Please update the attached copy of Gist- brocades hazardous materials management plan, sign and r~turnit by 12-12-'91. I have highlighted the areas which'need to be .completed. Correct the quantity of sulfuric acid if that is appropriate and feel free to make any other necessary'changes at this time. Sincerely, Barbara Brenner Hazardous Materials Planning Technician cc: Ralph Huey .RISK RANKING - GI~ST-B~OCADES, 96% SULFURIC ACID FACILITY RISK INDEX 2.'7 X 3 = 8.1 INSPECTION HISTORY 0 X 3 = 0 POPULATION EXPOSED 2 X 2 = 4 MCP 4 X ~1 =, 4 ]'OX FACTOR 7.4 X 1' = 7.4 (15.35 LB\GAL) (500 GAL) (.96)\1000 = 7.4 TOTAL = 23.5 FACILITY RISK INDEX RAT I NG G I S~I~-BROCADES . W = Activities or cor~ditiorfs that ir~crease the likelihc-'-,d of a release.' 3 x .5 = 1.5 (NO. OF' YES ANSWERS ON THE QUESTIONNAIRE Add 1 yes to each facility for storage arid ~,~ir~i~al X = This factor reflects a co~par~y's clai~ (safety). history. (WORKER COMPS,FACTOR, MAXIMUM EXPECTED IS 1.5) Y = Self reported accider~t / safety record. 0 (REASONABLE=(), INADEQUATE=O. 25, GROSSLY INADEQUA'~E=O. 5) Z = Not 'directly addressed ir~ the questior~r~aire. 0.5 3~AHM' s or~'site. (OTHER COMPLICATING FACTORS MINIMAL=O, CONSIDERABLE=0.5, ~UBSTANTIAL=i.O) FACILI]'Y RISK INDEX = ,-."~' 69 RATI. NG FI = W + X + Y~ + Z RAT I NG RA'I" I ONALE: Ri~k. inc. reases wi~h ir~creasir, g process cc, r~plexity and poter~tial for hur,~ar~ e~.-ror. POPULATION EXPOSED - RATING 1. IS TOXIC MATERIAL~AP]" TO BECOME AIRBORN RAPIDLY ~? i.e. A GAS, FINE DUST, HIGHLY VOLATILE LIQUID NO= 1 YES= 2 1 IF ANSWER T0 MI IS NO, PROCEED TO 06 IF ANSWER TO $~1 IS YES, ESTIMATE ]'HE EVACUATION RADIUS, USING THE BAKERSFIELD FIRE DEF'-['. GRAPH MODEL, AND ANSWER QUESTIONS 2-5. 2. IS THERE A SCHOOL WITH IN ]'HE EVACUATION RADIUS -~ NO=O, YES=i '~' 3. IS THERE' A NURSING HOME OR HOSPITAL WITH IN THE EVACUATION RADIUS o NO=O, YES=i 4. IS THERE RESIDENTIAL HOUSING WITHIN THE EVACUATION RADIUS ? NO=O~ YES=i /' 5. IS ]'HE POPULATION DENSITY OF ]'HIS AREA HIGHER THAN THE AVERAGE DUE TO ALOT OF MULTISTORY BUILDINGS NO=O, YES=i 6. WHAT IS THE OCCUPANCY OF THE BUILDING ]'HA]- AHM IS STORED OR HANDLED IN ? LESS THAN 5 PEOPLE=I 6 - 25 PEOPLE =2 26 - 50 PEOPLE =3 MORE THAN 50 PEOPLE =4 TOTAL POPULATION EXPOSED RATING = .2 RECEIVED AUG 0 FACILITY ·INFORMATION FORM HAZ. MAT. DIV. Please answer each of the'following questions, by cirCling Y (yes) or N no). I. Is any acutely hazardous material (AHM) .. ._~ manufactured or used in a chemical reaction ? Y 2. Is any other flammabie gas, flammable liquid or explosive material manufactured or used in /~-~N~ a chemical reaction ~ Y 3. -Is any reaction in question 1 or 2 a moderately or highly exothermic reaction ( e.g. alkylation esterfication, oxidation, nitration, polymerization or condensation) or one involving electrolysis ? Y 4. Can any unplanned release of a AHM to the atmosphere result from the malfunction of any scrubbing, treatment or neutralization system or the discharge of a pressure relief system * Y 5. Does any physical or chemical process in, which an AHM is produced or used involve a batch process ?~/ N 6. Does any physical or chemical process involve the production or use of any AHM at a pressure in excess of 15 psig ~ ~/ N · 7. In excess of 27S psig * Y / 8. Does any physical or chemical process involve the production or use of an AHM at a temperature above 125 degrees F ~ Y 9. In excess of 250 degrees ? Y 10. Can any explosive'dusC be present in any Closed container within 100 feet of an AHM or otherwise be present in the same building as an AHM ~ Y ll. Is there any ignition source or open flame within i00 ft. of any process, s~orage or transfer area where a flammable or explosive AHM is present , except where there is a firewall providing protection ? Y 12. Is' any l'ined or non-metallic pipe used in,the transfer of any AHM ? Y t3.ts any equipment or piping.handling any AHM more 10 years old ~ PLEASE PROVIDE THE FOLLOWING INFORMATION ( Attach additional pages if necessarl;) 1. Your company's current workers compensation . experience modification factor. ~ .690 2. How many people Occupy the building in which AHM's are used or stored ? 0 (outside storage) 3. Give details of al! accidents which involved any hazardous material and all other instances when the fire department has been summoned in an emergency. - 6/14/91 the fire department responded to a small fire in one of the yeast centrifuges, The fire was extinguished by our operator , The fire department was called asa precautionary measure, 4. Briefly described the ooerations process at your plant and the specific processes utilizing AHM"s, including storage proceedures. The sulfuric acis is stored adjacent to the south wall of the manufacturing building in a 700 gallon stain]ess steel tank. Sulfuric acid is used to lower .the pM in the cream yeast to inhibit bacterial growth, To operate the syJtem the acid vlave on the storage tank is opened allowing~the pressure pot feeder to fill to the desired level, The storage tank valve is closed the pot feeder discharge valve is opened to the appropriate destination then air pressure is applied to the pot feeder and the acid is forced out the discharge, When all the acid is discharged the air is shut off and the pot feeder discharge is shut, The pot feeder is equipped with a vent and. an overflow as well as a pressure relief which all return to the storage tank, 5. Briefly describe-the-equipment, being used in the processes involvin~ A}hMs. There is a 700 gallon stainless steel vented tank. The vent is piped directly to a drain which is connected to our waste water storage system.. All process piping is Schedule 10 stainless steel welded pipe. The pot feeder is a rated pressure vessel capable of holding approximately 16 gallons. The feeder is equipped with a pressure relief valve set at 30' psi which relieves back to the storage tank. The air supply to the pot feeder is. equipped with an air pressure regulator set at (25 P.S.I.). 6. Report quantity of A~M(s), referenced in the cover letter, that this business handles. ~ 500 gallons a) Maximum amount on hand a% any one ~_me. % c~¢,c~.-,-~-ro.=;~,.~ '96% (non-fuming) b) Please attach a Mamerlai Safec;£ Data Shee: for any material that is a mixture. Do include MSDS for pure substances. DEMOGRAPHIC DATA: State the straight line distance in fee~ between the -Jousiness property line and each of the fol!owinq. i. Nearest school. 5650 feet 2.. Nearest daycare center, hospital, nursing home or similar-facility. 1954 3.' Nearest residence/motel etc. 2006 4. Nearest occupied building. '" 3 Business Name: Gist-brocades Food Ingredients, Inc. Address: 5455 District Blvd. Bakersfield, California 93313 Z certify that the foregoing information is true and '- S i gnature: ~/ ~ ~. Title: Plant M.an.aper / Da. to: GIST-BROCADES PLANT'. ]'~ STOCKDALE HWY :, Q r"l r~ Q ~ W W IJJ ~ ~ ~ GIST-BRO,~ADES~ ~I~LN ~ ~~ DISTRIC, BLVD , ~ PACHECO RD > PANAMA LN LEGEND ~ ~. - School ~ -Nearost Ros~den~ ~-Fire Station ~ - Pro~sed School ~ - Hosp~al 1 Mile = 1 Inch FIGURE XlII-3 - Map showing the sens~ive ~pulation sites near the Gist-BroCades plant on Distri~ Blvd. Gist-brocades Food Ingredients Inc./RMPP/October; 1989/Page XIII-9 Luff Environmental Consulting TABLE XIlI-1 GIsT, BROCADES: pLANT SENSITIVE POPULATION. SITES. APPROXIMATE DISTANCE CR!TICAL SITE FROM PLANT WIND DIRECTION (Miles) (Wind From) Nearest Residence 0.38 South or Northwest Nearest Hospital 0.37 South Nearest School 1.07 Southwest Nearest Fire Station 2.13 Southeast Gist-brocades Food' ingredients Inc./RMPP/October; 1989/Page Xlll-10 Luft Environmental Consulting J FIODUCT SAFETY DA'T'A SHD T SULFU ACID SULFURiGAG[O;. 7584.g3'-~~'. m. 8U~URIC ACID Synonym: ba~e~ ac)d ~ENE~L CHEMICAL QO~PO~ATION go East Halsey Roa~ ,, A,m~w ~m~m)n~t~ clmhing whil~ w~h)ng, ~ medial a~anl~n is nat immedlate~ available. INGES~ON: D~ not induce vom~ing. If ~nsciaus, give several glasses;of milk (prefe~ed) or ws~r, } ]NMA~ON: ~;muvu tu t~u~h air. Ob~rvu Jut ~sible d~lny~d r~acUon. Il brea~hlng has stud. give a~UidaJ roopitmion, ~ bromhing with diffiou~y~ give exygen, pt~lded a qusl~ied. ~ET I~MEDIATE MEDICAL ASSISTANCE for ingestion, inhalation, ~ye ~nl~, IrrMt~n, o~.burn~. HEAL~ Inhalation ct fumes or JcJd mist can c~u~e Irrf~mlan ar ~rrosJve burns to the upper resgimlo~ system, Including nose, Oma cauj. irr~ntbn and corraalvm burn~ to mouth, throat, ~nd otom~oh. Con bo teal tf ow~llowad, ~a~e ~o dilute solut~ns: LD ~(rat): 2140 mg~g .. Reiermnc~ (bi, O~n c~use soy,re bum~. u ~ntzct c~ cause irr~et~Gcornesl burns, and coaju~t~l~. Olindne~ mey ~ault, or ~evmre or ~rmAne~ inju~. ~t ~ may IrtMle. or burn, Re(erence (b)~ J~;m~ ~ 1 m~/m3 (~ H ;~O ~ (OSHA) TLr: samJ.(ACGIH) ID~ 80 mg/m ~ None. (1) ~sJo~ of t~eth, (2) les~ns al fha skin, (~) tra~heo-bronch~is, (4) m~h Jail,rematCh, (5) ~njUnmlvJtls~ (BI gn~la. ' -Relere~e(~). - · , .,~'~./.: ,.~.'/~::: ::...':' :..= '~' , : ~ ~ ~. - . . ~ . ~- . . , , '~ ;, ~ ~ · ~~ ~o ~,~ o c F~mm~le ~te'~ti~l-~Y"~Pl~i~e'hY~r'O~engas c~n be generated In~ide~met~ drums:~nd-sm~getan~.~n~ntrated ~het flrew~h d~ ~ml~L .. U~ ws~r ~y u, uil~er suitable a~ent for fire~ ~]~oont to nan-leaking tanM ~r Do not use ~lt, d water streams near ruptured tanks or ~ill~ 6! ~UllUrlc ~¢1~t', Act~ ruacts vlui~utly witll water and ~n ~ on~ ~e~nnet, ~tdem to ~,,e. u~ ~nd ~. m~t~ to oerm~ss~ble JeveJs. Pa~a~n~ and unloading areas and o~n pro~sslng equipment m~y. ~quire m~hanioal exhaust systems. ~rroslon.pr~ ~nstruc~on r~mm nded. U~'V~lll~ Syll~a ~ ~' gel I~ eyep, on s~q~ on dm~in~. Do n~t breath~ ya~r ~r mist, Use prote~e equipment outlined In Semen b, P~-frem ~hy,~ damage, ~t~,~ ;~ ~t, ~ail-v~ntil~t~d ara~ away from ~mb~st~bles and rea~lve chef,als. Keep o~ of .. ~un ~ ~ey ~m he~. Keeg ~ntainers u~lght. No smoking In storage area, O~e, Imag s~lll: or ie~ ca~ous~ w~h ~emy ot water. Neu~rs[~e= residue w~h ~l~li such ~ sod~ ~,h or lime. mqulrem~, Ch~ w~fi ~rl~te igencies, . ~ a~ In metal ~alnem, v~rs c~n m~ain exp~s~e, hydroge~ g~. SEEPAGE S~ SEE'PAQE6, LIQUID. {~ 6OLIO I"'1 Cl~6 Oily, oolorl.ao to ol~ghtl7 yollow, ol.gr to turbid liquid. Odorl.oo~ ~¢,'"t~ ~ a~L~W'tv ..... u~LTIN~ P~INT ~rnv .~7 O ~ II I I ~mplete, 1% ~l~n; pH = 0.~ < 0.001 I Temperatures of 300 d~ C or higher: yle~ ~u~ur UNSTABLE. ~' STABLE ' g~, wh~h Is tox~, ~rmeNe, and~ oxld~er. a~ ~rmangana{~; ca~e t~res a~ ~ssJbJy exp~s~ns, AJJyt ~m~un~s and aJdehydes: unde~o v~ .. n~. (g), (~inu~, ~,~n ~). 8u~ur tr~x~e ~as: see ~ye, Also ~hl~ i~ a ffro. rl~ t In ~nta~ w~h o~an~ ma~e~nl~. MAY OCCUR r~ WILL NOT OCCUR NA 24,5 j~n'u24 hr./131uegllHeth=,l/treeh wrater ~,2,$ ppm/48 hrJpraw~C ~sa~ wate~ '~AH~USS~BST~8 ~. ~. ~F ~ R~ORTA~E~ANTIW; ..... 1~' - ~ ' (100% Ha SO4 bas~) J ~ ............... ~. ~al laws ~nd; regulations. U~ers ~re ~dvised m~nsult with ~pprop~ate- regul~lo~ ~gencies. before'dis~rge, . tre~tment'o~ EPA H~sr~ous W&ste No, O00~ (~rroalve) ~ (2) A~IH 1QsQ.go Ll~t, 'Thre~hold'L~ V~lue~ for Chemicat Substances,,,', Am. ~nf. et Governmental Industrial Hygienists, C~ncinnati 45202. gOT ID NumOer: UN 1830, D,Q,T, H~sr~u~ Materlale Ta~ie 4g CFR (~) ~eument~tlon ~J the Threshold Limit Value~ ~th ~d~n~ tfl~1~ Am, C~nt, ~f G~vernm~nt~l H~ienie[~, Cincinnati 452 , ~) ~S~ ~agl~try=ol Toxl~ E~fe~gt,~he~l~l Substancas, 1982.~. A~esslen ~WS 556 O0 OeO, PBaI.I N~. Tach. Into. 5e~e, 5pMnglield, VA 22161. (c) "Cf~erlafor a Re.remanded Sland~rd.;.Occupaflon~ Ex.sure to Suffur~ Acid', NIOSH U.S, Dept, el HHS, 1974~ PB~33098~ Nat, Tach, bio, Se~ice, Springfield, VA 22151. J, REFERENCES - General (~ntlnued) ' (d) N~SH~S~A, 'P~et G~ ~e Chemical H~ard~...", September, 1 (.) 'NIO~$HA-- ~upatWaal H~alth ~uJ~eJine~ ~or Chemical Hazar~e - ~u~urt~ A~I~", l~7a. (1) Alllad Chem~al TechnlcN So.ice. R~ for storage and handling (g) NFPA ~lnual 4~1 B, 'Manu~l of HazArdous ChemicAl R~acJJons, ~ 987 Nat, Fire Protein[on ~soc,, Boston 0221 {h) Br~her~ L, Handbook of Re,mire Chemical Hazards, 3rd Ed.. 1985 Butte~onhs, G. R~C~VI~ DATA-Incompatibility (continued) Alkalis, sm[nas, ~ater, ~ydrated saEs, csr~xylic acid ~nhydrides, nttrJl~s, oieflnlc organics, gJy~Js, aqueous ~E~J'iON E pROT~{;;q3Y]E F..GUIPMENT 1 H~ H~DLING ~ 2. ~PECIALIZED H~DLING _ . syitem me~bn~ on p. 2): Where: mqvlr~, ,~ m ~s~ra~r a~rov~ ~ NIOSH far euEur~ ~Id. ff m~ti~ ~ve 1 mg H~SO,/wear: Q~atal~ ~t t~Uff~.,~r wme~g~?, ,.g. a mlstl~ ~~ ~splrmoq (~) ~her c~ice3, R~ara~e (~), H~DLING - Re~r~ Eyes and Fl~: Eyes and and ~naliy fu~-f~ ~asti~ shte~. ~ not wear ~eshle~s. ~ a. f~. shte~ ~ ~u/l~ }~, For I~nd~, ,~'ms, and Body Hands, Arm~, and ~y A. & minim~, ~a~ ~.~,~stsnr~ ~pren. pru(~lvu ~ g minimum, we~r ~d-r;el~t&~ ~ron ~ g~y~t~, o~h~, ~, a~ g~ves f~ ro~ine p~u~ u~e. For la~ er spill. 6~ ~4~ ~I~;. ~S~ full CITY of BAKERSFIELD "WE CARE" FIRE DEPARTMENT 2101 H STREET S. D. JOHNSON October 3 1, 19 9 1 BAKERSFIELD. 93301 FIRE CHIEF 326-3911 Ashok Pandya Gist-brocades 5455 District Blvd. Bakersfield, CA 93313 Mr. Pandya: Following my inspection of the anhydrous ammonia storage tank and mixing facility, it is evident that the installation of this equipment is very near completion. I want to make certain that you understand that the revisions to the plans, the hazard analysis and the Risk Management and Prevention plan must all be approved by Bakersfield Fire prior to operation of the ammonia facility. Please call me at 326-3979 if you have any questions regarding the Fire Code or Risk Management Plan requirements. Sincerely, Barbara Brenner Hazardous Materials Planning Technician cc: Ralph Huey FiRE DEPARTMENT 2101 H STREET S D JOHNSON BAKERSFIELD, 93301 FIRECHIEF August 13, 1991 326-3911 Mr. Robert Deedy Gist-brocades Food Ingredients Inc. 5455 District Blvd. Bakersfield, CA 93313 Dear Mr. Deedy: Your business has been identified as a handler of 96% sulfuric acid. It has been determined.your operations may present an acutely hazardous materials.accident risk. Therefore, pursuan$ to section 25534 of the California Health and Safety Code, a Risk Management and Prevention Program (RMPP) will be required for the use and handling of s9&furic acid at Gist-brocades. The RMPP shall be based upon a risk assessment which shall consider all of the following: THE RESULTS OF A HAZARD ANALYSIS WHICH IDENTIFIES THE HAZARDS ASSOCIATED WITH THE HANDLING OF AN ACUTELY HAZARDOUS MATERIAL DUE TO OPERATING ERROR, EQUIPMENT FAILURE AND EXTERNAL EVENTS WHICH MAY PRESENT AN ACUTELY HAZARDOUS MATERIALS ACCIDENT RISK. FOR THE HAZARDS IDENTIFIED IN THE HAZARD ANALYSIS, AN OFFSITE CONSEQUENCE ANALYSIS WHICH ASSUMES PESSIMISTIC AIR DISPERSION AND OTHER ADVERSE ENVIRONMENTAL CONDITIONS. The RMPP shall include the following elements: A DESCRIPTION OF EACH ACCIDENT INVOLVING ACUTELY HAZARDOUS MATERIALS WHICH HAS OCCURRED AT THE FACILITY WITHIN THREE YEARS FROM THE DATE OF THIS RMPP REQUEST. THIS DESCRIPTION SHALL INCLUDE THE UNDERLYING CAUSES OF THE ACCIDENT AND THE MEASURES TAKEN, IF ANY, TO AVOID A RECURRENCE OF A SIMILAR ACCIDENT. A REPORT SPECIFYING THE NATURE, AGE AND CONDITION OF THE EQUIPMENT USED~TO HANDLE ACUTELY HAZARDOUS MATERIALS AT THE FACILITY. INCLUDE SCHEDULES FOR TESTING AND MAINTENANCE OF THIS EQUIPMENT. DESIGN, OPERATING AND MAINTENANCE CONTROLS WHICH MINIMIZE THE RISK OF AN ACCIDENT INVOLVING ACUTELY HAZARDOUS MATERIALS. DETECTION, MONITORING OR AUTOMATIC CONTROL SYSTEMS WHICH MINIMIZE THE POTENTIAL RISKS POSED BY ACUTELY HAZARDOUS MATERIALS ACCIDENTS. IDENTIFY, BY TITLE, ALL PERSONNEL AT THE BUSINESS WHO ARE RESPONSIBLE FOR CARRYING OUT THE SPECIFIC ELEMENTS OF THE RMPP AND A DESCRIPTION OF THEIR RESPECTIVE RESPONSIBILITIES. A DETAILED TRAINING PROGRAM TO INSURE THAT THOSE PERSONS ARE ABLE TO IMPLEMENT THE RMPP. AUDITING AND INSPECTION PROGRAMS DESIGNED TO ALLOW THE HANDLER TO CONFIRM THAT THE RISK MANAGEMENT AND PREVENTION PROGRAM IS EFFECTIVELY CARRIED OUT. RECORD KEEPING PROCEDURES FOR THE RISK MANAGEMENT AND PREVENTION PROGRAM. IN RESPONSE TO THE FINDINGS OF THE RISK ANALYSIS, ADDITIONAL STEPS TO BE TAKEN BY THE BUSINESS IN ORDER TO REDUCE THE RISK OF AN ACCIDENT INVOLVING ACUTELY HAZARDOUS MATERIALS. THESE ACTIONS MAY INCLUDE ANY OF THE FOLLOWING: INSTALLATION oF~ALARM, DETECTION, MONITORING OR AUTOMATIC CONTROL DEVICES. EQUIPMENT MODIFICATIONS, REPAIRS OR ADDITIONS. CHANGES IN THE OPERATIONS, PROCEDURES, MAINTENANCE SCHEDULES OR FACILITY DESIGN. THE ACUTELY HAZARDOUS MATERIALS HANDLER SHALL REVIEW THE RISK MANAGEMENT AND PREVENTION PROGRAM AND SHALL MAKE NECESSARY REVISIONS TO THE RMPP AT LEAST EVERY THREE YEARS. REVISIONS SHALL BE MADE WITHIN 60 DAYS FOLLOWING A MODIFICATION WHICH WOULD MATERIALLY AFFECT THE HANDLING OF AN ACUTELY HAZARDOUS MATERIAL. The California Health and Safety Code provides businesses 12 months, from the date of request, to complete and implement a RMPP. The Risk Management and Prevention Program must be certified as complete by a qualified preparer and the facility operator. It usually takes a business several months to locate a qualified company or individual to prepare the RMPP. It then takes several more months to complete the plan and the review by this Administering Agency. The attached questionnaire regarding the qualifications of the RMPP preparer should be submitted to this Agency by November 15, 1991. 'Upon approval of the RMPP preparer, we will agree to a schedule for the completion of the hazard evaluation and RMPP. The finished RMPP for the sulfuric acid will be due on August 13, 1992. Ail submittals regarding this RMPP shall be made to: Bakersfield Fire Department 2130 G Street Bakersfield, CA 93301 The City of Bakersfield charges $45.00 per hour for the review of Risk Management and Prevention Programs. Time spent conducting site inspections, reviewing hazard, risk and consequence analyses and meeting with company officials or consultants will also be billed at this rate. Upon completion of your Risk Management and Prevention Program, you will be billed for the time that Bakersfield Fire Department Personnel have spent reviewing the project. If I can be of any assistance, please call me at 326-3979. Sincerely, Barbara Brenner Hazardous Materials Planning Technician cc: Ralph Huey L-J BIOTECHNOLOGY CONTRIBUTING TO FOOD, HEALTH AND THE ENVIRONMENT RECEIVED August 6, 1991 JklJ~ 0 9 1991 HAZ. MAT. DIV. Bakersfield City Fire Department Ms. Barbara Brenner 2130 G Street Bakersfield, California 93301 Dear Ms. Brenner: Attached, please find the completed facility information questionnaire regarding our storage, handling and use of Sulfuric Acid. If you should have any questions concerning our response please contact me at your earliest convenience. Sincerely, bert F. Deedy / Plant Manager~ RFD/sc cc: Ralph Huey Mike Del Vecch~o Gene Corrigan Gist-brocades Food Ingredients Inc. 5455 District Blvd. Bakersfield, CA 93313 (805) 834-1050 Fax (805) 834-6212 CITY of BAKERSFIELD "WE CARE'-~ P.'ECEIVED F~R~ DEPARTMENT _ J U L S.D. JOHNSON Jul~25,1991 BAKERSFIELD, 93301 FIRE CHIEF 326-3911 Mr. Robert Deedy Gist-brocades Food Ingredients Inc. 5455 District Blvd. Bakersfield, CA 93313 Mr. Deedy: Enclosed is a facility information form which must be completed regarding the use of sulfuric acid at the Gist-brocades plant. This form will be used in determining, whether a Risk Management and Prevention Plan will be required for the use and handling of this acutely hazardous material. Please return the completed questionnaire to 2130 G Street Bakersfield, 93301 before August 26, 1991. Please call me at 326-3979 if you have any questions. Sincerely, Barbara Brenner Hazardous Materials Planning Technician cc: Ralph Huey RECEIVED 0 9 !991 FACILITY INFORMATION FORM HAZ. MAT. Please answer each of the'following questions by circling Y (yes) or N (no). 1. Is any acutely hazardous material (AHM) . ._.~.~-~ ..... manufactured or used in a chemical reaction ~ Y 2. Is any other flammable gas, flammable liquid or explosive material manufactured or used in a chemical reaction ? Y / 3. -Is any reaction in question 1 or 2 a moderately or highly exothermic reaction ( e.g. alkylation esterfication, oxidation, nitration, polymerization /vA or condensation) or one involving electrolysis ? Y 4. Can any unplanned release of a AHM to the atmosphere result from the malfunction of any scrubbing, treatment or neutralization system or the discharge of a relief system ~ v ~ pressure 5. Does any physical or chemical process in which an AHM is produced or used involve a batch process ?~/ N 6. Does any physical or chemical process involve the production or use of any AHM at a pressure in excess of 15 psig ? ~J/ N 7. In excess of 275 psig ~ Y /~ 8. Does any physical or chemical process involve the production or use of an AHM at a temperature above 125 degrees F ~ Y ( N~ 9. In excess of 250 degrees ? Y /~ 10. Can any explosive dust be present in any closed container within 100 feet of an AHM or otherwise be present in the same building as an. AHM ~ Y /~ 11. Is there any ignition source or open flame within 100 ft. of any process, storage or transfer area where a flammable or explosive AHM is present , except where there is a firewall providing protection ? Y 12. Is any lined or non-metallic pipe used in the transfer of any AHM ~ Y ~_~ 13. Is any equipment or piping-handling any AHM more 10 years old ? Y / PLEASE PROVIDE THE FOLLOWING INFORMATION--"': ( Attach additional pages if necessarl;). 1. Your'company's current workers compensation experience modification factor. .690 2. How many people occupy the building in which AHM's are used or stored ? 0 (outside storage) 3. Give details of all accidents which involved any hazaudous material and all other instances when the fire department has been summoned in an emergency. - 6/14/91 the fire department responded to a small fire in one of the yeast centrifuges. The fire was extinguished by our operator .' The fire department was called as'a precautionary measure. 4. Briefly described the operations process at your plant and the specific processes utilizing AHM's, including storage proceedures. The sulfuric acis is stored .adjacent to the south wall of the manufacturing building in a 700 gallon stain]ess steel tank. Sulfuric acid is used to lower the pH in the cream yeast to inhibit bacteria] growth. To operate the system the acid v]ave-on the stora.ge tank is opened allowing the. pressure pot feeder to fill to the desired. ]eve]. The storage tank valve is closed the pot feeder discharge valve is opened to the appropriate destination then air pressure is applied to the pot feeder and the acid is forced out the discharge. When all the acid is discharged the air is shut off and the pot feeder discharge is shut. The pot' feeder is equipped with a vent and an overflow as we]] as a pressure relief which all return to the storage tank. 5. Briefly describe-the equipmsn%, being used in the processes involvin~ AkkMs. There is a 700 gallon stainless steel vented tank. The vent is piped directly to a drain which is connected to our waste water storage system. All process piping is Schedule 10 stainless steel welded pipe. The pot feeder is a rated pressure vessel capable of holding approximately 16 gallons. The feeder is equipped with a pressure relief valve set at 30' psi which relieves back to the storage tank. The air supply to the pot feeder is equipped with an air pressure regulator set at (25 P.S.I.). 6. Report quantity of A}hq(s), referenced in the cover letter, that this business handles. ~axzmum amount on hand a% any one time. 500 ga]]0ns % ~~;~ 96% (non-fuming) b) Please a~ach a Ma~eriai Safety Data Sheet for any material that is a mixture. Do include MSDS for pure substances. DEMOGRAPHIC DATA: State the straight line distance in feet between the '~usiness property tine and each of the following. 1. Nearest school. 5650 feet 2. Neares~ daycare center, hospital, nursing home or similar facility. 1954 3.' Nearest residence/motel etc. 2006 4. Nearest occupied building. - 3 Business Name: Gist-brocades Food Ingredients, Inc. Address: 5455 District Blvd. Bakersfield, California 93313 I certify that the foregoing information is true and '- correct to ~knowledge. Signature: ~2~/~ Title: .plant. Manager / Date:..~///_ . ....... GIST-BROCADES, PLANT, ........... r~ STOCKDALE HWY ~~ UJ W ~j UJ CSUB cc ~ ~ ~ GIST-BRO ~ADES ~1~ LN PACHECO RD ~ PANAMA LN z HoSKING AVE LEGEND ~ ~ ~ - School ~ - Nearest Res~ence ~ Fire Station : ~ - Pro~sed School ~ - Hosp~al 1 Mile = 1 Inch FIGURE Xlil-3 - Map showing the sens~ive ~pulation sites near the Gist-Brocades plant on Distri~ Bird, Gist-brocades Food Ingredients inc./RMPP/October, 1989/Page Xlll-9 Luft Environmental Consulting TABLE XlII-1 GIST-BROCADES' PLANT SENSITIVE! POPULATION SITES APPROXIMATE DISTANCE CRITICAL SITE FROM PLANT WiND DIRECTION (Miles) (Wind From) Nearest Residence 0.38 South or Northwest Nearest Hospital 0.37 South Nearest School 1.07 Southwest Nearest Fire Station 2.13 Southeast Gist-brocades Food Ingredients Inc./RMPP/October, 1989/Page Xlll-10 Luft Environmental. Consulting ' ODUO 'SAF T D ICAClD ' SU~URIC'AQtD 8U~URIC ACiD Synonym: ba~e~ scm ~BNE~L OHEMIOAL OORPORATIO N Pamf~ny, N J. Man~eret Pmdum Safety (201) S15-1~0. : du~, 1980 May, 1090 (800) ~1-~0~0 ~lN OR GYG~; Imm~dime~y f~u~h wS~h ~lon:y ~f water ~nliAvIng for ~t lea~ 15 mlnv~e~. R~mew ~mmmin~t~ clmhin~ while waghing, C~nlim,e ~)y~hing whh ~ medial a~ntbn is not immedlate~ available, INGES~ON; Do not induce romping. If ~nscleus, give sever~[ glasses~ot milk (prefe~ed) or ws~r. INNA~ON~ Ramuvu tu h~h ~it. Ob~ucvu luf ~sibl$ ~$1~yed reamion. If breathing has stud. give roopimtion, ff bromhing with dilfiou~y~ give exygen, prwIded ~ qu~l~led eperater [= HEAL~ [nh~latien of fumes or ~d mlst can c~use Irr[t~Uon or ~rrosNe burns to the ugper respim~o~ system, including nose, Oan C~u~mirr~nt~n and corra~i~a burn~ to mauth, throm, ~nd otom~oh. Can ba fm~l tf ~Ea~a to dilute solut~ns: LD ~ (r~t): 2~ 40 mg~g .- Referenc~ 0an cause: ~ev~t$ burns.. L~u~ ~nt~ct c~0 cauae irr~atbn, corneal burns, and conjunctNM~, Olindne~, m~y ~ult, or ~eYere or ~rm~n,m inju~. Mist mnt~ m~y irdtale or burn, Reference (~),' ' ~f~4 1 mgtm3 (~9 H~O ~ (O~HA) TLV: aamm(ACGIH) IDLH 8o mg/m ~ Non,. I ~ m '1 I II . ._ ~) Ems~n'of t~eth~ (~)lesbns of the skin, (3) tracheo,bronchffls, (4} mesh intlemmatbn~ (5)~njuR~,vib,~ (~) RE AJ~3 E×Pt.O~ION ................ ~ LOWFrl, Noloppi~blo ' gPP~- F~mm~l* ~ ~tentialJy exptosNe hydre~en gas c~n be gener~ted*JnaJde met3{ drums and slo~ge, tan~, ~n~nt[~ted ~ lfl~d In ~.flre~ u~w~ter. ~r~yl ~v~.~rAyin~ w~,~ ~nt~ ~nt~ln~r~: ~ ~Jy a ~m~il amount of ~mbustible, Is present, ~her tlrew~h nat u~e ~j~ w~ter stream, near ruptured t~nks or ~¢~i11~ ~! ~lJIftltl~ ;reid, A~ld t~aul~ vlululltly wilh w~t~r ~nd ~n ~ on~'~e~nnel, m~y ~q~Jre 'm~hant~a[' exhaust ~y~tems. ~rrosIon.pr~J~ns~ruc~on r~mmended.U~ V~II~ sytl~ma h~) ~m,f~u~m~ u~ In the ete~ren~ [ndust~. ~ get In eye~, on s~q~ an~m~ng. Do,n~t breath~ ya~r o.r ml~:~ ~,? prm~?e eqv~pmen~ ?utl~q~d In ~em~q,b, ~t~uros wRh ~n; U~a, on~ w~h ade~f ventilation, ,, .. , P~-irJm ehyJNN.~m~g~, ~t~,~ ~- ~[, w~il_wntJl~t.H ara~ away {rom ~mbustibles and rea~lve chem~als. Keep o~ of k._ ~un ~ ~a~ i~m hca. Kee~ ~ntainara u~dght. No smo~ing. Jn storBge D~,? Im~ s~lle or le~ ca~ous~ w~h ~emy of water, Neutm[ize. resWue w~h ~lk~li such ~s sod~ ~sh or lime. ~nt~latlen ~ r~uired f~r ~* ~h du~ to faience d~ CO~ ~a4. (Sea So.ion I fo~ dis~l meth~s), Ho smoking in ~piJi ~ro6, A~:IO. ~ O~ Ot oow~h ~y mJ~tt tg, lht tnvir~nm~ ot th~ pr~u~ may be ~ubJ~ to F~em{ ~nd~r stat~ mqulrem~. C~ w~ ~pr ate ag;hems. ~¢~p~~~~L ~f~s SIGNAL WORD. DANGERI ~*~ e~U~:~ul~; F~ ~r~lng 91~ ~les~ u~J ru~er prot~ive. a~r~ In metal ~mJlnem, v~ri can ~m~in exp~Ne, hydroge~ ....... ~EE PAGE S; ~EEPAGE:$, LIQUID ~ BOLID l"'I.. Oll'f, oolorl.(~o to ol~htl7 y011ow, oiler to turb~ liquid. Odorlloo~ ~;CI;~ ~II~Vl'~ ' ' ~O~LIN'~ i~<SiNI' ................ ~0X: ~'t~ '~'O ~':'~ ......... ~'~ ............ ~ .................... ~,~--,~ F~ ~%. 1,~2 N~ ~mplete. l%.~l~n: pH = Temperatures e~ 3~ d~. C er higher; yle~ suEur trl~e ~ UNSTABLE ~ STABLE ' g~, wh~b t~ t~x~, N~m mm~u~, ca~e~, ~lene~. a~l~ (whenhe~ted3: cause e=iosionl Suffur tr~x~e g~s: see ~ye. Also tbI~ Is a fire. rI~ ~ In ~nte~ w~h [;3 MAY OCCUR ~ WILL NOT OCCURI NA HQT APPI,,ICAI~I.~ · .~:... .... ,.,: ..... ,. ....... ~, ,,.,.,:,., ~:, .~.: ,. ...... · . ~.-.:.... ...... ~ · .,~ .... .pi~iqlITAI~Y:,?I~IIICI!T'- EPA HaZardous W~ze No, DO0~ (~rro~lve) J ;11 ~HA, Z.L~h Z~ CFR 1~10.1000 (Ruvi~u~ 19~91 (~) A~IH 1989-9g U~h "Thr~held Mm~ V~lue~ for Ch~mic~t A~.'~nf, ¢t Qov~rnm.nt~I industrial Hyg!enist~, Oincinnmi 4S20~, DOT ID Number: UN 1830, D,O.T. H~ir~ul M~terlali Table 4g CFR 172,1ol ~) N~S~ flmgl~try~f ~oxl~ E~fe~gl,¢,h~l~I ~ubst~ncos, 1982.~. A~asslon ~WS 5~ Od dad, P~a t.1~7;, N~. Tach.into. 5e~me, ~prlnGl[eld, VA 22161, (c) 'Cf Reda for a Re.remanded S~and~rd...Occupa[Ional Ex~su~e to Su~ur~ Acid', NIOSH U,S, gept, of HHS, 1974~ PB23309& Nat, Tach. Into, Se~ice, Springfield, VA 22151. J, REFERENC~ - General (~ntlnued) (d) N~SH~8~A, "P~et Gu~ t~ Chemical H~erda,.,", September, 1 g85. (e) 'NIO~SHA -- ~up~t~nal Health ~u{delines ~or Chemical Haz~rde - ~u~urlc AGfa", 1978. {t) Alllad. Chem~al TechnlcN Se~ice R~ for storage and hnndting prac~uren. {g) NFPA Manual 491 M, 'Manu~l of Haz3rdaus Chemic&l Reactions, 1g~7 Nat. Flr~ Pratemion ~aoc,, Bo~on 02210. (h) Br~her~ L, Handbook of Reamlve Chemical Hazarda, 3rd Ed., lg85 8utte~o~hs, O. R~C~VI~ DATA - lnaomp~tlblllty (continued) Alkalis, smines, ~ater, hydrated sees, csr~xytlc said ~nhydrldes, nitrll~s, oleflnl~ ~rg~nlcs, gly~ls, aqueous ~c~a: - Rafs, (h), Aisc lot metalS, tee nyorogen generation, Sim on O. ; : .' k'JR;;'ql::l,J,. /,Rqft ,C'T,,'.R PO,,~ qTb,:Rl',l -I'"11 ',"lq.q q'-l,'-;,q-lA -]NnR,q-lH, l:Cl'f 'g,'E,:RT TH I TI",, q~ -Fir t. HEA'¢Y HANDLING 2.. SPECIALIZED. H~DLING' (on~ ~ble. ~en u~: the c~ yentl~at~n' syitem medina, on p~ 2): Rilpl~tory ~o~on. Where ~qvir~, u~* a ms,rarer ~roy~ ~ N]OSH for su~ur~ ~td. E m~ ~ve 1 mg H~SO~/wear:  aM mi~k w~h -~ ~a~ ~n~ter a~ a~ w~h ~~r ~pli~Or; (G) ~her c~ice3, R~era~e (~). H~DLING - Re~r~ Eymm mncl FlOe: Eye= and Aa: a:: minimum, wear hat, d3emic~ ~a~ety goggle~, A~ et minimum, ~ety Glad, em w~th ~n~dor~t~ ~ len~m. ~ .... le~ o¢ O'piil-ir-~har-ama~enw,-~e,~hem~t-~ ~t~y H,ind~, A~m,, and 8m:ly Hands, Arm,, mhd Bady 0~, ~ ~' g~ves t~ ro~ine p~u~ u~e. For la~ ar spill: 6~ ~ir t~, ~G ~Ull For ~mmmmd. ~i~n, In~tu~e ~d .... ~-',-~ or~lwc~hi~(~ee ~e ~e under 1. HEA~ t~u~e~ i~ t~ H~BLiH~ - Hands, ~m~, ~nd ~y~'. -- CITY! of BAKERSFIELD FIRE DEPARTMENT April 25, L99 i 2101 H STREET D. S. NEEDHAM BAKERSFIELD· 93301. . . FIRE CHIEF ,. . ....... 326-3911 Mr. Richard Ewing Level Technologies, Ltd~ P.O. Box 41088 Bakersfi,eid, CA 93384 Dear Mr. Ewing,. I have completed review of your response to my request for additional in~qrmation on the Gist ammonia tank instaiiation' nce~ like to clarify the requirement regarding welded fittings, on the lines which carry anhydrous ammonia. Liquid anhydrous ammonia is by definition a compressed gas. I have included a copy of this Fire Code definition for your reference. The type of containment which exempts a.gas from welded or brazed fittings is an exhausted enclosure vented to a treatment system. Liquid spill control containment does not exempt anhydrous ammonia piping from this requirement. Liquified anhydrous ammonia will return to the gaseous state before it is contained by the spill control drainage basin. This project will be required to comply with the requirements of Section 80.4011c) of the Uniform Fire Code, welded or brazed fittihgs throughout, unless the containment meets that required for a tOxic gas. The use of a fence to provide security and protection from vehicular damage will be acceptable if the posts which hold the fence meet the standards'outlined in Section 80.301(w) of the ·Fire Code. Every 4 feet, a post of' a't least 4" diameter shall be concrete filled and set in a concrete footing. Please refer to my · letter dated 3-21-91 for the. specific requirements. The other items outlined in your response are satisfactory. With the inclusion of the conditions stated above, this proj'ect has been approved by' the Bakersfield Fire .:Department, Hazardous Materials Division. If you have any questions, please call me a% 326-3979. Sincerely, Barbara Brenner' Hazardous Materials Planning Technician cc: Ralph Huey % · ologies, Ltd. TO: Barbara Brenner Hazardous Materials Planning Technician 2101H Street Bakersfield, Ca 93301 Dear Ms. Barbara Brenner, This letter is in reference to your request for additional information regarding the GIST BROCADES anhydrous ammonia project. 1. Protection of tank from collision with vehicles. Gist Brocades will be installing a fence around the Anhydrous tank area with support posts in corners and in front of the tank. 2. Spacing from tank, relief valve discharge, seismic bracing. The nearest building is about 100 ft from the tank (this is a Gist Brocade process building). The property line and street are approximately 200 feet from the tank. The relief valve on the tank is an emergency relief valve designed for fire case open to atmosphere. Gist Brocades will put a rupture disk on the valve to guard against leakage. It is not practical to contain these gases under emergency conditions. The rest of the relief valves are thermal relief valves whose discharge quantities are very small and shall be scrubbed in the vent tank. The tank is braced for seismic 4 conditions according to building codes. The security for the area will be provided by the fence in item 1. 3. Piping connections, emergency shut of valves. All piping shall be welded fittings ~r screwed .ons with seal welds to prevent escape of toxic except in those areas where containment is available. Containment is available in all cases except where the ammonia line crosses the road after leaving the pump. Shut off valve and excess flow valves are available at the ammonia tank. In addition manual shut off valves are available at the point of use. (805) 589-4330 · Fax (805) 589-8158 6631 Duncan Way · Bakersfield CA 93308 · P.O. Box 41088 Bakersfield,CA 93384 ologies, Ltd. 4. Provide volumes of aqueous ammonia tanks and describe spill control. The volume of the aqueous ammonia tank is about 20,000 gallons. The facility is asphalt paved through out with concrete foundations. All spills are collected in a plant drainage system where it is contained. 5. Label tanks All Tanks are and will be labeled in with accordance code. 6. Underground piping and stainless steel stress corrosion. All underground piping will be inserted in a 4 inch sleeve to mechanically protect it and to minimize galvanic action. In addition the underground piping will be carbon steel with seal weld connections. At the transition to stainless steel piping above ground isolation fittings will be utilized to minimize stress corrosion. Level Technology hopes that the above additional information addresses your concerns adequately. We have included with this letter a complete set of plans for your inspection. If you should have any further questions please call Mr. Richard Ewing at 805-589-4330. Sincerely, ~ V. Richard Ewing cc Ashok Pandya Bob Chance (805) 589-4330 · Fax (805) 589-8158 6631 Duncan Way · Bakersfield CA 93308 · P.O. Box 41088 Bakersfield,CA 93384 FIRE DEPARTMENT 2101 H STREET D. S. NEEDHAM BAKERSFIELD, 93301 May 9, 1991 Mr. Richard Ewing Level Technologies, L'td. P.O. Box 4i088 ........... Bakersfield, CA 93384 Dear Mr. Ewing, The roi±owing information is a confirmanion of our phone Conversations regarding the inmtallation of the ammonia system an Gist-brocades' plant. Secondary containment will not be required around vessels and piping which contain anhydrous ammonia. 'However, the anhydrous ammonia piping must be welded or brazed at all connections. The spill control system which you have described for the aqueous ammonia, collecnion in the plant drainage system, is also adequane. Please. call anytime that I 'can be of assistance. Sincerely, Barbara Brenner Hazardous Materials Planning Technician cc': Ralph Huey i CITY of BAKERSFIELD "_ WE CARE" FIRE DEPARTMENT 2101 H STREET D. S. NEEDHAM .' BAKERSFIELD. 93301 'D FIRE CHIEF March ,..1 ~ 19,91 ....... ~ 326-3911 ivir. Richard Ewing Engineer LiqUid Level Technologies~ Inc. 663'1 Duncan Way Bakersfield. CA 93308 Mr. Ewing: The Bakersfield Fire Department Hazardous Materials and Fire Safety Control Divisions have reviewed tl~e clans sumaitted for tine anhydrous ammonia storage tarlK and mixinq r-e, actor 'to ~e located at the Gist-~rbcades ~ian~. Addi~ionai info~masion ~ill ~e necessary to verify compliance Nith Article 80 of the Uniform Fire Code Sections. I have included the text of earn section for your convenience. · ~ The annvd~ous ammonia storage tank must fr-om ool'li~ion form ~O.SOl(~) Protectiom from Vehicles. Guard other means shall De Drovided to mrotec5 storage tanks from velqicular, damage, b~hen guard Dosts are installe~, the posts shall be: t. Cons%~ucted of' s~eel not less nnan diame~e~ and concrete filled. 2. S~aced ~o~ mo~e than 4 ~eet bes~,~een ~osss on cente~. J. Set mot less than J feet deed 'Li"~ a concrese foo~i'ng of not less than !5-inch 4. Set Nith the top, of the posts no5 tess 'tham ~eet above g~oumd~ amd 5. Located not less th~m 5 feet fo~rn the tank. ~ Please m'tate ~hat the distances ~ill be between exDosu~es and the anhydrous ammoDia sto~age tank. HOw ~ill ~eleases ~om the ~essure ~elie{ valves ~ t~ated sc~uDDed? S~ecifv,ho~ the system will De seismically braced'~ 2. Distance from sto'rage to exposure, s'. in .addition to ~lae ~r-ovislons of the gases slqall oomDi~' wit. lq the folio~ing: ~. Distance limi ~ation 'to exposures.. Yhe exgerio~ ':sto/-'age of hi,DJ]iV EO):'iQ C,F- ~,O><iC: compressed gases shall not be within 75 f:eec of a Duilding, ,property lime~ st-feet, alley, publio way or exit to a public way unless the storage is shielaea by a structure having a minimum fire- resistive rating of two tiours and ~Nhich inter~-uot~ · the line of siglat between the storage and the ........... exposure-. The protective structure shall- have--no-t more than two sides at approximately 90-degree directions? except that a third diagonal' section may be used at the' vertex, B. Openings in exposure Buildings. Nhen the storage area is located closed than '75 feet to a building~ openings into a building other than piping shall not be above the height of 'the top of the shielding structure or within 50 feet horizontally form the' storage area whether or not shielded by a protective structure. O. Air intakes. The storage area shall not be within 75 feet of air intakes. 4. Piping and controls. In addition to the requirements of Section 80.~01 (o)? pipil~g and controls on stationary tanks shall be in accordaiace w~tn the following: ~. Pressure-relief devices shall be vented to a treatment system designed in accordance with the provisions of Section 80.501 (a) 6 D. (o) Special Provisions. 1. Seismic proteotloR. Stationary tanRs and associated piping systems shall be seismically braced in accomdance with the provisions of the Buflding' Code. 2. Security. Storage areas shall be secured against unautlaorized entry. m Piping used for 'transmission of toxic gases must be welded or brazed at all connections. Provide details regarding the locations of emergency shutoff valves. / eb.401(c) m.n. pipiing and tubing u~ilized for the \. transmission of highly toxic or toxic material shall '~xhave welded or brazed connections throughout unless an exhausted enclosure is provided if the material im"a ,.~am'~ or ti~e piping is provided with receptor for containment if 'the ma'terial is a liquid. EXCEPTION: Nonmetallic piping ~ith approved connectiOns. D. Readily accessible manual or automatic remotely activated fail-sa~e emergency mlqutoff valves shall be ~ installed on supply piping.and tuOing at the following ,,, locat'ions: (i) ~'t the point of .use. ........... (!-i-i) ~-t-the tanN~ -cylinder .o~ bulR: sour'ce, · * Provide the volumes of the aqueous ammonia storage tanks ~nd the reactor vessel, Indicate how spill control or secondary containment wfll-be provided' o) E×tecior Dispensing and Use. 4'. Spill coNtFoi~ drainage and oontain~ent. B. Closed systems. 'Exterior areas where hazardous materials liquids are used in individual 'tanks containers exceeding 55 gallons shall be provided with a means to control spills. Secondary containment shall be provided if tlqe aggregate of multiple tanks or containers exceeds 1,000 gallons. * Tanks must be appropriately labeled. UFC 80.501 and Bakersfield Miunioipal Oode 15.64.~45 Section 80.~Ol(d) of the Uniform Fire Oode is amended to read: (d) Signage. In addition to the hazardous identification signs ~equi~ed by Section 80.104(e)? stationary aboveground tanks shall be placarded with hazard identification signs as specified in U.F.C. Standard No. 79-~ or with other .labels or siqns approved by the Chief, for the. specific macer~al contained. Signs prohibiting smoking shall be provided in storage areas and within 25 feet of outdoor storage areas. ,Signs shall be in English as a primary language symbols allo~ed by this Code. Signs shall be durable. The size~ color and letteriing shall be in conformance with nationally recognized standards. ('Ord. 5252, Section 15, 1989) * Stainless steel piping will be adequate for the underground transmission of anhydrous ammonia, ~e are concerned that there may be stress corrosion where the stainless is 3oined to the carbon steel, Please comment on the measures taken to prevent stress corrosion or note w~y it is not e×peoted to be a problem,' ~;~_~o o~- ¢~ Please subt~it the plans or in¢ommation whio~ desoribe the methods om equipment ~hich ~ilt be used to ¢ui¢i1~ t~ese oode seotions. Please oall .me at 326-3979 if you have any questions. Sincerely, Barbara Brenner· Hazardous Materials Planning Technioian do: Raluh Huey AU(; 0 8 1991 - HAZ. MAT. DIV. August 6, 1991 Bakersfield City Fire Department Ms. Barbara Brenner 2130 G Street Bakersfield, California 93301 Dear Ms. Brenner: Attached, please find the completed facility information questionnaire regarding our storage, handling and use of Sulfuric Acid. If you should have any questions concerning our response please contact me at your earliest convenience. Sincerely, RFD/sc ~/~ cc: Ralph Huey Mike Del Vecch~o Gene Corrigan Gist-brocades Food Ingredients Inc.. 5455 District Blvd. Bakersfield, CA 93313 (805) 834-1050 Fax (805) 834-6212 CITY of BAKERSFIELD ~ "WE CARE" FIRE DEPARTMENi- 2101 H STREET S. D. JOHNSON July' 25,. 1991 BAKERSFIELD, 93301 FIRE CHIEF 326-3911 Mr.'Robert Deedy Gist-brocades Food Ingredients Inc. 5455 District Blvd. Bakersfield, CA 93313 Mr.. Deedy: Enclosed is a facility information form which must be completed regarding the use of sulfuric acid at the Gist-brocades plant. This form will be used in determining whether a Risk Management and Prevention Plan will be required for the use and' handling of this ~cukely hazardous material. Please return the completed questionnaire to 2130 G Street Bakersfield, 93301 before August 26, 1991. Please call me at 326-3979 if you have any questions. Sincerely, Barbara Brenner Hazardous Materials Planning Technician cc: Ralph' Huey FIRE DEPARTrvlENT 2101 H STREET D, S. NEEDHAM JLlly 17 · 19 9 1 BAKERSFIELD, 93301 FIRE CHIEF 326-3911 Mr.'Robert Deedy Gist-brocades Food Ingredients Inc. 5455 District Blvd. Bakersfield, CA 93313 Mr. Deedy: ~ As of July 1,'1991, the-City of Bakersfield has instituted a fee of. $45.00 per hour for the review of Risk Management and Prevention Programs. Time spent conducting site inspections· reviewing hazard, risk and consequence analyses and meeting with company officials or consultants will also be billed at this rate. Upon completion of your Risk Management. and Prevention Program· you will be billed for the time that Bakersfield Fire Department personnel have spent, reviewing'the project. If you have an~ questions regarding this policy· pleaSe call;me at 326-3979. Sincerely, Barbara Brenner Hazardous Materials Planning Technician cc: Ralph Huey · ~i :- "WE CARE" FIRE DEPARTMENT May 9, 1991 2101 H STREET D. S. NEEDHAM BAKERSFIELD, 93301 FIRE CHIEF Mr. Richard Ewing, Engineer Level Technologies, Inc. P.O. Box 41088 Bakersfield, CA 93384 Dear Mr. Ewing, The Bakersfield Fire Department Hazardous Materials and Fire Safety Control Divisions have completed review of the plans submitted for the anhydrous ammonia storage tank to be located at the Gist-brocades facility at 5455 District Blvd. These plans have been approved regarding their compliance with the 1988 Uniform Fire Code. Gist-brocades is responsible for the completion of a Risk Management and Prevention Program (RMPP) prior to the beginning of ammonia storage and dilution. Gist-brocades staff inform us that Luft Environmental Consulting will prepare the RMPP. Within 30 days of receipt of the anhydrous ammonia G~st-brocades will need to amend their hazardous materials inventory to include the anhydrous ammonia. At this time, all Fire Code and hazardous materials regulations have been adequately addressed. We appreciate your cooperation and Gist-brocsdes commitment to safety. Sincerely. ~/. Hazardous Materials Coordinator Fire Marshall- cc: Mike Quon Ashok Pandya CITY of. BAKERSFIELD FI~E DEPA~ENT 2~0: ~ STREET D. S. NEE~AM BAKERSFIELD, 93301 FIRE CHIEF 326-3911 January 7, 1991 Mr. Lloyd Fry Maintenance Engineer 5455 District Blvd. Bakersfield, CA 93313: Dea~ Mr. Fry: Thank you for your prompt response to my letter of 12/20/90. The implementation schedule which you have proposed for the installation of the chlorine cylinder tie down system and the chlorine handling training is satisfactory. I will need to make a brief inspection upon completion of the tie down installation to verify c.ompliance with the RMPP .... Please call me when the work is complete so that we may schedule a time for the follow up inspection. Sincerely, Barbara Brenner Hazardous Materials Planning Technician THE ENVIRONMENTBIOTECHNOLOGY CONTR BUTING TO FOOD L H RECEIVED 0 3 1991 December 27, 1990 HA7 ~4AT'. DIV. City of Bakersfield Ms. Barbara Brenner 2101 H Street Bakersfield, California 93301 Dear Ms. Brenner: To address your concerns listed as deficiencies in your letter of 12/20/90, I offer the following: The hold down system for the chlorine cylinders has been purchased and will consist of 2 polyester straps per cylinder. Each is rated at 1,000 lbs, and will be anchored into the concrete foundation at 4 points. The expected completion date for installation is 1/4/91 with my assurance that it will be completed with no excuses by 1/31/91. All aspects of chlorine handlings, both emergency and routine, will be covered on 1/31/91 and is scheduled for every February thereafter with a list of attendees and areas covered kept on record. I appreciate your being prepared with list in hand and knowledge of the system being inspected. I believe thi:~ is a valuable use of my time in keeping both the workplace and community safe so feel'free to call me anytime you have any concerns regarding our operation here. It has been a pleasure working together on this and hopefully we will enjoy continued cooperation on future projects. Sincerely, L1 oyd Fry Maintenance Engifleer LF/sc cc: Bob Deedy Gist-brocades Food Ingredients Inc. 5455 District Blvd. Bakersfield, CA 93313 (805) 834-1050 Fax (805) 834-6212 CITY of BAKERSFIELD F[RE DEPARTMENT 2101 H STREET S. NEEDHAM BAKERSFIELD· 93301 FIRE CHIEP 326-3911 December 20, 1990 Mr. Lloyd Frye Gist-brocades Food Ingredients, Inc. 5455 District Boulevard Bakersfield, CA 93313 Mr. Frye: The inspection conducted on December 18, 1990 regsrding implementation o~ the Risk Management and Prevention Program revealed thst the proposed quick release tie down mechanism for the chlorine cylinders hms not yet been installed. The law allows one year for the implementstion of Risk Management Plans, so this installation is .now overdue. The only other eras of deficiency which I noted was the failure to provide refresher training for use of the chlorine patch kit and reiteration of proper chlorine handling procedures. It is most important that ~employees are well trained should they ever be called upon to respond to a leaking cylinder. Please document these training sessions when you hold them so that there will be s record to verify adequate response training. Overall the inspection was quite sstisiactory. .Please submit s schedule for the installation of the. tie downs and by January 18, 1991. Please include a note regarding the ~requency which you propose for the repetition of chlorine handling procedures and leak response training. Thank you for all oi your cooperation in this matter. Please call me at 326-3979 anytime that I can be o~ assistance. Sincerely, Barbmrs Brenner Hazardous Materials Planninq'Technlcman December lg~ 1990 Chlorine System Verify inventory. (400~ lbs. ). (Sec. 4)~ ..... ~ ~o° ~ Is vacuum f~d x~egulator securely attache~ using yoke clamp ? (Sec, 4) ~ Is ammonium hydroxide available to check for fitting le~aks ? ( Sec. 6 ) q · 4, Has the quick release tie 'down system been installed ? 5. Is the procedure of closing the 'valve on the online chlorine container~ while loading and unloading containers~ bei, ng implemented. (Sec. 14) Safety Equipment Is the chlorine response kit B available and ready for use 2. Is protective clothing available ? (Sec. 14)~' ~ .' ~, Verify location and avsilability of respirators cylinders for escape)and ~CBA (3). (Sec. 6) 4. Verify locations ~f the three fire hose houses. (Sec. 6~ Documentation of training Have evacuation drills been conducted ? (Sec. ll) 2. Are equipment manuals available for employee use in the maintenance engineer's office ? (SecolO) Are MSDS maintained and available to employees ?~ Are employees trained to use the ~CBA ? 4. Has safety training been documented ? (Sec. 5) Is refresher training on SCBA and chlorine plug/patch conducted ? ~q¢~ ~ PAGE Maintenance 1. Are chlorine residual data logged to establish normal operation baseline ~or the system ? (Sec. 5) .2. Are maintenance records documented ? (Sec. 5) Releases 1.~Have there been any releases or accidents since submittal of the RMPP ? (Sec. 4) CITY of BAKERSFIELD "WE CARE" FIRE DEPARTMENT 2101 H STREET D. S. NEEDHAM BAKERSFIELD, 93301 FIRE CHIEF 326-3911 November Mr. Karl Luff Luff Environmental Consulting 3701 Pegasus Drive, Suite 121 Bakersfield, 08 93301 Mr. Luff: Luff Environmental Consulting has been accepted by the Bakersfield Fire Department as qualified to prepare the Risk Management and Prevention Program for 6ist-brocades anhydrous ammonia system. The plan for the risk analysis will be accepted with the following modifications. Due to the accuracy limitations of %he Cameo II-hloha vapor dispersion model, by a factor of 2, we request %hat the air modeling be performed using the rural terrain setting, This agency is also standardizing the concentrations to be used for modeling. The IOLH (500 ppm) and the LOC (50 ppm) are the concentration levels which we now require for vapor dispersion modeling of ammonia. Item number 3 in your plan for the risk analysis indicates that modeling of chlorine releases is to be included. Sases that are heavier than air must be modeled using a dense gas dispersion model. Next week i expect to have Bakersfield Fire's Guidance for RMPP Preparation completed, I will be sure to send you a copy as soon as it is available. Ralph Huey will not be handling the review of this RMPP, so please direct all correspondence to my attention. Because a RMPP must be accepted prior to the operation of Gis't-brocades~ new anhydrous ammonia system, there will be no formal schedule for completion. However, I do need ~o know what 'the proposed date of completion is for this project. Please call me whenever I can be of assistance. Sincerely, Barbara Brenner Hazardous Ma'teriai~ Planning Technician x~-.Q~--~/~m..,¢,~ ~/ ~;~~Z~S (' x~Y~~ ~ October I, i990 FiRE OEP,a, RTblENT 2101 H STREET D S NEEDHAM BAKERSFIELD 93301 FIRE CHIEF 326-39~ i A~hok Pandya, Project Engineer Gist-Brocades 5455 DistriCt Blvd. Bakersfield, CA 93313 Dear Mr. Pandya: We have .reviewed your proposal for installation of a 15,000 gallon Anhydrous Ammonia Storage Tank at Gist-Brocades, 5455 District Blvd. As discussed in our meeting 9-26-90. Anhydrous Ammonia is an Acutely Hazardous Material? Stored in the quantities you have indicated and taking into consideration the proximity to sensitive population this administering agency will require that you submit a Risk Management and Prevention Program (RMPP). This RMPP shall be completed in accordance to Article 2, Section 25531 et. seq. of Chapter 6.95 of the California Health and Safety Code. This RMPP shall be submitted to this Administering Agency and implemented before start up of your facility modification dealing with Anhydrous Ammonia. There will not, however, be any special requirements for public review associated with this RMPP. You will also.be required to meet all applicable sections of the 1988 Uniform Building Code and 1988 Uniform Fire Code with regard to Anhydrous Ammonia Storage and Handling. A review of the 1988 Uniform Fire Code indicated that various sections of Article 74 and Article 80 do apply to this installation, pay particular attention to the spacing requirements of Section 80.303(b). However, the requirements for a diffusion system as outlined in Article 63 of the fire code are not mandatory per the fire code. This may however, be something you want to consider in the hazard and operability study when completing your RMPP. The first step in'the RMPP process is selection of a qualified person to certify the RMPP. I have included a questionnaire regarding the qualification of this person. Once you have selected your qualified individual or company, please have the questionnaire completed and returned to: Bakersfield Fire Department Hazardous Materials Division 2130 G Street Bakersfield, CA 93301 Pa o_.'e Z t-Brocades Cont. So that we may review those qualificanion as soon as possible. It would be advisable for you to co~firm the acceptance of these qualifications before finalizing a contract With any outside firm. If we can be of any further assistance please do .not hesitate to call. Sincerely yours, alph E. Huey azardous Materials' Coordinator Fire Marshall REH/ed Encl. HE ~-i.6 Z~R©-OF'EFih~E~ [ L ! T"r ~ [HE RMPP CERTiFEC6'FiON t) F THE RMRF' The Risk Management and Prevention Program must be cased upon 'the findings of Risk and Consequence 6nflyses compl, eted by a technically qualified team. The Risk ~nalysls or Hazard a.nd Operability study team members should represent a variety Of disciplines reflecting 'the specific processes and materials applications at 'the facility Generally, these teams will include members from the disciplines of: Engineering Health and Safety Maintenance Operations Depending upon complexity of the operations, engineering and maintenance expertise may fail into the areas of Chemlcal mechanical or electrical. The team leader, the responsible party who may certify the document as complete, may be a generailist. However, the team leader must possess sufficient-management ability and expertise to understand the 'various components of 'the Risk hnaiyszs, Hazard Evaluation and Risk Management and Prevention Pmogram. To determine the qualifications of the team it will be necessary to address the following questions: Who will be members of the Hazard and Operability Study Team ? Provide the following information: Name of each member Experience in Hazard and Operability Studies Educational background Process ~xperience 2. Who will be the Haz-Op team ieaoer and what are their qualifications Or training ? 3,. Who will conduct the Consequence ~nalyszs and what are their qualifications or training ? Who will perform quality control for the Hazard and Oper*abili'ty Study and'what are their quaii'fications or training '7 FINE) '?,i'11~ ? The approved team wi~l 'then need t:c, cons.~e~r the i. How do ?'ou p~opc, se equzpmen'~ 2. ~hat externa~ event~ , in addition to an ~ar+hquat~e of S,~ magnitude, do you plan to evaluate as a part of the Hazard and OpepaOiiity S~udy ? What factor5 do you plan to consider when conduciing of and ,;consequence to ~he vulnerable zone. ) Which air model do you plan to use for the dispersion analysis ? 5. What methoaotoQy will be used fop estimation of human error ( operating Who wi!! assign ~he operating error probabilities eno wha% quaiiflcatlons does ~h~s person have for this assignmen~ ? /,,.,~'. ~i~\\..' CITY of BAKERSFIELD h~<~// ~ ~,~:~ F~RE DEPARTMEN~ 210~ H STREET D S NEEDHAM BAKERSFIELD. 93301 FIRE CHIEF 326-391 November 12, 1SS0 Mm. Karl Luf~ Luf~ Environmental Con:ulting 3701 Pegasus Drive ~aker~field, CA S~08 Luff: Enclosed i~ a co~¥ 'of B~ker~field Fire'~ RMPP preparation Guidelines. We have dev~iope~ these in an effor~ to clarify our requirement~ and to avoid confusion r~gardlng acceptable methodology. Please cai1 anytime ~hat ! can be of a~i~tance. Sincerely, BIOTECHNOLOGY CONTBIBUTING TO HEALTH AND THE ENVIRONMENT R-CcIP ' kg[2 o v 3 988 October 18, 1988 Mr. Ralph E. Huey Hazardous Materials Coordinator Hazardous Materials Division 2130 G Street Bakersfield, CA 93301 SIR: Attached is a completed Acutely Hazardous Materials Registration Form (Form HM 377711/15/88] for the chemicals mentioned in your October 13th letter to Bushh Industrial Products Corporation (now, Gist-brocades Food Ingredients). Unfortunately, I cannot provide a competent RisklManagement and Prevention Program (RMPP) on such short notice. To prepare a complete RMPP I will need to meet with our plant safety coordinator and his staff, which I am one, then, the plan will go through the plant manager and finally to our environmental consultant for any final revisions. Since this will take at least a month I would appreciate more lee-way in this submittal. I recommend a deadline of November 30, 1988 for the RMPP. If~you have any questions, ~or comments concerning this letter or the attached form feel free to call me at (805) 834-1050. Our facsimile number is (805) 834-6212. Dirk~ J. Will'rd ./LO~. Process Engineer CC: file ~~ Thoby DeRuyter Lloyd Fry Carl Walker Gist-brocades Food Ingredients Inc. 5455 District Bird Bakersfield, CA 93313 (805) 834-1050 J ACUTELY HAZARDOUS MATERIALS-REGISTRATION FORM THIS FORM MUST BE COMPLETED BY THE OWNER OR OPERATOR OF EACH BUSINESS IN CALIFORNIA WHICH AT ANY TIME HANDLES ANY ACUTELY HAZARDOUS MATERIAL IN QU ~ANTITtES GREATER THAN 500 POUNDS, 55 GALLONS OR 200 CUBIC FEET OF GAS AT STP. l THIS FORM SHALL BE COMPLETED AND SUBMITTED TO YOUR LOCAL ADMINISTERING AGENCY. (§25533 & 25536 Health & Safety Code) Note instructions on reverse Business Name GIST-BROCADES FOOD INGREDIENTS INC. (BAKERSFIELD YEAST PLANT) Business Site Address 5455 DISTRICT BLVD., BAKERSFIELD, ~CALI FORNIA 93313 Business Mailing Address (if different) N/A Business Phone (805) 834-1050 Business Plan Submission Date2 JULY 3, 1987 - ~ __p~ess_~i::~.~.ig~nati_on3- _. _ N/~ ACI. ITE[.Y HAZARDOUS MATERIALS HANDLED4 -USE ADDITIONAL PAGES IF NECESSARY- CHEMICAL NAME QUANTITY CHLORINE (GAS IN 2,000 LBS. PRESSURTZED'CYLI, NDER'S) 4,000 LBS. SULFURIC ACID (77-99 WT% WITH WATER) 700 GALLONS GENERAL DESCRIPTION OF PROCESSES AND PRINCIPAL EQUIPMENTS: ' CHLORINE: USED FOR DESTRUCTION OF ALL .NEGATIVE ~-STATE ORGANISHS IN COOLING TO['IER AND WELL WATER. SULFURIC ACID: USED FOR PH CONTROL IN FERMENTERS. PRINTED NAME DIRK JEFFREY WILLARD DATE OCTOBER 18, 1988 California Office of Emergency Services FORM HM 3777 (1-15-88) INSTRUCTIONS: Superscripts: 1. Quantifies for RMPP compliance are "equal to or greater than" thc minimum criteria and apply to chemicals handled "at any one time". 2. Businesses handling reportable quantifies of Acutely I-laT.~rdous M~terials that have not submitted a business plan MUST contact local Administering Agencies. The business plan submission ..date-will assure the Administering Agency that a business plan has ~ submitted and is on file. This will also immediately identify businesses that . have not submitted business plans ....... 3. "Process Designation" is provided as a reporting option (with the approval of the Administering Agency) for facilities that can most easily report by process. Thus, facility RMPP registration data could be submitted in a similar format to a business plan that is divided by process. "By process" data can initiate an emergency respons~ to a process incident rather than a general emergency response to a major facility. Process designation can simplify inspections for major facilities and improve fumm emergency response. - ~ 4. Refer to the EPA list'of EXtremely HaTardous SubstanCes from the Federal Register (Volume 52, No. 77,~p~ ~3397 et_ seq,, April 22, 1987). Each chemical has a threshold planning quantity. This list may be changed by EPA on an annual basis. Updates of this list may be available early in 1988. To comply with this element, you may attach a copy of the inventory submitted to your Administering Agency from your business plan and highlight all Acutely Hazardous Materi_sl.~ It is recommended that facilities list all extremely ba:,ardous chemicals handled in quantities equal to or in excess of 1) 500 pounds,and 2) any EPA threshold planning quantity less.than 500 pounds. 5. Do not include Trade Secret information in these descriptions ..... General: For emergency response purposes, it would be desirable to describe the following to the Administering Agency: 1'. Batch Process: a. What raw materials? b. What operating pressure range? c. What opemdng tempemmre range? d. Batch capacity rating? e. Product characteristics?' (e.g., chemical state, flammability, toxicity, etc.) f. Critical process points and characteristics? 2. Continuous process: (similar information as above.) :NOTE: "Pursuant to §25534, the Administering Agency may require the submission of a Risk Management Prevetttion Program (RMPP), if the Administering Agency'deteannines that the handler's operation may pre~. nt an acutely l~n?ardous materials accident risk. The handler shalYpmpam the RMPP in accordance with subdivision (c) [of §25534]. The RMPP shall be prepared within 12 months following the request made by the Administering Agency pursuant to this section." (§ 25534 (a).Health and Safety Code) An amendment to the RMPP must be submitmd to the Administering Agency within 30 days of: 1. Any additional handling of acutely hazardous materials. 2. Any material or substantial alterations to business activities. 3. Change of address, business ownership, or business name. (§ 25533 (c) Health & Safety Code) · EVERY BUSINESS REQUIRED TO SUBMIT AN RMPP'SHALL-1MPLEMENT THE APPROVED RMPP California Office of Eme~ency Services FORM HM 3777 (1-15-88) CARE" FIRE DEPARTMENT 2101 H STREET O. S. NEEDHAM OCTO~BER 1 3, 1 988 BAKERSFILED, 93301 FiRE CHIEF 326-3911 BUSCH INDUSTRIAL PRODUCTS CORP. 5455 DISTRICT BLVD '. · BAKERSFIELD, CA 93309 DEAR MR. RICHARD HUGHES: TH~-ENCLOSED "ACUTELY HAZARDOUS MATERIALS REGISTRATION FORM" MUST BE COMPLETED, ALONG WITH THE RISK MANAGEMENT AND PREVENTION PROGRAM (SEE ATTACHED REQUIREMENTS) BY ANY BUSINESS HANDLING ABOVE THE MINIMUM REPORTING QUANTITY OF ANY MATERIAL ON THE EPA LIST OF EXTREMELY HAZARDOUS SUBSTANCES. (FED. REGISTER VOL. 52, NO. 77, P. 13397). YOUR COMPANY HAS REPORTED HANDLING THE FOLLOWING ACUTELY HAZARDOUS MATERIALS: CHLORINE AND SULFURIC ACID PLEASE RETURN THE COMPLETED ACUTELY HAZARDOUS MATERIALS REGISTRATION FORM AND RISK MANAGEMENT AND PREVENTION PROGRAM HAZARDOUS MATERIALS DIVISION 2130 G STREET BAKERSFIELD, CA 93301 IF YOU HAVE ANY QUESTIONS REGARDING THIS FORM PLEASE CALL RALPH HUEY AT 326-3979. SINCERELY YOURS, RALPH E. HUEY HAZARDOUS MATERIALS COORDINATOR REH/ed ENCLOSURE