HomeMy WebLinkAboutRISK MANAGEMENT (3)PACIFIC WOOD PRESERVING OF BAKERSFIELD, INC.
RISK MANAGEMENT PLAN
Prepared for:
Pacific Wood Preserving of Bakersfield, Inc.
5601 District Blvd.
Bakersfield, California 95688
Prepared by:
Reese-Chambers Systems Consultants, Inc.
3379 Somis Rd.
P.O. Box 8
Somis, California 93066
TABLE OF CONTENTS
1. INTRODUCTION .......................................................................................................... 1-1
2. GENERAL REQUIREMENTS ...................................................................................... 2-1
2.1 Purpose and Scope ............................................................................................ 2-1
2.2 CalARP ............................................................................................................... 2-1
2.3 Emergency Information Access .......................................................................... 2-1
3. EXECUTIVE SUMMARY ............................................................................................. 3-1
3.1 Accidental Release Prevention and Emergency Response Policies ................... 3-1
3.2 Description of the Stationary Soume and Regulated Substances ....................... 3-1
3.3 Worst-Case Release Scenario and Alternative Scenario .................................... 3-5
3.4 Five-Year Accident History ............................................... : ................................. 3-5
3.5 Emergency Response Program .......................................................................... 3-5
3.6 Planned Changes to Improve Safety .................................................................. 3-6
4. FIVE-YEAR ACCIDENT HISTORY .............................................................................. 4-1
5. OVERVIEW OF PREVENTION PROGRAMS .............................................................. 5-1
5.1 Safety Information and Process Safety Information ............................................ 5-1
5.2 Operating Procedures ......................................................................................... 5-2
5.3 Training .............................................................................................................. 5-3
· 5.4 Maintenance and Mechanical Integrity ................................................................ 5-3
5.5 Compliance Audits .............................................................................................. 5-3
5.6 Incident Investigation .......................................................................................... 5-3
5.7 External Events Analysis .................................................................................... 5--4
6. OFFSITE CONSEQUENCE ANALYSIS ...................................................................... 6-1
6.1 Aqueous Ammonia ............................................................................................. 6-1
6.2 Worst-Case Scenario .......................................................................................... 6-1
6.3 Alternative Release Scenario .............................................................................. 6-2
6.4 Population Impacts ............................................................................................. 6-3
7. OVERVIEW OF EMERGENCY RESPONSE PROGRAM ............................................ 7-1
8. HAZARD ANALYSIS ................................................................................................... 8-1
8.1 Introduction ......................................................................................................... 8-1
8.2 Methodology and Objectives ............................................................................... 8-1
8.3 Hazard Analysis Team Members and Qualifications ........................................... 8-2
8.4 Summary of Action Items/Recommendations ..................................................... 8-3
8.5 Hazard Analysis Data Sheets .............................................................................
9. OTHER REQUIREMENTS ........................................................................................... 9-1
9.1 Recordkeeping ............................................................................ ~ ...................... 9-1
9.2 Audits and Inspections ........................................................................................ 9-1
9.3 Availability of Information to the Public ............................................................... 9-1
10. RMP CERTIFICATION ......................................................................... ; ..................... 10-1
PWP of Bakersfield RMP i
August 2001
1. INTRODUCTION
Pacific Wood Preserving (PWP) presently has a Program 1 Risk Management Plan (RMP) in
place. The purpose of this update to the RMP is to address some additional wood trea~ting_
processes that utilize aqueous ammonia in the treatment solution. The use o ~;1a~
ammonia elevates the RMP to a Program 2 level. The process covered in the prior Program 1
RMP is also addressed in this updated RMP.
Three wood treatment processes have been addressed in this RMP. The first two involve the
use of aqueous ammonia and are classified as Program 2, while the third uses arsenic
pentoxide in solution and is classified as Category 1. Each of the processes is summarized
below.
The copper/borate treatment process is being conducted as a plant research project to evaluate
the process. This process will initially bring in 28% aqueous ammonia in 55-gallon drums and
dilute and mix it with other chemicals in a 2,000-gallon mixing tank to form a wood treatment
solution that will contain 2% ammonia. This 2% solution will be stored in a 36,000-.gallon work
tank. Wood is put in a treatment cylinder and the coppedborate solution is pumped into the
cylinder to treat the wood. After the treatment process is completed, the remaining solution is
pumped back to the work tank. Additional solution is prepared and added to the work tank as
necessary. If the treatment process proves successful, the copper/borate solution will either be
brought on site pre-mixed with no more than 4% ammonia or mixed on site using aqueous
ammonia in concentrations less than 20%.
The 'ACQ treatment process brings in aqueous ammonia in concentrations up to 15% ammonia
by tank truck and stores the liquid in a 17,000-gallon tank. The ACQ solution is then made on
site and stored in a 36,000-gallon work tank. Wood is treated using this ACQ solution in the
same manner as described above for the copper/borate solution.
The above two processes are treated as a single process in the RMP analysis because all of
the tanks are interconnected with piping.
The CCA wood treatment process uses a solution that contains arsenic acid (arsenic pentoxide)
which is on the California regulated substances list. The CCA is delivered as a 60% solution,
the other 40% being water, by truck in quantities of 50,000 lbs. A working solution of
approximately 2% CCA is produced by adding concentrate and water in one of the work tanks.
The solution is then used to treat wood in the same manner as described above.
A hazard analysis using the "what if/checklist" methodology has recently been conducted on
both acqueous ammonia processes. Five mitigation measures were recommended and all have
been implemented. A hazard analysis addressing the CC^ process was previously conducted.
A summary of the RMP has been completed using the EPA RMP Submit program and
submitted to Bakersfield Environmental Services as pad of this RMP.
PWP of Bakersfield RMP 1-1
August 2001
2. GENERAL REQUIREMENTS
2.1 Purpose and Scope
California's Accidental Release Prevention (CalARP) regulations require the owner or operator
of a stationary source that handles more than a threshold quantity of a regulated substance in a
process to develop and submit a Risk Management Plan (RMP). According to the definition of a
process contained in the regulations, the PWP Bakersfield facility has two processes that
utilizes a regulated substance in quantities greater than the threshold quantity. The regulated
substances are aqueous ammonia and arsenic pentoxide.
The CalARP regulations implement the federal accident release prevention regulations. The
objective of the CalARP program is to prevent accidental releases of chemicals that have the
potential to affect public health and the environment.
This RMP describes the risk management program that has been developed at the PWP facility.
In accordance with the regulations, this program incorporates a management system, a hazard
assessment, a prevention program, and an emergency response program.
PWP's aqueous ammonia treatment process (ACQ and copper borate processes) is classified
as Program 2 process because it utilizes aqueous ammonia in concentrations above 1% and in
quantities over 500 pounds, and can result in offsite impacts. PWP's CCA treatment process is
classified as a Program 1 process because up to 27,000 lbs of arsenic pentoxide in solution can
be on site at any given time (the threshold limit is 10,000 lbs), and because the process
presents no offsite impacts.
2.2 CalARP Program Management
Section 2735.6 of the CalARP regulations requires the development of a management system
to oversee the implementation of the risk management program elements. The owner or
operator is to assign a qualified person or position that has the overall responsibility for the
development, implementation, and integration of the risk management program elements. PWP
has assigned the Environmental Health & Safety Manager this responsibility. The
Environmental Health & Safety Manager reports directly to the Plant Manager.
2.3 Emergency Information Access
Section 2735.7 of the CalARP regulations states that the local Administering Agency (AA) shall
provide immediate access to all components of the CalARP program upon request of a state or
local emergency response agency. If any of the components of the CalARP program are
designated as "trade secret" as defined in Section 6254.7(d) of the Government Code and
Section 1060 of the Evidence Code, the emergency response agency or agencies shall be
given notice that the information released shall be used only in connection with the official duties
of the agency or agencies and shall not otherwise be released.
PWP of Bakersfield RMP 2-1
August 2001
3. EXECUTIVE SUMMARY
Section 2745.3 requires that the owner or operator provide in the RMP an executive summary
that includes a brief description of the elements described below.
3.1 Accidental Release Prevention and Emergency Response Policies
PWP utilizes aqueous ammonia and arsenic pentoxide at their wood treatment facility in
Bakersfield. It is PWP's policy to comply with all applicable government regulations. This RMP
summarizes the operating practices and procedures in place at PWP.
3.2 Description of the Stationary Source and Regulated Substances
Figure 3-1 shows the location of the PWP facility. Figure 3-2 presents a layout of the facility. All
solutions containing CCA and arsenic pentoxide are stored in Area 1. The cylinder in Area 4 is
utilized for treating wood with the CCA solution.
All solutions containing aqueous ammonia will be stored in tanks located in Area 13. The
treatment cylinder that will be utilized is located in Area 10. A short description of the three
wood treatment systems (two processes according to the regulations) is presented below.
CCA - The CCA product is delivered as a 60% concentrate solution, the remaining 40% is
water. The solution as delivered contains 15% chromic acid, 6% copper oxide, and 30%
arsenic acid (arsenic pentoxide). A 6,000 gallon fiberglass tank is designated as the storage
container for the CCA concentrate. Normal delivery is approximately 50,000 lbs. The CCA
concentrate is re-ordered when the storage tank contains approximately 600 gallons.
A working solution of approximately 2% CCA is produced by adding concentrate and water in
one of the two work tanks through an electronically controlled, pneumatically actuated mixing
station. Once the mixing is complete, the work tank is tested to determine if the concentration
meets specifications.
A charge of wood is then loaded into the retort cylinder via railroad type trams. The wood is
initially subjected to a vacuum in the cylinder. Once the vacuum process is complete, the
working solution is pumped into the cylinder. Once the cylinder is completely filled with liquid,
the hydraulic pressure in the cylinder is increased by a liquid pump to force the CCA fluid into
the wood. After the pressure cycle is complete, the working solution is removed from the
cylinder and placed back into the work tank. Another vacuum is then applied to the wood to
assist in liquid removal from the cylinder and decrease drippage on the pad.
The working solution is then checked to determine the concentration and water and/or CCA
concentrate is added to replenish the solution for its next use.
Copper/Borate Process - PWP is in the process of conducting commercial plant trials of a new
copper/borate wood treatment system. The purpose of the trial is to test a suitable Iow
environmental impact alternative to chromated copper arsenic (CCA) preservatives. If this
system proves viable, it will be implemented as a regular pad of PWP's business. The process
that is being used during the plant trials is described below. In addition, several options for
implementation of the process as a regular part of business are also described below.
PWP of Bakersfield RMP 3-1
August 2001
Figure 3-1 Location of PWP
PWP of Bakersfield RMP 3-2
August 2001
FIG WOOD PRESERVING OF BAICEI~$FIELUJ
PARK~
~ ~IEA
Figure 3-2 Facility Layout
PWP of Bakersfield RMP 3-3
August 2001
Chemicals will be delivered to the plant for the purpose of making the preservative solution.
Ammonia hydroxide (aqueous ammonia) 28 % solution is one of the chemicals that will be
utilized in the mixture. The ammonia hydroxide will be delivered to the plant in 55-gallon drums.
The drums will be delivered on pallets with four drums to a pallet. The drums will be stored in
the covered storage area. Once sufficient materials are delivered on-site, 36,000 gallons of
solution will be prepared in 2,000-gallon batches using the mixing tank. The mixing process is
described below.
A specified amount of water is added to the 2,000-gallon mixing tank. A small amount of formic
acid is then added to the tank and mixed with the water. Ammonia hydroxide in an amount
approximately equal to the amount of water in the tank is then added to the tank. A pH safety
check is then conducted on the mixture in the tank to ensure that the mixture is basic prior to the
addition of the copper carbonate. Ammonia bicarbonate is then added and the tank undergoes
mixing until all components are dissolved, approximately one hour. Lastly, Borax MG is added
and mixed to form a very liquid paste. This paste is diluted with water to 2,000 gallons and fully
dissolved. The ammonia hydroxide concentration in this final solution is 2 %. The 2,000-gallon
solution is then transferred via piping to the 36,000 Borate Work Tank. This process is repeated
18 times to fill the 36,000-gallon tank.
Wood to be treated with this solution is put into the treatment cylinder and the door is closed. A
vacuum is drawn in the cylinder to pull air out of the wood so the solution will better penetrate.
Treatment solution is then transferred from the work tank to the treatment cylinder and the
cylinder is hydraulically pressurized. The wood is left in this pressurized solution for a specified
amount of time depending on the type of wood. After the specified time, the solution is pumped
back to the work tank. Some of the solution penetrates the wood and is therefore not pumped
back to the work tank. Thus, additional solution must be made up and transferred to the work
tank periodically.
Several options of ~,eceiving or making the Borate solution when the process goes commercial
are being considered and one or all may be used. First, the solution may be brought on site
fully mixed, requiring only additional dilution with water. Such solution could be delivered in
drums, IBCs, or tank truck. Second, ammonia hydroxide in less than 20% solution will be
delivered to the facility in drums, IBCs, or tank truck with the treatment solution blended on site
as described above.
ACQ Process - The ACQ process is similar to the coppedborate process. Aqueous ammonia
with no more than 15% ammonia is delivered by tank truck and stored in a 17,000-gallon tank.
Normally, the tank is only filled with 5,076 gallons. Other materials are then mixed in the mixing
tank and then this solution and the aqueous ammonia are pumped to a 36,000-gallon work tank
where further mixing takes place using a circulation pump. The final solution contains
approximately 1% ammonia. Wood treating takes place as described above for the
copper/borate process.
The characteristics and hazards of aqueous ammonia are described briefly in Section 6.0 of this
document. For purposes of the offsite consequence analyses, 40 CFR Part 68 and the CalARP
regulations define the toxic endpoint for aqueous ammonia as 0.14 mg/I (200 ppm). This
concentration has been established by the American Industrial Hygiene Association as the
Emergency Response Planning Guideline Level 2 (ERPG-2). ERPG-2 is the maximum airborne
concentration below which it is believed that nearly all individuals could be exposed for up to
one hour without experiencing or developing irreversible or other serious health effects or
symptoms which could impair an individual's ability to take protective action.
PWP of Bakersfield RMP 3-4
August 2001
3.3 Worst-Case Release Scenario and Alternative Release Scenario
Offsite consequence analyses are used as tools to assist in emergency response planning. The
CalARP regulations require that offsite impacts due to accidental releases of regulated
substances be analyzed. The analysis must analyze the worst-case release scenario and an
alternative release scenario.
The offsite consequence analysis must include an estimate of the residential population within
an area potentially affected by the accidental release scenario. The area is defined as a cimle
with radius equivalent to the distance the release would travel with concentrations at or above
the endpoint. The circle also defines the area in which potential environmental receptors must
be identified.
The worst-case release scenario for the PWP facility was determined to be a release from the
17,000-gallon tank containing 20% aqueous ammonia. Although only 15% aqueous ammonia is
presently delivered by tank truck and stored in storage tanks, PWP may want to increase the
concentration in the future. In any case, the ammonia concentration will remain below 20%
when delivered by tank truck and stored in storage tanks. Releases from larger tanks with lower
concentrations of ammonia and from drums containing 28 % aqueous ammonia were also
analyzed and it was determined that these scenarios resulted in shoder distances to the
endpoints. The worst-case release scenado consisted of the release of the 20% aqueous
ammonia into the diked area and pit and produces a plume that could travel 0.4 miles. Section
6 documents the worst-case and alternative release scenarios.
Section 6 also contains information on sensitive receptors within the hazard footprint. The
population potentially affected within the worst-case release scenario is 40 people. There are
no environmental receptors within the worst-case release scenario footprint.
The alternate release scenario consisted of the dropping of a pallet containing four drums
containing 28% aqueous ammonia resulting in the rupturing of the drum. The plum for this
scenario was calculated to travel 0.06 miles (approximately 300 feet). This plum would extend
offsite and overlap the adjacent business located to the west, but it would not extend into
residential areas.
3.4 Five-Year Accident History
As discussed in Section 4, PWP has not had any accidental releases involving the processes
Using aqueous ammonia or arsenic pentoxide that have resulted in deaths, injuries, or
significant properly damage on site, or known offsite deaths injuries, evacuations, sheltering in
place, property damage, or environmental damage in the last five years.
3.5 Emergency Response Program
PWP has established an emergency action plan and a chain of command to respond to
emergencies and notify emergency responders when there is a need for a response. The plan
is summarized in Section 7.
PWP of Bakersfield RMP 3-5
August 2001
3.6 Planned Changes to Improve Safety - *
Based on the findings of the hazard analysis that was conducted on August 2, 2001, the
following five mitigation measures were recommended. All have been implemented.
Bring in only half (63) of the drums already purchased (126) containing 28% solution
anhydrous ammonia.
· Install a water misting system to aid in keeping the anhydrous ammonia drums cool.
· Develop written checklist for the copper/borate mixing process
· Add water hose to the platform area.
· Calibrate a dipstick to be used to determine initial volume of water to be added to the
work tank.
PWP of Bakersfield RMP 3-6
August 2001
4. FIVE-YEAR ACCIDENT HISTORY
Section 2750.9 of the CalARP regulations requires a discussion of the five-year accident history
at the facility. PWP has not had any accidental releases involving the processes using aqueous
ammonia or arsenic pentoxide that have resulted in deaths, injuries, or significant property
damage on site, or known offsite deaths injuries, evacuations, sheltering in place, property
damage, or environmental damage in the last five years.
PWP of Bakersfield RMP 4-1
August 2001
5. OVERVIEW OF PREVENTION PROGRAMS
Two of PWP's wood treatment systems utilize aqueous ammonia. Aqueous ammonia
processes are classified as Program I under the CalARP program because they can result in
offsite consequences. Therefore, PWP must comply with the requirements of Section 2735.5(e)
of the CalARP regulations. Section 2735.5(e) states that the facility shall:
Develop and implement a management system
Conduct a hazard assessment
Implement the prevention program requirements
· Develop and implement an emergency response program
· Submit as part of the RMP the data on prevention program elements for Program 2
processes
The CalARP program management system required by Section 2735.6 has been developed
and implemented by PWP as discussed in Section 2.2.
The emergency response program, which meets the requirements of Sections 2765.1 and
2765.2, is described in Section 7.
PWP conducted a hazard assessment in accordance with Sections 2750.1 through 2750.9 at
the Bakersfield facility on August 2, 2001. Documentation of the hazard assessment is
contained in Section 8.
5.1 Safety Information and Process Safety Information
Cai ARP regulations require PWP to compile and maintain the following up-to-date safety
information related to acqueous ammonia:
· Material Safety Data Sheet(MSDSs)
· Maximum intended inventory of equipment in which aqueous ammonia is stored or
processed.
· Safe upper and lower temperatures, pressures, flows, and compositions
· Equipment specifications
Code and standards used to design, build, and operate the process
Copies of all MSDSs, including aqueous ammonia, are maintained on site and submitted to the
Fire Depadment as pad of the Integrated Hazardous Materials & Waste Contingency Plan.
Inventories of hazardous materials are also contained in the Integrated Hazardous Materials &
Waste Contingency Plan.
Any of the tanks listed in Table 5-1 can contain aqueous ammonia in varying concentrations but
always below 20%. In addition, 28% aqueous ammonia is being brought on site in drums and
stored in the covered storage area. No more than 63 drums shall be on site at any given time.
After the initial mixing process for the commercial plant trials is completed, no aqueous
ammonia at or above 20% will be brought on site. Drums and/or IBCs containing aqueous
ammonia below 20% may be brought on site and stored.
PWP of Bakersfield RMP 5-1
August 2001
Table 5-1 Tankage
Description Capacity
Dricon Work Tank 36,096
Borate Work Tank 36,096
ACQ-Cl Concentrate 15,228
ACQ-C2 Concentrate 17,766
ACQ Work Tank 37,600
Effluent Tank 19,458
E~mpty - Not Presently in Use 20,304
Dricon Mix Tank 4,109
Mix Tank 2,000
Treatment Cylinder 37,000
The maximum amount of ammonia that may be at the PWP facility at any given time has been
calculated assuming that one 36,000 work tank of copper/borate solution and one 36,000 gallon
work tank of ACQ are full and that enough ammonia in aqueous solution to make enough
solution to refill the two tanks is onsite. This additional aqueous ammonia may be in tanks,
drums, or IBCs. There is 2% ammonia by weight in the copper/borate solution, which equates
to approximately 36,000 gal x 8.3 lbs/gal x 0.02 = 6,000 lbs. The ACQ solution has 1%
ammonia, which equates to 3,000 lbs. Adding these two and then doubling to account for the
ammonia for the makeup, equates to 18,000 lbs.
The aqueous ammonia and wood treatment solutions containing aqueous ammonia are not
stored under pressure and are not impacted by high or Iow ambient temperatures. All treatment
cylinders that are pressurized are equipped with pressure relief valves. The pressure relief
valves are set at or below the maximum allowable working pressures of the relief valves. The
pressure relief valves are piped to release to the containment pit. Drums and ICBs are also
equipped with pressure relief valves.
The treatment process is controlled and monitored by a control system that controls valves
pumps and monitors valve positions, pressures, and temperatures.
5.2 Operating Procedures
Each operator goes through an extensive training period. The initial trainin9 covers the function
and capability of each piece of equipment as it relates to the treatment process. An emphasis is
placed on how to safely operate the equipment. A portion of this training involves new trainees
working under a qualified employee that supervises every step of the new trainee's operation of
the treatment process. This training continues until the qualified operator determines that the
trainee is now qualified to operate the treatment process without supervision.
Under this facility's operating procedures there are always two employees at the site when a
treatment process is in operation. Along with this, employees are required to manually read the
tank gauges before, during, and after each charge to ensure tank levels are maintained.
PWP of Bakersfield RMP 5-2
August 2001
5.3 Training
PWP's training program is described in their written Hazard Communication Program. New
Employee Training Forms are filled out and maintained for all employees. The training program
addresses the following:
. Telephone usage
· Evacuation location
· Hazard communication (labeling, MSDSs, chemical information)
· Hazardous wastes
· Lock out/tag out program
· Confined space program
· Emergency response procedures
· Forklift operation
5.4 Maintenance and Mechanical Integrity
While in operation, the process equipment is continually being inspected visually by operators
for leaks, malfunctions or maintenance related problems. Other documented formal inspections
are as follows:
· Daily/Weekly 40 CFR 265, Subpart J inspections on the tank systems
· Weekly 40 CFR 265, Subpart W inspections on the drip pad
· Annual Independent Engineer Certification on ddp pads
5.5 Compliance Audits
pwP must certify that they have evaluated compliance with the provisions of Article 5 (Sections
2755.1 through 2755.7) of the CalARP regulations at least every three years. The purpose of
these compliance audits is to vedfy that the procedures and practices developed for the CalARP
program are adequate and are being followed. The Environmental Health & Safety Officer and
Plant Manager are responsible for conducting this audit and will develop a report containing the
findings, recommended actions, and date of correction. Reports will be kept on site for at least
five years.
5.6 Incident Investigation
PWP will investigate any incident that results in, or could have resulted in, a catastrophic
release of ammonia. This investigation process will:
· Begin immediately
· Be summarized in a report
· Address the report's findings and recommendations
· Review the report with staff and contractors
· Be retained on site for at least five years
PWP of Bakersfield RMP 5-3
August 2001
5.7 External Events Analysis
External events that could result in a release on aqueous ammonia were addressed during the
conduct of the hazards analysis that is documented in Section 8. External events examined
included vehicle traffic, seismic events, and electrical failures.
PWP of Bakersfield RMP 5-4
August 2001
6. OFFSITE CONSEQUENCE ANALYSIS
CalARP regulations require an offsite consequence analysis that addresses the potential offsite
impacts due to a release of a regulated substance, in this case aqueous ammonia. The
regulations provide definitive guidance regarding the release parameters to be utilized in the
offsite consequence analysis. The regulations require that a standardized worst-case release
scenario and an alternative release scenario be analyzed. For aqueous ammonia, the worst-
case release is defined as the release that would result in the greatest distance to the endpoint
using the specified calculation methodology. The alternate scenario should be a release that is
more likely to occur, and that will result in an endpoint that goes offsite.
6.1 Aqueous Ammonia
Aqueous ammonia consists of ammonia dissolved in water. Under the federal regulations,
aqueous ammonia with less than 20% ammonia by weight is not listed as a regulated
substance. Under the CalARP regulations, there are no limitations on the ammonia
concentration in the aqueous ammonia. An RMP and offsite consequence analysis is required if
there are more that 500 lbs of ammonia on-site at any given time.
The potential hazard from aqueous ammonia is that it can give off toxic ammonia vapors if
released to the atmosphere. The higher the concentration of ammonia in the water, the more
vapors that are given off. When the concentration of ammonia in the water falls below 20%, the
amount of ammonia vapors that are produced at ambient temperatures is sufficiently Iow that it
is not considered a major hazard.
Ammonia, referred to as anhydrous ammonia when not mixed with any other material, has a
molecular weight of 17 and is lighter than air. Ammonia is gaseous at standard temperature
and pressure. The offsite consequence analysis is based on the amount of ammonia that is
released. When aqueous ammonia is release, the ammonia that evaporates is blown along by
the wind. As it is blown, it mixes with the air and becomes diluted. Under CalARP, the distance
that the vapors travel before they fall below a concentration of 0.14 mg/I (approximately 200
ppm) is defined as the endpoint. This endpoint is equivalent to the Emergency Response
Planning Guideline Level 2 (ERPG-2) established by the American Industrial Hygiene
Association (AIHA). ERPG-2 is defined as "the maximum airborne concentration below which it
is believed that nearly all individuals could be exposed for up to one hour without experiencing
or developing irreversible or other serious health effects or symptoms which could impair an
individual's ability to take protective action." Further, the AIHA states that at the ERPG-2, there
is likely to be strong odor and some eye irritation, but serious health effects are unlikely.
6.2 Worst-Case Scenario
Currently, aqueous ammonia is brought on-site by tank truck and stored in 17,700-gallon tanks
with the ammonia percentage being less than 15%. It is possible that higher concentrations of
aqueous ammonia could be delivered to the facility by tank truck and stored in a 20,000-gallon
tank; however, the ammonia concentration would always be below 20%. The aqueous
ammonia is then diluted and mixed with other chemicals and stored in larger tanks with
capacities up to 37,600 gallons. The percentage of ammonia in these solutions will always be
less than 2%. Aqueous ammonia with 28% ammonia is also being brought on-site in 55-gallon
drums for commercial plant trials. The amount of ammonia that could be released in the event
of a worst-case accident involving all three of the above cases was calculated and it was
PWP of Bakersfield RMP 6-1
August 2001
determined that the release involving the 20% aqueous ammonia from the 20,000 gallon tank
would result in the largest amount of ammonia vapors being released. Hence, the worst-case
release is defined as a 20,000--gallon release of 20% aqueous ammonia. The calculations used
to determine the endpoint are presented below. The methodology contained in the EPA
document titled "RMP Offsite Consequence Analysis Guidance" was utilized for the calculations.
Since the tank is located inside secondary containment, formula (7) in Section 3.2.3 was utilized
to calculate the release rate. The formula is:
· QR=I.4xLFAxA
where: QR = Release rate (lbs per min)
1.4 = Wind speed factor
LFA = Liquid Factor Ambient (listed in Exhibit B-2, Appendix B)
A = Diked area (square feet)
The values for each of the above parameters for the worst-case scenario are presented below.
LFA = 0.015 (from Exhibit B-2, Appendix B)
A = 20,000 sq. ft. (based on measurements of the containment area and pit)
Hence, QR = 1.4 x 0.015 x 20,000 = 420 Ibs/min
Reference Table 10 for aqueous ammonia with F stability and 1.5 meters per second wind was
then used to get the endpoint. The value listed for an urban environment was utilized. The
endpoint from the table for this scenado is 0.4 miles. Figure 6-1 shows the area that would
potentially be impacted by the worst-case release from the PWP facility.
6.3 Alternative Release Scenario
Drums are delivered on pallets containing four drums. Thus, the dropping of a pallet containing
four drums, each containing 28% anhydrous ammonia, that results in a rupture of all four drums
was chosen as the alternative release scenario. The methodology contained the EPA
document titled "RMP Offsite Consequence Analysis Guidance" was also utilized for the
alternative release scenario calculations.
Since the drums could be dropped in an area that does not have secondary containment,
formula (18) in Section 8.2.3 was utilized to calculate the release rate. D stability with 3 meters
per second wind is utilized for the alternative scenario since these conditions are more likely.
Formula (18)is presented below.
° QR=QSx2.4xLFAxDF
where: QR = Release rate (lbs per min)
QS = Quantity released
2.4 = Wind speed factor
LFA = Liquid Factor Ambient (listed in Exhibit B-2, Appendix B)
DF = Density factor (listed in Exhibit B-2, Appendix B)
PWP of Bakersfield RMP 6-2
August 2001
The values for ~ach of the above parameters for the alternative scenario are presented below.
QS = 1,830 lbs (weight of aqueous ammonia in four drums)
LFA = 0.019 (from Exhibit B~2, Appendix B)
DF = 0.55 (from Exhibit B-2, Appendix B)
Hence, QR = 1,830 x 2.4 x 0.019 x 0.55 = 45.9 lbs/rain
Reference Table 12 for aqueous ammonia with D stability and 3 meters per second wind was
then used to get the endpoint. The endpoint from the table for this scenado is 0.06 miles
(approximately 300 ft.). Figure 6-1 shows the area that would potentially be impacted by the
alternative release scenario at the PWP facility.
6.4 Population Impacts
The offsite consequence analysis must include an estimate of the residential population within
the area potentially affected by the accidental release scenarios. This area is defined as a circle
with a radius equivalent to the distance the release would travel with concentrations above the
endpoint. The circle also defines the area in which potential environmental receptors must be
identified.
The PWP facility is located on District Blvd. and the immediate area surrounding the facility
consists of industrial facilities and commercial businesses. Figure 6-1 shows both the 0.4 and
O.06-mile circles from the worst-case and alternative release scenarios. Neither of the circles
overlaps any environmental receptors or schools, daycare centers, medical centers, nursing
homes, hospitals, parks, arenas, pdsons, or federal lands.
Worst-Case Release - The solid circle in Figure 6-1 represents the worst-case scenario 0.4-
mile potential area of impact. The circle was centered on the containment area in which the
tanks that can contain aqueous ammonia solutions are located. The immediate area
surrounding the plant consists of industrial facilities and commercial businesses. The southern
most area of the circle overlaps about 80 residences. This equates to approximately 320
people being located inside the circle.
Alternative Scenario - The dashed-line circle in Figure 6-1 represents the alternative scenario
potential area of impact. This circle overlaps several nearby business, but it does not overlap
any residences.
PWP of Bakersfield RMP 6-3
August 2001
Ln /
~O00':Ma pclue,st~comi:.ln¢.:Cl~O00' DT, .l'noi: ,. : ':: ';.::::: .:.: ..
Figure 6-1 Scenario Hazard Zones
6-4
PWP of Bakersfield RMP
August 2001
7. OVERVIEW OF EMERGENCY RESPONSE PROGRAM
PWP has developed and implemented an Integrated Hazardous Materials & Waste Contingency
Plan. The Plan is current and was last updated February, 2001. The Plan addresses the
following elements.
· Emergency Coordinators authority and responsibility
· Emergency response contacts
· Medical information
· Site information
· Facility operations
· Evacuation procedures
· General fire procedures
· General spill/emergency response procedures
o Liquid spill in a containment area
o Liquid spill in a non-contained area
o Solid chemical spill in a contained area
o Solid chemical spill in a non-contained area
· Emergency equipment
· Decontamination
· Personnel training
· Inspections
· Security
· Communications procedures
· Prevention and best management practices
· Natural disasters
· Hazardous material storage information
o Name
o Hazard
o Location
o Reportable quantity
o Type of storage
o Size of storage container
o Storage container construction materials and year built
o Secondary containment
PWP also has a Hazard Communication Program in place. This Plan addresses the following:
· Material safety data sheets
· Labels and other forms of warning
· Personnel protective equipment
· Training
PWP of Bakersfield RMP 7-1
August 2001
8. HAZARDS ANALYSIS
8.1 Introduction
The Hazard Analysis documented herein was conducted to review the Pacific Wood
Bakersfield, Inc. CoppeflBorate and ACQ wood treatment processes. The analysis is required
by State of California regulations regarding the preparation of a Risk Management Program
(RMP). The RMP process for the Pacific Wood facility is administered by the Bakersfield Office
of Environmental Services. The analysis was conducted at the Pacific Wood facility located at
5601 District Blvd. in Bakersfield, California on August 2, 2001.
The five recommendations resulting from the conduct of the analysis have already been
implemented.
8.2 Methodology and Objectives
The "What-If/Checklist" methodology was utilized for the conduct of the hazard analysis. The
What-If analysis technique is a brainstorming approach in which a group of experienced people
asks questions or voice concerns about possible undesired events. The Checklist methodology
uses a written list of items or procedural steps to vedfy the status of a system. The What-
If/Checklist analysis technique combines the creative, brainstorming features of the What-If
analysis method with the systematic features of the Checklist analysis method. This hybrid
method capitalizes on the strengths and compensates for the individual shortcomings of the
separate approaches. This method is listed as an acceptable hazard analysis technique for use
in the preparation of an RMP by both federal and California. The methodology is also listed as
an acceptable hazard analysis technique in "Guidelines for Hazard Evaluation Procedures,
Second Edition with Worked Examples" by the Center for Chemical Process Safety of the
American Institute of Chemical Engineers.
The process was divided into the following five areas for analysis purposes:
Initial delivery and mixing of copper/borate solution
Copper/borate and ACQ treatment process
ACQ delivery and mixing process
Delivery of aqueous ammonia solution by IBC
Delivery of aqueous ammonia solution by tank truck
For each of the following areas, a series of questions was developed for the purposes of
determining what would happen if a certain event were to happen. For example, for unloading
and moving of drums, the question was asked "What if a drum leaks during transpod by truck".
The list of questions was developed by the hazard analysis team leader who then distributed the
list to all participants prior to the conduct of the analysis. Team members then reviewed the
questions and made recommended changes and additions.
PWP of Bakersfield RMP 8-1
August 2001
The following areas were then addressed for each question:
× The likelihood of the event described in the question occurring. This likelihood of
the event occurring was put in one of the following four categories:
1. Probable - expected to happen during any given year
2. Likely - expected to happen during life of project
3. Unlikely - has happened at other similar facilities
4. Remote
The classification of likelihood was based on the opinions of team members and
is subjective. The purpose of estimating likelihood is to be able to compare
events and determine the level of prevention measures necessary.
× The potential consequences of the event occurring. Events that can result in
adverse consequences such as releases are then scrutinized in more detail.
× Existing controls/prevention measures. The purpose of addressing this area is
determine if there are sufficient controls and measures in place to minimize the
possibility of the event occurring and/or the consequences of the event should it
Occur.
Recommendations were then made, if necessary, based on the results of the
previous findings.
Findings for each of the above areas were recorded real time on the What-If/Checklist as the
analysis progressed.
The hazard analysis has four Overall aims:
To identify events which could potentially create a hazardous situation.
Estimate the likelihood of the event occurring.
To determine whether further action is required to prevent the event from
occurring or to minimize the consequences should it occur.
To ensure that any actions identified are implemented.
8.3 Hazard Analysis Team Members and Qualifications
The process of hazard analysis requires the use of a team of individuals that has the following
experience. Individual team members do not necessarily have to have experience in all the
areas, but at least one person should experience in each of the areas.
hazard analysis conduct using chosen methodology
operation of facility type being studied
design of facility
PWP of Bakersfield RMP 8-2
August 2001
The members of the hazard analysis team and their experience are provided below.
(1) Tim Chambers Team Leader
B.S. and M.S. in Mathematics. Twenty years experience in hazard analysis including
acting as team leader for the conduct of such studies using the What-If/Checklist and
Hazop methodologies. Vice president of Reese-Chambers Systems Consultants, Inc., a
firm specializing in risk analysis. Member of the Society for Risk Analysis.
(2) Ron Saylor
Environmental and Safety Manager for the Pacific Wood of Preserving.
(3) Rick McCullogh
Plant Manager for the Pacific Wood Bakersfield facility.
(4) Jeff Lloyd
Market Development Manager for US Borax responsible for the conduct of the
coppedborate research project. He has a PhD in microbiology. He is a Fellow of the
Institute of Wood Science, Convener of the diffusibles working group and Co-Chairman
of Wood Protecting Chemicals, both of the International Research Group on Wood
Preservation. He is also a member of the Amedcan Wood Preservers Association.
(5) Howard Wines
Hazardous Materials Specialist with the Bakersfield Fire Department. Responsible for
the review of the RMP. Participated as an observer
8.4 Summary Of Action Items/Recommendations
During conduct of the hazard analysis, five action items/recommendations were made. The
following lists these items together with the responsible person and completion date
requirement. All five action items/recommendations have been implemented.
1) Bring in only half (63) of the drums already purchased (126) containing 28% solution
anhydrous ammonia.
This recommendation was made to reduce the amount of 28% solution anhydrous ammonia
stored at the Pacific Wood Bakersfield facility. Responsibility for implementing this measure lies
with Jeff Lloyd of US Borax because he is responsible for delivery of the material.
2) Install a water misting system to aid in keeping the anhydrous ammonia drums cool..
This recommendation was made to help keep the drums from overheating and emitting
ammonia vapors through the pressure relief valve. Rick McCullough is responsible for the
installation of this system prior to delivery of any of these drums.
3) Develop written checklist for the copper/borate mixing process.
PWP of Bakersfield RMP 8-3
August 2001
This measure was recommended to help ensure that the mixing process is done correctly so
that material is not contaminated. The coppedborate solution that will be made represents a
similar but new process for the facility. Jeff Lloyd of US Borax is responsible for developing the
checklist that will be reviewed and approved by Rick McCullough of Pacific Wood. The checklist
is to be developed and approved prior to delivery of any of the 28% solution anhydrous
ammonia drums.
4) Add water hose to the platform area..
This measure was recommended in the event there is a release near the platform and mixing
tank. Water from the hose can be utilized to water down a release and flush the liquid into the
nearby pit. Rick McCullough is responsible for implementing this mitigation measure pdor to
delivery of any of the 28% solution anhydrous ammonia drums.
5) Calibrate a dipstick to be used to determine initial volume of water to be added to the
work tank.
The first step in the mixing process is to add a specified amount of water to the mixing tank.
The purpose of this mitigation measure is to provide the operator with a simple method to
determine when the proper amount of water has been added to the tank.
8.5 Hazard Analysis Data Sheets
The hazard analysis data sheets are contained in Appendix A.
PWP of Bakersfield RMP 8-4
August 2001
9. OTHER REQUIREMENTS
9.1 Recordkeeping
PWP maintains records suppoding the implementation of the CalARP regulations for five years
as required by Section 2775.1 of the regulations.
9.2 Audits and Inspections
The Administering Agency (Bakersfield Office of Environmental Services) is required to
periodically audit RMPs and to inspect facilities that have RMPs at least once every three years.
PWP will cooperate fully with these effods.
9.3 Availability of Information to the Public
The RMP shall be available to the public, excluding those components, which have been
designated as trade secret.
PWP of Bakersfield RMP 9-1
August 2001
10. RMP CERTIFICATION
Section 2745.2 of the CalARP regulations states that the RMP shall be certified complete by a
qualified person and the stationary source owner or operator. Completeness shall be
determined in accordance with Sections 2745.3 through 2745.9. Section 2745.9 requires the
owner or operator to submit in the RMP a single certification that, to the best of the signer's
knowledge, information, and belief formed after reasonable inquiry, the information is true,
accurate, and complete.
The following certifications have been provided.
As a qualified person, I have reviewed and can attest to the validity and appropriateness of the
hazard analysis performed in August, 2001 on the aqueous ammonia processes, and the
relationship between the mitigation measures identified and implemented as a result of the
hazard analysis. I also certify that this RMP is complete. Further, to the best of my knowledge,
information, and belief formed after reasonable inquiry, the information submitted is true,
accurate, and complete.
EJate
Vice President
Reese-Chambers Systems Consultants, Inc.
On behalf of Pacific Wood Preserving of Bakersfield, Inc., I certify that the RMP is complete.
Further, to the best of my knowledge, information, and belief formed after reasonable inquiry,
the information submitted is true, accurate, and complete.
Ron Saylo----~r Date
Environmental Health & Safety Manager
Pacific Wood Preserving of Bakersfield, Inc.
PWP of Bakersfield RMP 10-1
August 2001
APPENDIX A
HAZARD ANALYSIS DATA SHEETS
PWP of Bakersfield RMP
August 2001
APPENDIX A
HAZARD ANALYSIS DATA SHEETS
PWP of Bakersfield RMP
August 2001
PACIFIC WOOD BAKERSFIELD FACILITY
WHAT IF/CHECKLIST FORM
Analysis Team: Reese-Chambers, PWP, Borax, Bakersfield Fire Department Date of Analysis: Aug. 2, 2001
System Investigated: Copper/Borate Research Project Initial Mixing Process
What-if? Likelihood Potential Existing Controls/ Recommendations
Consequences Prevention Measures
1. Drum leaking at time Unlikely Release of at most 55 - Licensed contractor used
of pickup? gal of 28% ammonia - DOT certified drums
solution - Pressure relief valves in
drums
2. Drum leaks during Unlikely Release of at most 55 - Visual inspection when
transport by truck? gal drums delivered
- Licensed contractor used
- DOT certified drums
- Pressure relief valves in
drums
3. Wrong product is Unlikely Make bad product - Look at bill of lading
delivered? - Each drum labeled
4. Drop pallet during Unlikely Release of at most 4 - Designed to withstand
offloading? drums of 28% ammonia dropping
solution - Trained forklift drivers
5. Drum develops leak Unlikely Release one drum - Move to bunded area and Bring in only half of
during storage on site? dilute drums initially
- Storage area drains to pit
- Pallets not stacked
6. Vehicle/equipment Remote Cause drum(s) to leak - Chemicals stored together
runs into drum while in - No through truck traffic
storage? - Trained operators
What-if? Likelihood Potential Existing Controls/ Recommendations
Consequences Prevention Measures
7. Drum gets too hot? Likely Liquid vents through - Store out of direct sunlight, - install Arizona misters
relief valve storage area covered
- Drums have pressure relief
valves
8. Drum gets too cold? Unlikely No impact - Enough air space to allow for
expansion through pressure
relief valve
9. Pallet/drum is Unlikely Release of up to 4 - Two people present to help
dropped/damaged drums with spotting
during transport to - Trained operators
platform?
10. Drum falls off Unlikely Up to 4 drums leak - 2 people present
platform? - Leave shrink wrap on 4 drum
pallet
11. Mistake made during Unlikely - Jeff (borax) to be present
insertion of pump? - Leave shrink wrap on 4 drum
pallet
12. Make mistake during Unlikely Small release from - 2 people present
pumping/siphoning? siphon hose - Gauge on pump to measure
volume transferred
13. Mixing tank has Likely Contaminate product - No incompatible materials in Develop written
other product in it? back storage area checklist
- Trained operators
14. Mixing tank develops Unlikely Release into pit - Tank located in bunded area
leak? - Weekly inspection program
performed using check list
15. Too much vapor Unlikely Incapacitate worker - 2 people present Add water hose to
comes off mixing tank? - Only 1 bbl open at a time platform area.
- Operator has communication
system to call for help
What-if? Likelihood Potential Existing Controls/ Recommendations
Consequences Prevention Measures
16. Too much copper Unlikely Release of CO2 - pH test performed prior to Develop checklist
carbonate added adding copper carbonate
resulting in energetic - Add a small amount to check
CO2 release? for fizz
17. Mixing attendant Unlikely Injur worker - 2 people present
becomes incapacitated? - Operator has communication
system to call for help
18. Overfill mixing tank? Unlikely Release into pit - Visual inspection Calibrate a dip stick to
- Located inside bunded area determine initial volume
of water to be added
19. Mixing tank Unlikely Contaminated product - Someone from Borax will be Develop check list
becomes contaminated present at all times during
(bad mixture)? initial mixing
20. Mixing tank Unlikely None
becomes overheated?
21. Mixing tank Remote None - Open top tank
becomes
overpressurized?
22. Transfer piping leaks Unlikely Leak into pit - Inspection program
(valve, hole, corrosion)? - ASTM standard tests show
problem with brass. - No brass
materials at the facility - No
problems with steel products.
23. Transfer piping Unlikely Contaminate product - No incompatible materials Check list
routed to wrong present in back area
tank/location? - Manual valves
- Trained treaters are used
and walk lines before transfer
begins
Potential Existing Controls/ Recommendations
What-if? Likelihood Consequences Prevention Measures
24. Transfer pump Likely Delay of transfer, no - Swap out pumps
doesn't work? problems with process - Clean filters
25. Work tank not empty Unlikely Contaminate product No incompatible materials
(first time filling)? present in back area
Trained operators
26. Work tank has other Unlikely Contaminate product No incompatible materials
product in it? present in back area
Trained operators
27. Work tank leaks Unlikely Leak into pit Weekly inspection
(valve, hole)? Located in bunded area
28. Overfill work tank? Unlikely Leak into pit - Only fill to 24 feet of 26 ft.
- Visual gage on side of tank
- Located in bunded area
29. Work tank becomes Remote More ammonia vapors - Open top tank
overheated? released - Ammonia always below
14% in tank
30. Work tank becomes Remote None - Open top tank
overpressurized?
31. Major earthquake? Likely Tank and piping leaks - Tanks designed to Seismic
Zone 4 standards
- Tanks and piping located
in bunded area
32. There is a power Probable Pumps stop - Non black out area
failure? Mixer stops
What-if? Likelihood Potential Existing Controls/ Recommendations
Consequences Prevention Measures
"33. There is a Air not used
compressed air failure?
34. There is a hydraulic Hydraulics not
failure? used
35. There is an None All manual operations
instrumentation or
control room failure?
PACIFIC WOOD BAKERSFIELD FACILITY
WHAT IF/CHECKLIST FORM
Analysis Team: Reese-Chambers, PWP, Borax, Bakersfield Fire Department Date of Analysis: Aug. 2, 2001
System Investigated: Treatment Process
What-if? Likelihood Potential Existing Controls/ Recommendations
Consequences Prevention Measures
1. Leak in piping Remote Leak into pit - Inspection program
between work tank and - ASTM standard tests show
treatment cylinder problem with brass. - No brass
(valve, hole, corrosion)? materials at the facility - No
problems with steel products.
2. Pump fails? Likely Delay of transfer, no - Light on control panel
problems with process - Pumps and valves
controlled from control room
- Swap out pumps
- Clean filters
3. Piping routed to Unlikely Contaminate product - No incompatible materials
wrong location? present in back area
- Status of valves shown in
control room
4. Vehicle/equipment Remote Leak into pit - Piping located inside
runs into piping? bunded area
5. Treatment cylinder Likely Leak - Sequencing won't allow
leaks (door not closed, pump to run when door is
hole in cylinder, gasket open
leak)? - Door closed indicator on
control panel
- Would here hiss if gasket
is leaking during vacuum
What-if? Likelihood Potential Existing Controls/ Recommendations
Consequences Prevention Measures
6o Vacuum not drawn Unlikely None - Vacuum reading displayed
in treatment cylinder? in control room and recorded
on paper
- Door open procedures
allow pressure difference to
equalize through small hole
7. Door opened while Remote None - Vacuum reading displayed
under vacuum? in control room and recorded
on paper
- Can't open due to vacuum
- Door open procedures
allow pressure difference to
equalize through small hole
8. Door opened while Remote Solution released to pit - Pressure reading
under pressure (after displayed in control room and
solution pumped in)? recorded on paper
- Door open procedures
allow pressure difference to
equalize through small hole
9. Treatment cylinder Unlikely Release through safety - Pumps can't exceed
overpresurrized? release valve design pressure of cylinder
- Safety release valves on
piping and cylinder
10. Treatment cylinder Remote Release through - Only liquid in cylinder
overheats? pressure relief valve - Pressure relief valves
11. Transfer pump does Likely None - Light on control panel
not workwhen sending - Pumps and valves
product back to work controlled from control room
tank? Swap out pumps
- Clean filters
What-if? Likelihood Potential Existing Controls/ Recommendations
Consequences Prevention Measures
12. Overfill work tank Unlikely Release into pit Trained operators
when pumping from Visual gauge on work tank
treatment cylinder? Located in bunded area
13. Major rain storm Likely Rain water takes up Bunded area has extra
(impact on sump area room in the pit capacity
below treatment Can pump pit to tank
cylinder)?
14. Overfill work tank Unlikely Release back to sump Trained operators
pumping from sump? Visual gauge on tank
Located in bunded area
15. There is a power Probable Everything electrical All automatic valves close
failure? shuts down including Procedures call for closing
compressor, hydraulic other valves
pump, and control
system
16. There is a Probable No compressed air to All automatic valves would
compressed air failure? operate valves close
17. There is a hydraulic Probable Can't open or close Hydraulics only operate
failure? treatment cylinder door door
18. There is an Probable Can't control or monitor Procedures call for
instrumentation or treatment process shutting down until problem
control room failure? fixed
PACIFIC WOOD BAKERSFIELD FACILITY
WHAT IF/CHECKLIST FORM
Analysis Team: Reese-Chambers, PWP, Borax, Bakersfield Fire Department Date of Analysis: Aug. 2, 2001
System Investigated: ACQ Process
What-if? Likelihood Potential Existing Controls/ Recommendations
Consequences Prevention Measures
1. Tanktruck leaking Unlikely Leak of 8-15% aqueous - Use licensed contractor
when arrives? ammonia - PWP person present
before truck begins transfer
2. Wrong product is Unlikely Contaminate product - Truck placarded
delivered? - Bill of lading checked
3. Leak in transfer Unlikely Release - Truck uses own hose
hose? - DOT certified and tested
hose
- Trained truck operator
- PWP operator present
4. Storage tank Unlikely Leak into pit - Weekly inspection
develops leak? Located in bunded area
5. Storage tank has Unlikely Contaminate product - No incompatible materials
other product in it? present in back area
Trained operators
6. Overfill storage Unlikely Leak into pit - Only fill to 1/3 capacity
tank? - Visual gage on side of tank
Located in bunded area
7. Storage tank Remote More ammonia vapors - Open top tank
becomes overheated? released
What-if? Likelihood Potential Existing Controls/ Recommendations
Consequences Prevention Measures
8. Storage tank Remote None Open top tank
becomes
overpressurized?
9. Transfer piping leaks Unlikely Leak into pit Inspection program
(valve, hole, corrosion)? ASTM standard tests show
problem with brass, o No brass
materials at the facility - No
problems with steel products.
10. Transfer piping Unlikely Contaminate product No incompatible materials
routed to wrong present in back area
tank/location? Manual valves
Trained operators are used
and walk lines before transfer
begins
11. Transfer pump Likely Delay of transfer, no Swap out pumps
doesn't work? problems with process Clean filters
12. Major earthquake? Likely Tank and piping leaks Tanks designed to Seismic
Zone 4 standards
Tanks and piping located
in bunded area
13. Power failure? Probable Pumps stop Non black out area
Mixer stops
14. Compressed air Air not used
failure?
What-if? Likelihood Potential Existing Controls/ Recommendations
Consequences Prevention Measures
15. Hydraulic failure? Hydraulics not
used
16. Instrumentation or None All manual operations
control room failure?
17. Mixing system fails? Unlikely Leak into pit in the event - If pump fails, solution not
of a leak mixed - replace pump
- If piping leaks, it releases
into pit
PACIFIC WOOD BAKERSFIELD FACILITY
WHAT IF/CHECKLIST FORM
Analysis Team: Reese-Chambers, PWP, Borax, Bakersfield Fire Department Date of Analysis: Au§. 2, 2001
System Investigated: Copper/Borate Commercial Mixing Process - IBC Delivery
What-if? Likelihood Potential Existing Controls/ Recommendations
Consequences Prevention Measures
1. IBC leaking when Unlikely Release of at most 55 - Licensed contractor used
delivered? gal of 28% ammonia - DOT certified IBCs
solution - Pressure relief valves in IBC
2. Wrong product is Unlikely Make bad product - Look at bill of lading
delivered? - Each IBC labeled
3. Drop IBC during Unlikely Release of at most one - Designed to withstand
offloading? IBC dropping - have external
frame
- Trained forklift drivers
4. IBC develops leak Unlikely Release one IBC - Move to bunded area and
during storage on site? dilute
- Storage area drains to pit
- IBCs not stacked
5. Vehicle/equipment Remote Cause IBC to leak - Chemicals stored together
runs into IBC while in - IBC has external frame
storage? - No through truck traffic
- Trained operators
6. IBC gets too hot? Likely Liquid vents through - Store out of direct sunlight,
relief valve storage area covered
- IBCs have pressure relief
valves
What-if? Likelihood Potential Existing Controls/ Recommendations
Consequences Prevention Measures
7. IBC gets too cold? Unlikely No impact - Enough air space to allow for
expansion through pressure
relief valve
8. IBC is Unlikely Release of IBC - Two people present to help
dropped/damaged with spotting
during transport to - Trained operators
platform?
9. IBC falls off Unlikely Release of IBC - 2 people present
platform? - IBC has external frame
10. Mistake made during Unlikely - Trained operators
transfer to mixing tank? - Simple procedure; IBC has
connection at bottom of tank;
connect hose and drain to
mixing tank
PACIFIC WOOD BAKERSFIELD FACILITY
WHAT IF/CHECKLIST FORM
Analysis Team: Reese-Chambers, PWP, Borax, Bakersfield Fire Department Date of Analysis: Aug. 2, 2001
System Investigated: Copper/Borate Commercial Mixing Process - Tank Truck Delivery
What-if? Likelihood Potential Existing Controls/ Recommendations
Consequences Prevention Measures
1. Tank truck leaking Unlikely Leak of aqueous Use licensed contractor
when arrives? ammonia PWP person present
before truck begins transfer
2. Wrong product is Unlikely Contaminate product Truck placarded
delivered? Bill of lading checked
3. Leak in transfer Unlikely Release Truck uses own hose
hose? DOT certified and tested
hose
Trained truck operator
PWP operator present
4. Storage tank Unlikely Leak into pit Weekly inspection
develops leak? Located in bunded area
5. Storage tank has Unlikely Contaminate product No incompatible materials
other product in it? present in back area
Trained operators
6. Overfill storage Unlikely Leak into pit Visual gage on side of tank
tank? Located in bunded area
7. Storage tank Remote More ammonia vapors Open top tank
becomes overheated? released
What-if? Likelihood Potential Existing Controls/ Recommendations
Consequences Prevention Measures
8. Storage tank Remote None Open top tank
becomes
overpressurized?
9. Transfer piping Unlikely Leak into pit Inspection program
leaks? ASTM standard tests show
problem with brass. - No brass
materials at the facility - No
problems with steel products.
10. Transfer piping Unlikely Contaminate product - No incompatible materials
routed to wrong present in back area
tank/location? Manual valves
- Trained operators are used
and walk lines before transfer
begins
11. Transfer pump Likely Delay of transfer, no - Swap out pumps
doesn't work? problems with process - Clean filters
12. Major earthquake? Likely Tank and piping leaks - Tanks designed to Seismic
Zone 4 standards
- Tanks and piping located
in bunded area
13. Power failure? Probable Pumps stop - Non black out area
Mixer stops
14. Compressed air Air not used
failure?
What-if? Likelihood Potential Existing Controls/ Recommendations
Consequences Prevention Measures
15. Hydraulic failure? Hydraulics not
used
16. Instrumentation or None All manual operations
control room failure?
17. Unlikely Leak into pit in the event If pump fails, solution not
of a leak mixed - replace pump
If piping leaks, it releases
into pit
Facility Name: Padfic Wood Preserving of Bakersfield, Inc.
EPA ID:
RMP Report for Pacific Wood Prese ing of Bakersfield, Inc.
Section 1. Registration Information
1.1 Source Identification: Facility ID: I There were no reportable accidents in the last 5 years,
a. Facility Name: Pacific Wood Preserving of Bakersfield, Inc.
b. Parent Company #1 Name:
c. Parent Company #2 Name:
:1.2 EPA Facility Identifier:.
1.3 Other EPA Systems Fadlity ID:
1.4 Dun and Bradstreet Numbers (DUNS):
a. Facility DUNS: 118810514
b. Parout Company #1 DUNS:
c. Parent Company #2 DUNS:
1.5 Facility Locatiou Address:
a. Street 1: 5601 District Blvd.
b. Street 2:
c. City: Bakersfield d. State: CA eo Zip: 93313 .
f. Coultty: Kern
facility Latitude and Lon~itnde:
g. Lat. (ddmmss.s): 35 18 46.4 IL Long. (dddmmss.s): -I 19 03 54.8
I, I. at/Long Methnd: A1 Address Matching * House Number
J, Lat/Long Description: AB Administrative Building
1.60wnor or Operator:.
a. Name: Ron Laughlin
b. Phone: (661) 83:3.0429
Mailing address:
C. Street 1: 5601 District Blvd. d. Street 2:
e. City: Bakersfield f. State: CA g. ZIp: 93313 ,
1.7 Name and flue of person or position responsible for part 68 (RMP) implementation:
08/22/2001 12:42:48 PM Page 1 of 8
Facility Name: Pacific Wood Preserving of Bakersfield, Inc.
EPA ID:
a. Name of person: Ron Saylor
b. Title of person or position: Environmental Health & Safety Mgr.
1.8 Emergenc~ contact:
a. Name: Rick McCullough
b. Title: Operations Manager
c. Phoae: (66]) 833-0429
d. 24-1tour phone: (66]) 836-3304
e. Ext. or PIN:
1.9 Other p~nts of contact:
a. Facility or Parent Company E-Mail Address: ron.saylor@pacificwood.com
b. Facility Public C,intact Phone: (661) 833-0429
c. Facility or Parent Company WWW Hon~page Address: www.pacificwood.com
1.10 LEPC:
1.11 Number oi lull Ume employees on site: 35
a. OSHA PSM: No
b. EPCRA 302: Yes
c. CAA TIUe V: No Air operating permit ID:
1.13 OSHA Star Or Merit Ranking: No
1.14 Last Safety Inspection (by an E~ternsl Agency) Date: 06/26/2001
1.15 Last Safety laspoction Performed by alt External Ageltcy: Bakersfield Environmental Services
1.16 Will this RMP invelve predictive filing?: No
Section 1.17 Process(es)
a. Process ID: 1 Program Level 2 Wood preserving
b. NAICS Code
321114 Wood Preservation
c. Process Chemicals
c. 1 Process Chemical (ID / Name) c.2 CAS Nr. c.3 Qty (lbs.)
08/22/2001 12:42:49 PM Page 2 of 8
Facility Name: Pacific Wood Preserving of Bakersfield, Inc.
EPA E~.
I Ammonia (conc 20% or 8renter) 7664-43.-7 18,000
a. Process ID: :~ Program Level I CCA
b. NAICS Code
321] 14 Wood Preservation
C. Process Chemicals
C.1 Process Chemical (ID / Name) c.2 CAS Nr. c.3 ~ Obs.)
2 Arsenic pentoxide 1327-52-2 27,000
Section 2. Toxics: Worst Case
Toxics: Worst Case ID: 1
2.1 a. Chemical Name: Ammonia (conc 20% or greater)
b. Porca~t Weight of Chemical (if In a rnl~tore): 20.0
2.2 Physical State: Liquid
2,3 ~xlel nsed: EPA's OCA Guidance Reference Tables or Equations
2.4 Scenalio: Liquid spill & Vaporization
2.5 ~kmntlly released: 16,600 lbs
2.6 Release rate: 420.0 lbs/rain
2.7 Release duration: ]0.0 milts
2.8 Wind speed: 1.5 m/sec
2.9 Atmusl~herlc Stability Class: F
2.10 Topography: Urban
2.11 Distance to Endpelnt: 0.40 mi
2.12 Estimated Residential polmlaflon within distance to endpolnt: 320
2.13 Public receptors within distance to endpolnt:
a. Schools: No d. Prlsees/Corregtlee facilities: No
b. Residences; Yes e. Recreation areas: No
c. Hospitals: No f. Major commercial, office or, Industrial areas: Yes
g. Other (Specily):
2.14 Environmental receptors within distance to endpolnt:
a. National or state parks, forests, or monuments: No
b. Officially designated wildlife sanctuaries, preserves, m, refuges: No
c. Federal wildumess areas: No
d. Other (Spedfy):
2.15 Passive mitigation considered:
a. Dikes: Yes d. Drains: Yes
08/22/2001 12:42:50 PM Page 3 of 8
Facility Name: Padfic Wood Preserving of Bakersfield, Inc.
EPA ID:
b. £eClo~ures: Yes e~ Sumps: Yes
c. Befms: Yes f. Other (Specify):
2.16 Graphic file name:
Section 3. Toxics: Alternative Release
Toxics: Alternative Release ID:
3.1 a. Chemical Name: Ammonia (conc 20% or greater)
b. Percent Weight o! Chemical (if In a mixture): 28.0
3.2 Physical State: Liquid
3.3 Model: £PA's OCA Guidance Reference Tables or Equations
3.4 $ceearlo: Vessel leak
3.5 Quantity released: 1,83o lbs
3.6 Release rate: 45.9 Ibs/mln
3.7 Release duration: 10.0 mina
3.8 Wind speed: 3.0 m/snc
3.9 Atmospheric Stability Class: D
3.10 Topography:. Urban
3.11 Distance to Endpolnt: 0.06 mi
3.12 Estimated Resideatial population within distance to emipulnt: 0
3.13 Public receptors within distance to eedpoint:
a. Schools: No d. Prtsoes/Co~nction facilities: No
b. Residences: No e. Recrnation areas: No
c. Hospitals: No f. Major tommee:Iai, office, or Imiustrlal areas: No
g. Other (Specify):.
3.14 Envirenmentaf receptors within distance te endpelnt:
a. National or state psdcs, forests, or moeumenta: No
b. Officially designated wildlife sanclnarJes, preserves, or refuges: No
c. Federal wilderness areas: No
3.15 Passive mitigation cons/tiered:
a. Dikes: No d. D~ales: No
b. En<:Jesures: No e. SlUmps: Yes
C. BetlltS: Yes f. Other (Specify):
3.16 Active mltlption considered:
a. Sprinkler systems: No i. Flares: No
b. Deluge system: No g. Scrubbers: No
08/22/2001 12:42:50 PM Page 4 of 8
Facility Name: Pacific Wood Preserving of Bakersfield, Inc.
EPA ID:
c. Water curtain: No h. Emergency shutdown systems: No
d. Neutralization: Yes i. Other (Specify):
e. Excess flew valve: No
3.17 Graphic file name:
Section 4. Flammables: Worst Case --- No Data To Report
Section S. Flammables: Alternative Release --- No Data To Report
Section 6. Accident History --- No Data To Report
Section 7. Prevention Program 3 --- No Data To Report
Section 8. Prevention Program 2
Process ID: I Wood preserving
Prevention Program ID: 1
Presentioe Program DescrIptioe: Copper/borate and ACQwood preserving solutions are mixed onsite using aqueous
ammonia as one of the components. Solutions are then pumped to wood filled
treatment cylinderto treat the wood.
B.1 NAICS Code'. 3211~4
8.2 Chemicals: Chemical Name
Ammonia (conc 20~o or greater)
8.3 Safely IrdormaUon:
a. The date of the most recent review or revision of the safely information: 08/02/2001
b. Select all Federal or state rngulaflons or Industry-specific design codes and standards used to demoestrate
compliance with the safety intormation requirement:
NFPA 58 (or state law based on NFPA 58): No ANSI Stsrldards: Yes
O~HA (29 CFR 1910.111): No ASM£ Staudard$: Yes
ASTM Standards: Yes None: No
Other (Specify):
Commeets:
8.4 Hazard review:
a. The date of completion ol most recent hazard review or update: 08/02/2001
b. The eq~ected or actual date of completion of all changes resulUng from the hazard review: 08/06/2001
c. Major hazards identified:
Toxic release: Yes OverpressurIzation: No Earthquake:
No
08/22/2001 12:42:50 PM Page 5 of 8
Facility Name: Pacific Wood Preserving of Bakersfield, Inc.
EPA [~.
Fire: No Corrosion: No Floods (flood plain):
No
Explosion: No Overfilling: No Tornado:
No
Runaway reaction: No Contamination: No Hurricanes:
No
Polymerization: No Equipment failure: No Other (Specify):
Loss of cooling, heating,
electricity, instrument air: No
d. Process coofrofs Jn use:
Vents: Yes Emergency air supply:. No Other (Specify):
Relief eal~ns: Yes Emergency power:. No
Check valves: No Backup pump: No
Scmbi)ers: No Grounding equipment: No
Flares: No inhibitor addition: No
Manual shutoffs: Yes Rupture disks: No
Antonmifc shutcfffs: Yes Excess flo~ device: No
Interlocks: Yes (Duem:h system: No
Alarms and procedures: Yes Purge system: No
Keyed bypass: No None: No
e. Mitigation systems In use:
Slxhtlder system: No Water Curtain: No
Dikes: Yes Enclosure: No
Fire walls: No Neutralization: Yes
Blast walls: No Hone: No
Deluge system: No O~her (Specify):
f. Monltoring/dntectioe systems in use:
Process area detesters: No No~te: No
Perimeter monitors: No Other (specify): Operator inspections
g. Changes since last hazard review or hazard review update:
Reduction in chemical inventory: No InataliaUon of perimeter monitoring systems: No
Increase in chemical inventory: Yes Installation of mitigation systems: No
Change process parameters: No None recommended: No
InstallaUon of process cmttrels: No None: No
Installation of process detecUon systems: No Other (Specify):
8.5 The date of the most recent review or revision of operating procedures: 08/02/2001
8.6 Training:
08/22_/2001 12:42:51 PM Page 6 of 8
Facility Name: Pacific Wood Preserving of Bakersfield, Inc,
EPAI~
a. The date of the most recent revie~ or revision of training programs: 021141200!
b. The type of training provided: Classroom: Yes On the job: Yes
Other training (Specify):
c. The type of competency testing used:
Written tests: Yes Observation: Yes
Oral tests: Yes Other (Specify):
Demonstration: Yes
8.7 Maintenance:
a. The date of the most recent review or revision of maintenance preceduros: 05/02/200!
b. The date of the most recent equipment inspection or test: 08/02/2001
c. Equipment most recently Inspected or tested: all tanks, valves, and fittings
8.8 Compliance audits:
a, The date of the most recent compllanc~ audit: 08/02/200]
b. Expected or actual date of completion of all changes resulting from the compliance audit: 08/06/200!
8.9 Incident investigation:
a. The date of the most recent incident Invesfigatien (if any):
b. Expected or actual date of completion of all changes resulting front the investigation:
8.10 The date of the most recent change that triggered a review or revision of safety
information, the hazard review, operating or maintenance procedures, or training: 08/o2/2001
Se~ion 9. Emergency Response
9.! W~itton Emor~e~y Respe~ ~ Plan:
a. Is facility Included in wrltton community emergency response plan? No
b. Does tacttity have its own written emergency respOnSe plan? Yes
9.2 Does tacilJty's ER plan include specific actions to be taken In respeese to
accidental ruieases of regulated substance(s)? Yes
9.3 Does faciltiy's ER plan Include procedures for intormlng the public aed local agencies
responding to accidental releases? Yes
9.4 Does facility's ER plan Include Infevmation on emergency heath care?
Yes
9.5 Date of most recent review or update of facility's ER plan: 02/14/2001 -
9.6 Date of most recent ER training for facility's employees: 07/10/2001
08/22/2001 12:42:51 PM Page 7 of 8
Facility Name: Pacific Wood Preserving of Bakersfield, Inc.
EPA ID:.
9.7 Local a~ency with which facility's ER plan or response activities are coordinated:
a. Name ol ageecy: Bakersfield Office of Environmental
b. Telephone number: (661) 324-4542
9.8 Subject to:
a. OSHA Regu)allons at 29 CFR 1910.38: Yes
b. OSHA Regulations at 29 CFR 1910.120:. Yes
c. Clean Water Act RegulaUons at 40 CFR 112: No
d. RCRA Regulations at 40 CFR 264, 265, and 279.52: Yes
e. OPA-90 Re~ulaUons at 40 CFR 112, 33 CFR 154, 4.9 CFR 194, or 30 CFR 254: No
t. State EPCRA Rules/Law: Yes
Executive Summa~
Pacific Wood Preserving (PWP) presently has a Program 1 Risk Management Plan (RMP) in place. The purpose of this update to the
AMP is to address some additional wood treating processes that utilize aqueous ammonia in the treatment solution. The use of
(:~'n~c~o~ ammonia elevates the AMP to a Program 2 level. The process covered in the prior Program 1 AMP is also addressed in this
updated AMP.
Three wood treatment processes have been addressed in this AMP. The first two involve the use of aqueous ammonia and are
classified as Program 2, while the third uses arsenic pentoxide in solution and is classified as Category ]. Each of the processes is
summarized below.
The copper/borate treatment process is being conducted as a plant research project to evaluate the process. This process will initially
bring in 28% aqueous ammonia in 55-gallon drums and dilute and mix it with other chemicals in a 2,000-gallon mixing tank to form
a wood treatment solution that will contain 2% ammonia. This 2% solution will be stored in a 36,000-gallon work tank. Wood is put
in a treatment cylinder and the copper/borate solution is pumped into the cylinder to treat the wood. After the treatment process is
completed, the remaining solution is pumped back to the work tank. Additional solution is prepared and added to the work tank as
necessary. If the treatment process proves successful, the copper/borate solution will either be brought on site pre-mixed with no more
than 4% ammonia or mixed on site using aqueous ammonia in concentrations less than 20%.
The ACQ treatment process brings in aqueous ammonia in concentrations up to 15% ammonia by tank truck and stores the liquid in a
17,000.gallon tank. The ACQ solution is then made on site and stored in a 36,000-gallon work tank. Wood is treated using this ACQ
solution in the same manner as described above for the copper/borate solution.
The above two processes are treated as a single process in the AMP analysis because ali et the tanks are interconnected with piping.
The CCA wood treatment process uses a solution that contains arsenic acid (arsenic pentoxide) which is on the California regulated
substances list. The CCA is delivered as a 60% solution, the other 40% being water, by truck in quantities of 50,000 lbs. A working
solution of approximately 2% CCA is produced by adding concentrate and water in one of the work tanks. The solution is then used to
treat wood in the same manner as described above.
A hazard analysis using the "what if/checklist" methodology has recently been conducted on both acqueous ammonia processes. Five
mitigation measures were recommended and all have been implemented. A hazard analysis addressing the CCA process was previously
conducted.
08/22/2001 12:42:51 PM Page 8 of 8