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HomeMy WebLinkAboutRISK MANAGEMENT (2)PILLSBURY BAKERIES AND FOODSERVICE Risk Management Plan Prepared for Pillsbury Bakeries and Foodservice 6800 McDivitt Drive Bakersfield, CA 93313 June, 1999 ., LUFr Engineers & Environmental Consultants, Inc. 2029 21st Street Bakersfield, CA 93301 PILLSBURY BAKERIES AND FOODSERVICE RISK MANAGEMENT PLAN TABLE OF CONTENTS 1.0 2.0 3.0 4.0 5.0 Introduction 1.1 1.2 1.3 1.4 1.5 1.6 Federal and State Regulations Applicability RMP Submission RMP Review Process RMP Updates Covered Process Modification General Requirements 2.1 Purpose and Scope 2.2 CalARP Program Management 2.3 Emergency Information Access 2.4 Registration Executive Summary 3.1 3.2 3.3 3.4 3.5 3.6 3.7 Accidental Release Prevention and Emergency Response Policies Description of the Stationary Source and Regulated Substances Worst-Case Release Scenario and Alternative Release Scenario General Accidental Release Prevention Program and Chemical- Specific Prevention Steps Five-Year Accident History Emergency Response Program Planned Changes To Improve Safety Five-year Accident History Overview of Program 3 Prevention Program 5.1 5.2 5.3 5.4 5.5 5.6 5.7 5.8 5.9 Description of Prevention Program Process Safety Information Process Hazard Analysis Operating Procedures Training Mechanical Integrity Management of Change Pre-Startup Review Compliance Audits 6.0 7.0 8.0 9.0 5.10 5.11 5.12 5.13 5.14 Incident Investigation Employee Participation Hot Work Permit Contractors External Events Analysis RMP Offsite Consequence Analysis 6.1 6.2 6.3 6.4 6.5 6.6 Scenarios to be Analyzed Compounds Included in the Offsite Consequence Analysis Worst Case Release Scenario Alternative Release Scenario Population Impacts Environmental Impacts Overview of Emergency Response Program 7.1 CalARP and EPCRA Requirements 7.2 Facility Emergency Planning and Response Other 8.1 8.2 8.3 8.4 8.5 Requirements Recordkeeping Audits Inspections Availability of Information to the Public Permit Content and Permitting Authority RMP Certification Appendix A Appendix B Appendix C RMP*Submit State-Only Requirements Sensitive Receptor Information I"1'1 --I Z 0 1.0 INTRODUCTION 1.1 Federal and State Regulations Amendments to the federal Clean Air Act (CAA) were signed into law on November 15, 1990 adding Section 112(r), which established the accidental release prevention program. The purpose of this program is to prevent the accidental release and to minimize the consequences of a release of a regulated substance. Section 112(r)(1) of the federal Clean Air Act states that the owners and operators of stationary sources producing, processing, handling or storing such substances have a general duty to: · Identify hazards which may result from such releases using appropriate hazard assessment techniques, · Design and maintain a safe facility taking such steps as are necessary to prevent releases, and · Minimize the consequences of accidental releases which do occur. The U.S. Environmental Protection Agency (EPA) is mandated under the Clean Air Act to establish rules and guidance for chemical accident prevention. On June 20, 1996, EPA promulgated regulations in Part 68 of Title 40 of the Code of Federal Regulations (40 CFR Part 68) that require sources to develop and implement risk management plans (RMP). The 1990 CAA Amendments also required that the Secretary of Labor promulgate a chemical process safety standard designed to protect employees from hazards associated with accidental releases of highly hazardous chemicals in the workplace. In February, 1992, the Occupational Safety and Health Administration (OSHA) published the Process Safety Management (PSM) Standard. EPA has incorporated OSHA's PSM requirements into the accidental release prevention program. California adopted an almost identical PSM program under Section 5189, Title 8, California Code of Regulations in January, 1994. California State Senate Bill 1889 requires California to implement the federal accidental release prevention program. Effective January 1, 1997, state law under Chapter 6.95, Article 2, of the California Health & Safety Code was amended, replacing the Risk Management and Prevention Program (RMPP) with the California Accidental Release Prevention Program (CalARP). The legislation June, 1999 Page 1-1 z~LUFr also required the Governor's Office of Emergency Services (OES) to adopt implementing regulations and seek delegation of the program from the U.S. EPA. OES obtained delegation from the U.S. EPA and issued final CalARP regulations on November 16, 1998. These regulations are contained in Chapter 4.5, Division 2, Title 19, of the California Code of Regulations (CCR). The CalARP regulations require the completion and submission of a Risk Management Plan (RMP) to the local Administering Agency (AA). This document was prepared to meet the requirements of the CalARP regulations. 1.2 Applicability The CalARP regulations apply to the owner or operator of a stationary source which handles more than a threshold quantity of a regulated substance in a process. Regulated substances are listed in three separate tables in Section 2770.5 of the CalARP regulations. At the Pillsbury Bakeries and Foodservice (Pillsbury) Bakersfield facility, there is one process that handles a regulated substance above the threshold quantity. The refrigeration system utilizes anhydrous ammonia as a refrigerant to provide process cooling for the spiral freezers, water and glycol chiller system, and cold storage. The anhydrous ammonia is present in the refrigeration system above the threshold quantity of 10,000 pounds listed in Table 1 in Section 2770.5. Under the federal accidental release prevention regulations, the U.S. EPA has classified processes into three categories ("Programs"), based on size and potential risk. Pillsbury's ammonia-based refrigeration system is classified as a Program 3 process and is also subject to PSM. A PSM program has been developed for Pillsbury. Section 5 of this RMP provides a brief overview of the PSM program. 1.3 RMP Submission The owner or operator of a stationary source, which handles more than a threshold quantity of a regulated substance in a process, shall submit a single RMP to the AA. If a stationary source has a process with more than a threshold quantity of a regulated substance as listed in Table 1 or 2 in Section 2770.5, the owner or operator shall submit the RMP no later than the latest of the following dates: · June 21, 1999; Three years after the date on which a regulated substance is first listed under Section 68.130, 40 CFR Part 68; or June, 1999 Page 1-2 ~LUFr The date on which a regulated substance is first present in a process, above the threshold quantity, as listed in Section 2770.5 Table 1 or 2, Chapter 4.5, Division 2, Title 19, CCR. RMP information required by the U.S. EPA must also be submitted by the above- listed dates to the U.S. EPA and to the AA. The U.S. EPA required information must be submitted on diskette along with the certification statement to the RMP Reporting Center, P.O. Box 3346, Merrifield, VA 22116-3346 by regular mail. If sent by certified mail or overnight mail, this information must be sent to the RMP Reporting Center, c/o Computer Based Systems, Inc., 4600 North Fairfax Drive, Suite 300, Arlington, VA 22203. RMP*SubmiFM is the software that has been developed by the U.S. EPA for submitting the RMP. A hard copy of the RMP*Submit information is included in Appendix A. 1.4 RMP Review Process 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 and shall be submitted to the AA. The AA shall publish the initial notice in a local newspaper of general circulation that the RMP has been submitted and the AA has initiated the process for government and public review. The AA shall review the RMP to determine if all of the required elements are contained in the document and provide a written notice to the owner or operator of any deficiencies. If no deficiencies are identified, the AA shall accept the RMP as complete and submit the RMP for formal public review. Within 15 calendar days after the AA determines that the RMP is complete, the AA shall make the RMP available to the public for formal review and comment by publishing a notice in a local newspaper of general circulation. The public shall have 45 calendar days to comment following the publication date of the notice. An evaluation review shall be conducted by the AA at the end of the formal public review period. The AA shall take the public comments into consideration during the evaluation period. The AA shall consider standard application of engineering and scientific principles, site specific characteristics, technical accuracy, severity of offsite consequences, and other information in the possession of or reviewed by the AA. The evaluation review shall be completed within either 24 or 36 months, depending on the type of process. The public shall have access to the RMP, including any electronic data developed as part of the U.S. EPA reporting requirements. Classified information June, 1999 Page 1-3 ~LUFD need not be included. Trade secrets are protected pursuant to Section 25538 of the California Health and Safety Code. 1.5 RMP Updates The owner or operator of a stationary source shall revise and update the RMP as follows: (1) Within five years of its initial submission or most recent update required by (2) through (7) below, whichever is later; (2) No later than three years after a newly regulated substance is first listed by the U.S. EPA. (3) No later than the date on which a newly regulated substance is first present in an already covered process above a threshold quantity; (4) No later than the date on which a regulated substance is first present above a threshold quantity in a new process; (5) Within six months of a change that requires a revised Process Hazard Analysis (PHA) or hazard review; (6) Within six months of a change that requires a revised offsite consequence analysis; (7) Within six months of a change that alters the Program level that applied to any covered process. Revised RMPs shall be subject to the public review process described in Section 1.4. Within 30 days of a change in the owner or operator, the new owner or operator shall contact the AA to update the registration information. The new owner or operator shall determine if RMP changes are necessary. 1.6 Covered Process Modification When an owner or operator intends to make a modification to a stationary source relating to a covered process, the requirements of Section 2745.11 of the CalARP regulations must be met. These requirements apply if the modification may result in a significant increase in either of the following: June, 1999 Page 1-4 z'JLUFr The amount of regulated substances handled at the stationary source as compared to the amount of regulated substances identified in the stationary source's RMP; or The risk of handling a regulated substance as compared to the amount of risk identified in the stationary source's RMP. Section 2745.11 requires the owner or operator intending to make a modification to do all of the following: (1) Where reasonably possible, notify the AA in writing of the owner or operator's intent to modify the stationary source at least five calendar days before implementing any modifications. As part of the notification process, the owner or operator shall consult with the AA when determining whether the RMP should be reviewed and revised. Where prenotification is not reasonably possible, the owner or operator shall provide written notice to the AA no later than 48 hours following the modification. (2) Establish procedures to manage the proposed modification and notify the AA that the procedures have been established. The owner or operator of the stationary source shall revise the appropriate documents expeditiously, but not later than 60 days from the date of the stationary source modification. June, 1999 Page 1-5 z'~LUFr 2.0 GENERAL REQUIREMENTS 2.1 Purpose and Scope California's Accidental Release Prevention (CalARP) regulations require the owner or operator of a stationary source which handles more than a threshold quantity of a regulated substance in a process to develop and submit a Risk Management Plan (RMP). Pillsbury Bakeries and Foodservice (Pillsbury)'s facility in Bakersfield, California utilizes a refrigeration process that handles ammonia, a regulated substance, in quantities greater than the threshold quantity. The CalARP regulations implement the federal accidental 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 which has been developed for Piilsbury's Bakersfield facility. In accordance with the regulations, this program incorporates a management system, a hazard assessment, a prevention program, and an emergency response program. Pillsbury's ammonia- based refrigeration system is classified as a Program 3 process, and therefore, must comply with the requirements of Section 2735.5(f) of the CalARP regulations. 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. When responsibility for implementing individual requirements of the CalARP program is assigned to persons other than the one described above, the names or positions of these people shall be documented and the lines of authority defined though an organization chart or similar document. Pillsbury has assigned overall responsibility for the development, implementation, and integration of the RMP elements to the Plant Manager. An organization chart which defines the lines of authority for implementing individual elements of the RMP is provided as Figure 2.1. June, 1999 Page 2-1 ~LUFr Plant Manager Quality, Sanitation, and Safety Manager Plant Operators Maintenance Manager Mechanics Technicians RMP ORGANIZATION CHART Pillsbury Bakeries and Foodservice Figure 2.1 2.3 Emergency Information Access Section 2735.7 of the CalARP regulations states that the 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. 2.4 Registration Registration information listed in Section 2740.1 of the CalARP regulations must be completed and submitted with the RMP to the U.S. EPA. A copy of this information must be provided to the AA. Appendix A includes a hard copy of the RMP*Submit information that has been transmitted to the U.S. EPA. Section 1 of the enclosed RMP*Submit forms, included in Appendix A, contains the required registration information. June, 1999 Page 2-2 z~.UFr I"11 --I Z ? 3.0 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 Pillsbury Bakeries and Foodservice (Pillsbury) utilizes anhydrous ammonia in the refrigeration system at their Bakersfield production facility. It is Pillsbury's policy to comply with all applicable governmental regulations. Further, it is Pillsbury's objective to be a responsible citizen of the community in all of its business activities. Pillsbury emphasizes safe and environmentally sound operating practices and procedures through their employee training programs. In addition to job specific training, operators and maintenance personnel receive training in accident prevention, safety, and first aid. Additionally, an emergency action plan has been prepared for Pillsbury and a chain of command to respond to emergencies has been established. Pillsbury has developed a detailed Compliance Audit Checklist which is used to evaluate compliance with the Process Safety Management (PSM) and CalARP regulations. At least every three years, Pillsbury will audit these programs and any findings of noncompliance will be documented and responded to and the deficiencies will be corrected. 3.2 Description of the Stationary Source and Regulated Substances Pillsbury owns and operates a bakery products production facility located at 6800 McDivitt Drive in Bakersfield, California. The plant began operation in July, 1991. The refrigeration system was upgraded in 1992. Figure 3.1 shows the location of the facility. The ammonia based refrigeration system at Pillsbury provides cooling for the process equipment and finished product storage and handling areas. The major components of the refrigeration system are the booster compressors, intercooler, high stage compressors, evaporative condensers, thermosyphon receiver, controlled pressure receiver, glycol chiller, process water chiller, evaporators, and a suction accumulator. The system is also equipped with an air purger, oil drain pot, emergency ventilation system, and an emergency refrigeration control box which discharges to a scrubber tank. Volume I, Section II of the PSM Supporting Document describes the ammonia refrigeration process in detail. June, 1999 Page 3-1 ~LUFr During normal operation, the anhydrous ammonia is distributed throughout the refrigeration system. However, during major maintenance activities, the entire refrigeration system can be "pumped down" to evacuate the ammonia from the system and store it in the controlled pressure receiver. The maximum quantity of ammonia that can be stored in the controlled pressure receiver is approximately 17,700 pounds. The characteristics and hazards of anhydrous ammonia are discussed briefly in Section 6.0 of this document and more extensively in Volume I, Section II of the PSM Supporting Document. For purposes of the offsite consequence analyses, 40 CFR Part 68 and the CalARP regulations define the toxic endpoint for anhydrous ammonia as 0.14 mg/I (200 ppm). A concentration of 200 ppm 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. 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 and 40 CFR Part 68 require the owner or operator of a stationary source to analyze the offsite impacts due to an accidental release of a regulated substance. The offsite consequence analysis for a Program 3 process must analyze the worst-case release scenario and an alternative release scenario. Since Pillsbury's ammonia-based refrigeration system is considered a Program 3 process, both release scenarios were evaluated in the offsite consequence analysis. The offsite consequence analysis must include an estimate of the residential population within an area potentially affected by the accidental release scenario. This area is defined as a circle with a 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 is defined by the U.S. EPA as the total release of the contents of the single largest vessel or pipe within 10 minutes. For liquefied gases stored under pressure, the entire contents of the vessel or pipe are assumed to be released as a vapor. A total vapor release is highly unlikely. June, 1999 Page 3-2 ~LUFr However, this standardized worst case scenario was developed for emergency response agencies to use for planning purposes. An alternative release scenario is a release that is more likely to occur than the worst-case release scenario. For Pillsbury, the alternative release scenario was selected based on the results of the Process Hazard Analyses (PHAs) for the ammonia-based refrigeration system. A credible release event with a high discharge rate would potentially have the greatest offsite impact. A leak from a valve packing was identified in the PHAs as having a medium probability of occurrence with a discharge rate high enough to cause an offsite impact, and therefore, was chosen as the alternative release scenario. Pillsbury has analyzed the offsite consequences of the worst-case and alternative release scenarios, as documented in Section 6.0 of the RMP. For the worst-case release scenario, the release of approximately 17,700 lbs. of ammonia over a 10 minute period within the engine room, the plume would travel 1.2 miles at concentrations at or above the endpoint. Sensitive receptor information is provided in Section 6.0 and in Appendix C. Using 1990 Census data, the population potentially affected within the worst-case release scenario circle is 13,000 people. There are no environmental receptors within the worst case release scenario circle. In the alternative release scenario, a packing leak from an isolation valve located outdoors on the roof was modeled as a release of liquefied ammonia stored under pressure. For a release of 22 Ib/min of anhydrous ammonia, the model calculated that the plume would travel less than 0.1 mile at concentrations at or above the endpoint. The alternative release scenario circle includes the nearby industrial facilities and roadways. No residences are located within the 0.1 mile radius of the location of the alternative release at the Pillsbury facility. As such, there would be no population impacts from the alternative release scenario. There were also no sensitive receptors or environmental receptors within the alternative release scenario circle. The ammonia refrigeration equipment is located within buildings except for a few pipelines and isolation valves located on the roof. Even without consideration of the emergency ventilation and scrubbing systems, the potential impact from a release within a building would be greatly reduced according to EPA's Offsite Consequence Analysis Guidance. If a release were to occur in the engine room, the emergency ventilation and scrubbing systems would further reduce any potential offsite impacts. The modeling performed for the worst-case release scenario includes a mitigation factor which assumes that the release is within an enclosed space, in direct contact with the outside air. June, 1999 Page 3-3 ~LUFr 3.4 General Accidental Release Prevention Program and Chemical- Specific Prevention Steps A PSM program, which meets the requirements of the general accidental release prevention program, has been developed at Pillsbury to address the anhydrous ammonia system. The PSM program, which is described in Section 5.0 of the RMP, includes the following chemical-specific prevention steps: Written process safety information, including information pertaining to the hazards of ammonia, the technology of the process, and the equipment in the process has been compiled. An initial Procbss Hazard Analysis (PHA) was performed and will be updated and revalidated at least every five years. Written operating procedures have been developed and implemented, and are reviewed at least annually. Safe work practices, such as Iockout/tagout, confined space entry, opening process equipment or piping, and control over entrance into the facility have been developed and implemented. Each employee involved in operating the ammonia system has received initial training and refresher training at least every three years. Written mechanical integrity procedures have been established and implemented. A Management of Change (MOC) program has been developed and implemented to address all proposed changes to the ammonia system. Pre-startup safety reviews are performed when a modification is made to the ammonia system that is significant enough to require a change in the process safety information. Audits are conducted at least every three years to evaluate compliance with the CalARP regulations. Incident investigation procedures have been established. A written plan of action regarding the implementation of employee participation has been developed and implemented. June, 1999 Page 3-4 ..dLUFr Hot work permits are issued for all hot work operations conducted on or near the ammonia system. A Contractor Safety Policy has been developed and implemented. To ensure that the general accidental release prevention program and the chemical-specific prevention steps are implemented, Pillsbury has assigned overall responsibility for the RMP elements to the Plant Manager. The Plant Manager has the overall responsibility for the development, implementation, and integration of the RMP elements. 3.5 Five-Year Accident History As discussed in Section 4.0 of this document, Pillsbury has not had any accidental releases from the ammonia-based refrigeration system 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. 3.6 Emergency Response Program Pillsbury has established an emergency action plan and a chain of command to respond to emergencies and to notify emergency responders when there is a need for a response. These procedures are described in Section 7.0 of the RMP. 3.7 Planned Changes To Improve Safety Based on the PHA revalidation performed in June, 1999, no changes were recommended. Section 5.0 describes the accidental release prevention program in place at Pillsbury. Through this program, Pillsbury regularly evaluates the need for any changes to improve safety. Currently, Pillsbury does not have any additional changes planned to improve safety. June, 1999 Page 3-5 ~LUFr 4.0 FIVE-YEAR ACCIDENT HISTORY Section 2750.9 of the CalARP regulations requires the owner or operator to include in the RMP a discussion of the five-year accident history at the facility. The accident history shall include information on all accidental releases from covered processes that resulted in deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage. Pillsbury Bakeries and Foodservice has not had any accidental releases from covered processes at their Bakersfield facility 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. June, 1999 Page 4-1 z'JLUFr 5.0 OVERVIEW OF PROGRAM 3 PREVENTION PROGRAM 5.1 Description of Prevention Program Pillsbury Bakeries and Foodservice (Pillsbury)'s ammonia-based refrigeration system is classified as a Program 3 process under the federal and California accidental release prevention regulations. Therefore, Pillsbury must comply with the requirements of Section 2735.5(f) of the CalARP regulations. Section 2735.5(f) states that the owner or operator of a stationary source with a process subject to Program 3 shall: (1) Develop and implement a management system as provided in Section 2735.6; (2) Conduct a hazard assessment as provided in Sections 2750.1 through 2750.9; (3) Implement the prevention program requirements of Section 2760.1 through 2760.12; (4) Develop and implement an emergency response program as provided in Sections 2765.1 to 2765.2; and, (5) Submit as part of the RMP the data on prevention program elements for Program 3 processes as provided in Section 2745.7. The CalARP program management system required by Section 2735.6 has been developed and implemented by Pillsbury, as discussed in Section 2.2 of this document. Pillsbury conducted a hazard assessment in accordance with Sections 2750.1 through 2750.9. The hazard assessment is presented in Section 6.0 of the RMP. The emergency response program at Pillsbury, which meets the requirements of Section 2765.1 and 2765.2, is described in Section 7.0. Pillsbury developed and implemented a Process Safety Management (PSM) program which is consistent with the prevention program requirements of Section 2760.1 through 2760.12. The PSM program for the Pillsbury is described in detail in the PSM Supporting Document, Volumes I and II. The elements of the Program 3 prevention program and the PSM program are briefly discussed below in Sections 5.2 through 5.14. June, 1999 Page 5-1 ~:~LUFr The data on the prevention program elements listed in Section 2745.7 of the CalARP regulations is provided in Section 7 of the RMP*Submit forms. These forms are included in Appendix A of this document. Since RMP*Submit was developed by the U.S. EPA, only the federally required data elements are included on these forms. The external events analysis information required by Section 2745.7(q) of the CalARP regulations is not included in RMP'Submit; therefore, it is addressed in this section of the RMP. 5.2 Process Safety Information The CalARP regulations and the PSM regulations require the owner or operator to complete a compilation of written process safety information. This compilation is-to enable the owner or operator and the employees involved in operating the process to identify and understand the hazards posed by those processes involving regulated substances. The process safety information shall include information pertaining to the hazards of the regulated substances used or produced by the process, information pertaining to the technology of the process, and information pertaining to the equipment in the process. Pillsbury compiled the process safety information in Volume I, Section II and Volume II, Section I of the PSM Supporting Document. Information is provided on the health and physical hazards of anhydrous ammonia, the technology of the ammonia-based refrigeration system which utilizes anhydrous ammonia, and the equipment in the process. 5.3 Process Hazard Analysis The owner or operator is required to perform an initial Process Hazard Analysis (PHA) on processes covered by the CalARP regulations. The PHA shall be appropriate to the complexity of the process and shall identify, evaluate, and control the hazards involved in the process. To assure that the PHA is consistent with the current process, the PHA shall be updated and revalidated at least every five years after completion of the initial PHA. The PHA shall address: (1) The hazards of the process; (2) The identification of any previous incident which had a likely potential for catastrophic consequences; (3) Engineering and administrative controls applicable to the hazards and their interrelationships such as appropriate application of detection methodologies to provide early warning of release. June, 1999 Page 5-2 ~LUF'r (4) Consequences of failure of engineering and administrative control; (5) Stationary source siting; (6) Human factors; (7) A qualitative evaluation of a range of the possible safety and health effects of failure of controls; and, (8) The PHA shall include the consideration of external events, including seismic events, if applicable. PHAs completed for other programs where external events were not considered shall be updated to include external events. [The CalARP regulations contain this requirement; however, the federal accidental release prevention regulations do not require this analysis.] Pillsbury performed PHAs in June, 1991 in conjunction with the Risk Management and Prevention Program (RMPP), which meet the requirements of the initial PHAs for the RMP program. The June, 1991 PHAs were reviewed in March, 1992 when the RMPP was revised to address the installation of new equipment. These PHAs were also revalidated in June, 1999. The PHA methodology used for the initial PHAs and the revalidations was the Hazard and Operability Study (HazOp) approach. Volume I, Section III of the PSM Supporting Document describes the PHAs and the method for updating and revalidating the PHAs. The matrices which recorded the PHAs are included in Volume II, Section II of the PSM Supporting Document. 5.4 Operating Procedures Written operating procedures are to be developed and implemented that provide clear instructions for safely conducting activities involved in each covered process consistent with the process safety information. These procedures must address steps for each operating phase, operating limits, safety and health considerations, and safety systems and their functions. Operating procedures must be readily accessible to employees who work in or maintain a process. Operating procedures are to be reviewed as often as necessary to assure that they reflect current operating practice, including changes that result from changes in process chemicals, technology, and equipment, and changes to stationary sources. The owner or operator shall certify annually that these operating procedures are current and accurate. June, 1999 Page 5-3 ~JLUFr The owner or operator is required to develop and implement safe work practices to provide for the control of hazards during operations such as Iockout/tagout; confined space entry; opening process equipment or piping; and control over entrance into the stationary source by maintenance, contractor, laboratory, or other support personnel. These safe work practices are to apply to employees and contractor employees. Pillsbury has developed operating procedures for the ammonia-based refrigeration system. These procedures are contained in the Refrigeration Manual, which is located in the engine room and the Maintenance Manager's office at the facility. Additionally, Volume I, Section IV of the PSM Supporting Document discusses the steps for each operating phase, operating limits, safety and health considerations, and safety systems associated with the ammonia system. Pillsbury has implemented procedures for issuing work authorizations to ensure safe work practices. These safe work practices concern Iockout/tagout, confined space entry, opening process equipment and piping, hot work permits, control over entrance to the facility, and contractor requirements. Volume I, Section IV of the PSM Supporting Document provides information on the locations of these procedures. The Plant Manager ensures that the operating instructions and plant procedures are certified annually. Certification forms are maintained in Volume II, Section III of the PSM Supporting Document. 5.5 Training Each employee presently involved in operating a process, and each employee before being involved in operating a newly assigned process, must be trained in an overview of the process and in the operating procedures. The training is to include emphasis on the specific safety and health hazards, emergency operations including shutdown, and safe work practices applicable to the employee's job tasks. The CalARP regulations allow for employer certification in lieu of initial training for those employees already involved in operating a process on June 21, 1999. The owner or operator must certify in writing that the employee has the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as specified in the operating procedures. Refresher training must be provided at least every three years. The owner or operator is to prepare and maintain a record of training for each employee. June, 1999 Page 5-4 ~LUFr Training at the Pillsbury is provided to all operations and maintenance personnel prior to the performance of any of their duties unsupervised at the plant. All plant personnel are required to complete an indoctrination training course prior to working unsupervised with any of the systems at the plant. In addition, all operations and maintenance personnel are specifically trained for their responsibilities within the plant. In addition to the initial indoctrination training, all of the refrigeration technicians working at the Pillsbury Bakersfield facility are trained through a program developed by the Pillsbury Company (corporate entity). The Pillsbury Company training program utilizes course work and hands on experience with the refrigeration equipment to increase the skill level of the refrigeration technicians. After the training programs, the operators and maintenance personnel are tested to ensure competency in job skill levels and safe work practices. There are three different skill level designations (Level I, Level II, and Level III) that the refrigeration technicians can achieve in the Pillsbury Company training program. The refrigeration technicians must successfully complete the training program before they are allowed to attempt the next training phase. In addition to the Pillsbury Company training program, Pillsbury Bakeries and Foodservice utilizes industry groups, such as the Refrigerating Engineers and Technicians Association (RE'T'A) and the International Institute of Ammonia Refrigeration (ILAR) for training materials and guidelines. These industry groups provide a variety of safety training courses and materials to the ammonia refrigeration industry. Prior to any operations or maintenance personnel working on the ammonia system, they must complete a detailed initial training program including the following elements: Overview of the process and equipment Operating instructions, including emergency operations and shutdown Operating limits Site specific safety information Safety systems and their functions Safe work practices, including: · Lockout/tagout June, 1999 Page 5-5 ~LUFr Confined space entry Opening process equipment or piping · Site security California's PSM program does not contain the employer certification in lieu of training provision. As such, all personnel involved in the ammonia-based refrigeration system prior to June 21, 1999 completed the initial training program. Refresher training is provided and training records are maintained. Volume I, Section V of the PSM Supporting Document contains a description of the training program at Pillsbury. 5.6 Mechanical Integrity The owner or operator must establish and implement written procedures to maintain the on-going integrity of process equipment. The mechanical integrity of the following process equipment must be maintained: Pressure vessels and storage tanks; Piping systems (including piping components such as valves); Relief and vent systems and devices; Emergency shutdown systems; Controls (including monitoring devices and sensors, alarms, and interlocks) and, · Pumps. Employees that are involved in maintaining the integrity of process equipment must be properly trained. Inspections and tests must be performed following good engineering practices, at a frequency consistent with the manufacturer's recommendations. Each inspection and test must be properly documented. Deficiencies in equipment that are outside acceptable limits must be corrected. During new construction, the owner or operator must assure that the equipment is suitable for the process application and is installed properly. The owner or operator must also assure that maintenance materials, spare parts and equipment are suitable for the process application. June, 1999 Page 5-6 ~LUFr At Pillsbury, scheduled inspections and preventative maintenance programs have been implemented for all major pieces of equipment in the ammonia refrigeration system. Routine maintenance is conducted at specified intervals based on manufacturers' recommendations, generally accepted engineering practices, and/or operating experience. A daily journal and a maintenance logbook are utilized to record the maintenance history for each major piece of process equipment. The Maintenance Manager utilizes the maintenance logbook, daily journal, and the current status reports to generate a maintenance activity sheet for the refrigeration system. This maintenance activity sheet lists all preventative and response.maintenance activities that need to be performed on the refrigeration system. Plant personnel utilize the maintenance activity sheet to plan and schedule activities for the week. Maintenance activities include inspecting and testing process equipment, replacing parts, and calibrating instruments. As each maintenance activity is performed at the facility, it is signed off on the maintenance activities sheet. A system is in place at Pillsbury for reporting potentially faulty or unsafe equipment and correcting deficiencies that are found. All new process equipment is evaluated prior to acquisition to assure that the equipment is suitable for the intended process application. During construction, inspections are performed to assure the equipment is properly installed. All maintenance materials and spare parts to be used with the new process equipment are verified to assure that they meet design specifications and the applicable codes. Volume I, Section VIII of the PSM Supporting Document describes the mechanical integrity procedures in place at Pillsbury. 5.7 Management of Change Written procedures must be established and implemented by the owner or operator to manage changes (except for "replacement in kind") to process chemicals, technology, equipment, and procedures; and changes to stationary sources that affect a covered process. The procedures must assure that the following considerations are addressed prior to any change: (1) The technical basis for the proposed change; (2) Impact of change on safety and health; (3) Modifications to operating procedures; (4) Necessary time period for the change; and, June, 1999 Page 5-7 ~LUFr (5) Authorization requirements for the proposed change. Employees must be trained prior to startup of the process. If the change results in a change in the process safety information, the information must be updated accordingly and a pre-startup safety review must be conducted. If the change results in a change in the operating procedures, the procedures must be updated. Pillsbury has developed a Management of Change (MOC) program that meets the requirements of the PSM and CalARP programs. All proposed changes to the ammonia-based refrigeration system are submitted to the MOC review committee using the Process Change Request Form. Volume I, Section X of the PSM Supporting Document describes the MOC review procedure in detail. The MOC program assures that all changes to the ammonia-based refrigeration system are properly evaluated and documented. New process hazard analyses are performed if needed and any necessary changes are made to the process safety information, operating procedures, and maintenance procedures. A follow-up report is included with the Process Change Request Forms, which documents that the appropriate updates were made, the employees were trained, and the pre-start up safety review was performed. These forms are filed in Volume II, Section X of the PSM Supporting Document. 5.8 Pre-Startup Review When a modification is significant enough to require a change in the process safety information, the owner or operator must perform a pre-startup safety review. This review is to confirm that prior to introduction of regulated substances to a process: (1) Construction and equipment is in accordance with design specifications; (2) Safety, operating, maintenance, and emergency procedures are in place and are adequate; (3) That the management of change requirements have been met and a PHA has been performed as necessary; (4) Training of each employee involved in operating a process has been completed. Pillsbury has developed and implemented a Pre-Start Up Safety Review Checklist to facilitate the pre-startup review and to assure documentation of the June, 1999 Page 5-8 .,~LUFr review. The pre-startup safety review is described in Volume I, Section VII of the PSM Supporting Document. Completed Pre-Start Up Safety Review Checklists are filed in Volume II, Section X of the PSM Supporting Document. 5.9 Compliance Audits The owner or operator must certify that they have evaluated compliance with the provisions of Article 6 (Sections 2760.1 through 2760.12) of the CalARP regulations at least every three years. The purpose of these compliance audits is to verify that the procedures and practices developed for the CalARP program are adequate and are being followed. Compliance audits are to be conducted by a least one person knowledgeable in the process. A report of findings must be developed and the owner or operator must promptly respond to the findings and document that deficiencies have been corrected. The owner or operator must retain the two most recent compliance audit reports. Pillsbury has developed a detailed Compliance Audit Checklist which they use for the PSM program. This checklist was reviewed and found to meet the requirements of Article 6 of the CalARP regulations. All items of noncompliance are documented on a Compliance Audit Findings Form. These items are responded to and the deficiencies are corrected. The compliance auditing program at Pillsbury is described in Volume I, Section XIII of the PSM Supporting Document. All completed forms are retained in Volume II, Section IX of the PSM Supporting Document. 5.10 Incident Investigation Each incident which resulted in, or could reasonably have resulted in, a catastrophic release of a regulated substance, must be investigated by the owner or operator of the facility. The incident investigation must be initiated as promptly as possible, but not later than 48 hours following the incident. An incident investigation team must be established and must consist of at least one person knowledgeable in the process involved and other persons with appropriate knowledge and experience to thoroughly investigate and analyze the incident. An incident investigation report must be prepared at the conclusion of the investigation which includes at a minimum: (1) Date of the incident; (2) Date investigation began; (3) A description of the incident; June, 1999 Page 5-9 ~,~LUFr (4) The factors that contributed to the incident; and, (5) Recommendations resulting from the investigation. The owner or operator must establish a system to promptly address and resolve the incident report findings and recommendations. Resolutions and corrective actions must be documented. The report must be reviewed with all affected personnel whose job tasks are relevant to the incident findings including contract employees where applicable. Incident investigation reports must be retained for five years. Written procedures for investigating incidents that resulted in, or could have reasonably resulted in, a catastrophic release of anhydrous ammonia have been developed by Pillsbury. The Plant Manager is responsible for initiating the incident investigation as promptly as possible utilizing these procedures. If the Plant Manager is not available, the Safety Manager will ensure that the investigation is initiated within 48 hours of the incident. Volume I, Section Xl of the PSM Supporting Document describes the incident investigation procedures which are in place at Pillsbury. Copies of completed Incident Investigation Reporting Forms will be retained for at least five years. 5.11 Employee Participation The PSM standard and the CalARP regulations specifically require employers to develop a written plan of action regarding the implementation of employee participation. Employees and their representatives must be consulted on the conduct and development of the PHAs and on the development of the other elements of process safety management. The owner or operator must provide employees and their representatives with access to PH^s and all other information required to be developed under the PSM standard and the CalARP regulations. At Pillsbury, all affected employees attend a training session where the facility's PSM and CalARP programs are explained. In this training session, the employee's right to access information generated by the PSM and CalARP programs and the role that the employees play in the development and implementation of these programs is presented. Details of the training programs are discussed in Volume I, Section V of the PSM Supporting Document. Pillsbury employees were involved in all stages of development of the PHA for the ammonia-based refrigeration system. Employees also have been involved in the management of change program, including the PHA. Pillsbury employees June, 1999 Page 5-10 have access to all of the information developed as part of the PSM and CalARP programs. The location of this information is discussed in Volume I, Section I of the PSM Supporting Document. 5.12 Hot Work Permit The owner or operator must issue a hot work permit for hot work operations conducted on or near a covered process. The permit must document that the fire prevention and protection regulations have been implemented prior to beginning the hot work operations, indicate the date(s) authorized for hot work, and identify the object on which hot work is to be performed. The permit must be kept on file until completion of the hot work operations. Written procedures for issuing and obtaining hot work permits are contained in the Hot Work Permit Instructions. A copy of the Hot Work Permit Instructions is included in Volume II, Section VII of the PSM Supporting Document. Hot work permits are retained for a least six months after their date of issuance. 5.13 Contractors Section 2760.12 of the CalARP regulations applies to contractors performing maintenance or repair, turnaround, major renovation, or specialty work on or adjacent to a covered process. The responsibilities of the owner or operator and the contract owner or operator are outlined in the CalARP regulations and in the PSM standard. Pillsbury has developed and implemented a Contractor Safety Policy, which is provided in Volume I, Section VI of the PSM Supporting Document. The Contractor Safety Policy outlines the employer responsibilities; contractor responsibilities; entrance, presence and exit of contractors; and contractor audits. A compliance statement indicating that the policy requirements have been met is signed by the contractor. Compliance statements are kept in Volume II, Section V of the PSM Supporting Document. 5.14 External Events Analysis Section 2745.7(q) of the CalARP regulations requires that the owner or operator submit information regarding the external events analysis. This information is not required by the federal accidental release prevention program (40 CFR Part 68), and therefore, does not need to be submitted to the U.S. EPA. Appendix B contains the information required by Section 2745.7(q) of the CalARP regulations. June, 1999 Page 5-11 ~LUFr Ill --I 0 Z o~ 0 6.00FFSITE CONSEQUENCE ANALYSIS Federal regulations in 40 CFR Section 68.20 require owners or operators of a stationary source to analyze the offsite impacts due to an accidental release of a regulated substance. The regulations provide definitive guidance regarding the release parameters to be utilized in the offsite consequence analysis. In addition, the U.S. Environmental Protection Agency's RMP Offsite Consequence Analysis Guidance document dated April 15, 1999 details the methodology to be followed when preparing an offsite consequence analysis. Similar to the federal regulations, the CalARP regulations require an offsite consequence analysis that generally follows the federal requirements. Section 2750.7 of the CalARP regulations requires that the offsite consequence analysis be reviewed and updated at least once every five years. Also, the offsite consequence analysis must be revised within six months of any change in the processes, quantities stored or handled, or other change that could be expected to increase or decrease the distance to the endpoint by a factor of two or more. 6.1 Scenarios to be Analyzed Under both the federal and state regulations, an offsite consequence analysis must analyze a standardized worst-case release scenario and an alternative release scenario. The worst-case release is defined as a release (over a ten minute period) of the largest quantity for a regulated substance from a vessel or pipe that results in the greatest distance to an endpoint (see Section 6.2 for the definition of endpoint). Although, it is highly unlikely that a worst-case release would actually occur, all owners and operators subject to the regulations are required to determine the worst-case release scenario from their process. Alternative release scenarios under the CalARP program are releases that (1) are more likely to occur, and (2) that will reach an endpoint offsite, unless no such scenario exists. Factors in selecting the alternative release scenario include the past operation of the process (5 year accident history) and the Process Hazard Analyses (PHAs) prepared for the process. Pursuant to Section 2750.4(b)(2) release scenarios considered should include: 1. Transfer hose releases due to splits or sudden hose uncoupling; Process piping releases from failures at flanges, joints, welds, valves and valve seals, and drains or bleeds; June, 1999 Page 6-1 ~LUFr Process vessel or pump releases due to cracks, seal failure, or drain, bleed, or plug failure; Vessel overfilling and spill, or over pressurization and venting through relief valves or rupture disks; and Shipping container mishandling and breakage or puncturing leading to a spill. Only Program 2 and 3 processes are required to prepare an alternative release scenario. The ammonia-based refrigeration system at the Pillsbury Bakeries and Foodservice (Pillsbury) facility is a Program 3 process, and an alternative release scenario for the process must be analyzed in the offsite consequence analysis. 6.2 Compounds Included in the Offsite Consequence Analysis Both toxic and flammable compounds are listed in the CalARP regulations. However, to be subject to the accidental release programs, a process must contain more than the threshold quantity for the individual compound. Since Pillsbury does not handle flammable compounds in quantities greater than the threshold quantity, only toxic compounds are addressed in the offsite consequence analysis. At Pillsbury, anhydrous ammonia is utilized as the refrigerant in the refrigeration system which provides cooling for the freezers, coolers, and chillers. Anhydrous ammonia is a chemical composed of three parts hydrogen and one part nitrogen (NH3). It has a molecular weight of 17.03 and is lighter than air. Ammonia is gaseous at standard temperature and pressure and can be liquefied under sufficient pressure. Anhydrous ammonia is shipped as a nonflammable gas and is an irritant to the eyes, skin, and mucous membranes. Depending on the concentration and duration of exposure, the health effects of ammonia gas range from mild to severe irritation to the lining of the nose, eyes, throat, and lungs. Exposure to ammonia in sufficiently high concentrations can be fatal. Ammonia has a perceptible odor as Iow as 5 ppm and is readily detectable at 20 to 50 ppm. Additional information on the physical and chemical properties of ammonia and the health effects of ammonia exposure are presented in Volume I, Section II of the PSM Supporting Document. The offsite consequence analysis must determine the distance a release would travel, under pessimistic atmospheric conditions, in concentrations above the established endpoint. Appendix A to 40 CFR Part 68 and Appendix A to the CalARP regulations define the federal and state endpoints for toxic chemicals, June, 1999 Page 6-2 z"JLUFr respectively. Under both the federal and state accidental release programs the endpoint for anhydrous ammonia is 0.14 mg/L (approximately 200 ppm). The endpoint for ammonia 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 a strong odor and some eye irritation, but serious health effects are unlikely. 6.3 Worst-Case Release Scenario A worst-case release is defined in Section 2750.3 of the CalARP regulations as the total release of the contents of the single largest vessel or pipe within 10 minutes. For liquefied gases stored under pressure, the entire contents of the vessel or pipe are assumed to be released as a gas (vapor). The CalARP regulations further require, in the selection of the worst-case release scenario, the analysis of an additional scenario if such scenario would result in a greater distance to an endpoint beyond the facility boundary. This additional scenario would be based on smaller quantities handled at higher process temperature or pressure and proximity to the boundary of the facility. Due to the behavior of liquid ammonia stored under pressure, a total vapor release is highly unlikely. If liquid ammonia is released to the atmosphere from a pressure vessel or pipeline, a portion of the liquid will immediately flash to the vapor phase. The remainder of the liquid ammonia released from the vessel will form a pool and evaporate over time. The rate of evaporation would depend on the type'of material the ammonia is spilled on (i.e. concrete, wood, steel, etc.), the temperature of the material, and any potential heat sources. The amount of liquid that flashes to the vapor phase is dependent on the storage pressure in the vessel prior to the release. In general, the higher the storage pressure prior to the release, the greater the percentage of liquid ammonia that would flash to the vapor phase. For example, if liquid ammonia were to be released from the high pressure side of the refrigeration system, approximately 21 percent of the liquid would flash to the vapor phase. If the liquid release were to occur on the Iow pressure side of the refrigeration system, approximately 8 percent would flash. June, 1999 Page 6-3 ~JLUFr 6.3.1 Release Rate Under a worst-case release, the entire contents of the single largest vessel or pipeline are assumed to be released as a vapor in 10 minutes. The major components of the refrigeration system are the booster compressors, intercooler, high stage compressors, evaporative condensers, thermosyphon receiver, controlled pressure receiver, glycol chiller, process water chiller, evaporators, and a suction accumulator. The system is also equipped with an air purger, oil drain pot, emergency ventilation system, and an emergency refrigerant control box which discharges to a scrubber tank. The controlled pressure receiver is the largest vessel at Pillsbury. No other vessel or pipeline release would result in a worst-case release scenario with a greater distance to an endpoint. As such, a catastrophic failure of the controlled pressure receiver was selected as the worst-case release scenario. During normal operation, the anhydrous ammonia is distributed throughout the refrigeration system. However, during major maintenance activities, the entire refrigeration system can be "pumped down" to evacuate the ammonia from the system and store it in the controlled pressure receiver. The maximum quantity of ammonia that can be stored in the controlled pressure receiver is approximately 17,700 pounds. The ammonia refrigeration equipment is located within buildings except for a few pipelines and isolation valves located on the roof. Even without consideration of the emergency ventilation and scrubbing systems, the potential impact from a release within a building would be greatly reduced. If a release were to occur in the engine room, the emergency ventilation and scrubbing systems would further reduce any potential offsite impacts. The U.S. Environmental Protection Agency's RMP Offsite Consequence Analysis Guidance document provides a mitigation factor of 55 percent for a release which occurs in a fully enclosed, non-airtight space that is directly adjacent to the outside air. 6.3.2 Modeling Parameters The U.S. Environmental Protection Agency and National Oceanic and Atmospheric Administration have developed the RMP*Comp model (Version 1.06) for offsite consequence analyses associated with a Risk Management Plan. The RMP*Comp model is a planning tool and is not recommended for emergency response situations. The default June, 1999 Page 6-4 ~LUFr parameters shown in Table 6.1 are utilized by the RMP*Comp model for the worst-case release scenario. Table 6.1 RMP*Comp Default Parameter Default Value Release duration 10 min. Wind speed Atmospheric stability class Ambient Temperature Parameters 3.4 mile/hour (1.5 meters/sec) F 77 °F (25 °C) In addition to the default parameters, the user must specify the release category (toxic or flammable) and the surface roughness of the area surrounding the site. A release from the ammonia-based refrigeration system would be considered a toxic gas release scenario. There are many obstacles in the immediate area of the Pillsbury facility. Therefore, the surface roughness of the area was designated as urban. 6.3.3 Modeling Results The data for the worst-case release scenario were input into the RMP*Comp model. Again, for the worst-case release of a liquefied gas stored under pressure, RMP*Comp assumes that the entire contents of the vessel or piping is released as a vapor. For a release of approximately 17,700 lbs of anhydrous ammonia in 10 minutes within the engine room, the plume would travel 1.2 miles at concentrations at or above the endpoint. Figure 6.1 shows the area that would potentially be impacted by a worst-case release from the Pillsbury facility. 6.4 Alternative Release Scenario An alternative release scenario is a release that is more likely to occur than the worst-case scenario. The alternative release scenario should be selected based on the past operating history and the results of the PH^s for the process. The regulations require that the alternative release scenario reach an endpoint offsite, unless no such scenario exists. 6.4.1 Release Rate The PHAs for the Pillsbury facility identified deviations from the design intent that could generate release events for the ammonia-based refrigeration system based on 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 June, 1999 Page 6-5 z~LUFr We~ldu Road ~ I-3 1 Timoer~oc~ Ln 2. ThornheOge St. 3, Bridle~ood OL 4. Anderiy Ct. :5. Crail Ct. 5. TimDerspira St 7. Rutleage Pt. J-4 I Hardin Wy. 2. Terrebonne Ct, 3. Lafayette Wy, 4. Gunnison Wy. 5. Bennington Wy. 6 Snowmass 7, Hanover Cir. LANE i ~dcncock Dr Twain Wy 3 Mdlav Wy 4 Sal:nger ${ District Schirra Courz ~' ~chirra Ct. ·/ A~drin Ct. O/ST o,~F ~ Boulevard ~ ' ~ ~ McKI~RICK, ~ BRANCH ~,o (3e Janelroi =ANAMA MavbrookI New Horizon __ District Milo California 0 2000 4000 Scale in Feet t Base Map: Greater Bakersfield City Street Map 1997 Engineers & Environmental Consultants, Inc. 2029 21 st Street Bakersfield, CA 93301 Figure 3.1 Pillsbury Bakeries & Foodservice Facility Location Scale in Miles California LUFT Engineers & Environmental Consultants, Inc. 2029 21 st Street Bakersfield, CA 93301 Figure 6.1 Pillsbury Bakeries & Foodservice Worst Case Release of Anhydrous Ammonia occurrence or a significant offsite consequence if the release were to occur. The releases associated with a high likelihood of occurrence were typified by very Iow release rates that would not create an offsite consequence. A credible release event with a high discharge rate would potentially have the greatest offsite impact. A leak from the packing of an isolation valve in the liquid ammonia pipeline on the roof of the building was selected as the alternative release scenario to be analyzed in the offsite consequence analysis. For purposes of the alternative release scenario, the normal operating pressure of 30 psig for the liquid ammonia line from the controlled pressure receiver was used. A very large leak in the packing of the isolation valve was assumed to result in a 1/16 inch by 1/4 inch opening in the packing. Based on the properties of liquid ammonia at 30 psig, a release rate of 22 Ib/min was calculated. 6.4.2 Modeling Parameters The RMP*Comp model was also used for the alternative release scenario. The pump seal failure was modeled as a release within a building of liquefied ammonia stored under pressure. As specified in the U.S. Environmental Protection Agency's RMP Offsite Consequence Analysis Guidance document, several default parameters are different than the worst-case release. The default parameters for the alternative release scenario are listed in Table 6.2. Similar to the worst-case release, a toxic gas release scenario in an urban area was input into the model. The duration of the release does not impact the results of the RMP*Comp model run. Table 6.2 RMP*Comp Default Parameters Parameter Default Value Wind speed 6.7 mile/hour (3 meters/sec) Atmospheric stability class Ambient Temperature D 77 °F (25 6.4.3 Modeling Results The data for the alternative release scenario was input into the RMP*Comp model. For a release of 22 Ib/min of anhydrous ammonia, the plume would travel less than 0.1 mile at concentrations at or above the June, 1999 Page 6-6 ~LUFD endpoint. The RMP*Comp model states that all distances shorter than 0.1 mile should be reported as 0.1 mile. 6.5 Population Impacts The offsite consequence analysis must include an estimate of the residential population within an 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 at or above the endpoint. The circle also defines the area in which potential environmental receptors must be identified. 6.5.1 Worst-Case Release The Pillsbury facility is located on McDivitt Drive in Bakersfield, California. The immediate area surrounding the plant consists of industrial facilities and commercial businesses. Figure 6.1 represents the 1.2 mile distance from the plant potentially affected by the worst-case release. For the worst-case release scenario, sensitive receptor information and maps were purchased from Environmental Data Resources, Inc. (EDR). This information is included in Appendix C. The 1990 Census data was used by EDR to determine the population within the area affected by the worst-case release scenario. EDR estimated the population potentially affected by the worst-case release, based on a uniform population density, to be 13,000 people. The offsite consequence analysis must identify the presence of schools, hospitals, long term health care facilities, child day care facilities, prisons, parks, recreational areas, and major commercial, office, and industrial buildings. Data provided by EDR was used to identify the presence of schools, hospitals, long term health care facilities, child day care facilities, and prisons. Since the EDR information did not address parks, recreational areas, and major commercial, office, and industrial buildings, their presence was determined by a review of the 1999 Thomas Guide for Central Valley Cities, U.S. Geological Survey (U.S.G.S.) maps, and observations of the area. Based on a review of the above-described information, the sensitive receptors within the worst-case release scenario circle include schools, parks, recreational areas, and major commercial, office, and industrial buildings. June, 1999 Page 6-7 ~LUFF 6.5.2 Alternative Release Scenario The 0.1 mile radius from the alternative release scenario would affect the Pillsbury plant parking lot, nearby industrial facilities and nearby roadways. Based on observations of the area, there are no residences and there would be no population impacts from the alternative release scenario. There are also no sensitive receptors within the alternative release scenario circle. 6.6 Environmental Impacts An offsite consequence analysis is required to consider environmental receptors potentially affected by a release. Environmental receptors include natural areas such as national or state parks, forests, or monuments; officially designated wildlife sanctuaries, preserves, or refuges; and federal wilderness areas. 6.6.1 Worst-Case Release The worst-case release includes the area within a 1.2 mile radius of the plant (see Figure 6.1). The Gosford 7.5 minute U.S.G.S. map was reviewed for environmentally sensitive receptors. According to the map, no environmentally sensitive areas would be impacted by the worst-case release from the Pillsbury facility. 6.6.2 Alternative Release Scenario The area potentially impacted by the alternative release is considerably less than the area potentially impacted by the worst-case scenario. Since the worst-case scenario would not affect any environmentally sensitive receptors, the smaller alternative release scenario also would not affect any environmentally sensitive areas. June, 1999 Page 6-8 ~LUFr 7.0 OVERVIEW OF EMERGENCY RESPONSE PROGRAM 7.1 CalARP and EPCRA Requirements The owner or operator of a stationary source with a Program 3 process is required to comply with the emergency response program requirements outlined in Section 2765.2 if employees respond to accidental releases of regulated substances. However, an exemption to Section 2765.2 exists for owners and operators of stationary sources whose employees do not respond to accidental releases, provided certain criteria has been met under Section 2765.1. Section 2765.2 of the CalARP regulations contains the requirements for an emergency response program. The emergency response program specified by this section must include the following elements: (1) An emergency response plan, which shall be maintained at the stationary source and contain at least the following: (A) Procedures for informing and interfacing with the public and local emergency response agencies about accidental release, emergency planning, and emergency response; (B) Documentation of proper first-aid and emergency medical treatment necessary to treat accidental human exposures; and, (c) Procedures and measures for emergency response after an accidental release of a regulated substance; (2) Procedures for the use of emergency response equipment and for its inspection, testing, and maintenance; (3) Training for all employees in relevant procedures and relevant aspects of the Incident Command System; and, (4) Procedures to review and update, as appropriate, the emergency response plan to reflect changes at the stationary source and ensure that employees are informed of changes. Section 2765.1 (b) states that the owner or operator of a stationary source whose employees will not respond to accidental releases of regulated substances need not comply with the requirements of Section 2765.2 provided they meet the following: June, 1999 Page 7-1 ~.UFr For stationary sources with any regulated toxic substance held in a process above the threshold quantity, the stationary source is included in the community emergency response plan developed under Section 11003 of Title 42 of the United States Code (USC). (2) For stationary sources with only regulated flammable substances held in a process above the threshold quantity, the owner or operator has coordinated response actions with the local fire department; and, (3) Appropriate mechanisms are in place to notify emergency responders when there is a need for a response. Section 11003 of Title 42 of the USC (EPCRA) describes the requirements for comprehensive emergency response plans. Each local emergency planning committee (LEPC) was to complete preparation of an emergency plan in accordance with Section 11003 by October 17, 1988. The LEPC must review the emergency plan at least once per year. The emergency plan must include, but is not limited to, each of the following: (1) Identification of facilities subject to the requirements of Subchapter I, identification of routes likely to be used for the transportation of extremely hazardous substances, and identification of additional facilities contributing or subjected to additional risk due to their proximity to facilities subject to Subchapter I. (2) Methods and procedures to be followed by facility owners and operators and local emergency and medical personnel to respond to any release of such substances. (3) Designation of a community emergency coordinator and facility emergency coordinators, who shall make determinations necessary to implement the plan. (4) Procedures providing reliable, effective, and timely notification by the facility emergency coordinators and the community emergency coordinator to persons designated in the emergency plan, and to the public, that a release has occurred. (5) Methods for determining the occurrence of a release, and the area or population likely to be affected by such release. June, 1999 Page 7-2 ..~LUFr (6) A description of emergency equipment and facilities in the community and at each facility in the community subject to Subchapter I, and an identification of the persons responsible for such equipment and facilities. (7) Evacuation plans, including provisions for a precautionary evacuation and alternative traffic routes. (8) Training programs, including schedules for training of local emergency response and medical personnel. (9) Methods and schedules for exercising the emergency plan. The Pillsbury Bakeries and Foodservice (Pillsbury) facility is located within the jurisdiction of the Region V LEPC. Region V includes the counties of Fresno, Kern, Kings, Madera, Mariposa, Merced, and Tulare, with headquarters in Fresno. A community emergency response plan has been prepared by the Region V LEPC, which is entitled the Region V Hazardous Materials Response Plan. This plan is intended to meet the requirements of Section 11003 of Title 42 of the USC. Section I.G of the Region V Hazardous Materials Response Plan identifies facilities impacted by the plan. Section I.G states that Hazardous Materials Business Plans are to be submitted to the Administering Agency (AA) and handlers of specified chemicals are required to be registered with the AA. This information is made available to local emergency response agencies. 7.2 Facility Emergency Planning and Response Due to the limited number of personnel on-site at the Pillsbury facility, personnel from outside of the immediate release area will not respond to an accidental release 'of ammonia beyond evacuation of the facility. Appropriate mechanisms are in place to notify emergency responders when there is a need for a response. Pillsbury has filed a Hazardous Materials Business Plan and has registered the anhydrous ammonia with the AA, as specified by the Region V Hazardous Materials Response Plan. Therefore, in accordance with Section 2765.1(b) of the CalARP regulations, Pillsbury does not need to develop and implement the emergency response program required by Section 2765.2. Although Pillsbury is exempt from the CalARP emergency response program, emergency planning and response procedures are in place at the facility. Volume I, Section XII of the PSM Supporting Document discusses emergency procedures at the Pillsbury facility. June, 1999 Page 7-3 ~LUFr Pillsbury's emergency action plan complies with the provisions of 29 CFR 1910.38(a) (and Section 3220 of Title 8, CCR) and provides emergency response procedures for the handling of small releases as required by 29 CFR 1910.119(n). A copy of the Emergency Action Plan is provided in Volume II, Section XI of the PSM Supporting Document. In the event of a release, a determination shall be made as to the on-site and off- site hazards. If there is a threat to the health and safety of the public or the environment, the following numbers will be called: 911 and 1-800-852-7550 or 1- 916-262-1621. These numbers will notify the appropriate local response personnel and the State Office of Emergency Services. Figure XII-1 in Volume I of the PSM Supporting Document shows the steps for handling an accidental release. The emergency response program information required by Section 2745.8 of the CalARP regulations is provided in Appendix A of this document. June, 1999 Page 7-4 ~LUFr rn --I 0 Z .m 8.0 OTHER REQUIREMENTS 8.1 Recordkeeping Section 2775.1 of the CalARP regulations requires the owner or operator to maintain records supporting the implementation of the CalARP regulations for five years, unless otherwise specified in Article 6 of the CalARP regulations. Pillsbury Bakeries and Foodservice retains all records required by the PSM program and the CalARP regulations for a minimum of five years or as otherwise specified in Article 6 of the CalARP regulations. 8.2 Audits The Administering Agency (AA) is required to periodically audit RMPs to review the adequacy of the RMPs. The AA will require revisions to the RMPs when necessary to ensure compliance with the CalARP regulations. Based on the audit, the AA may issue the owner or operator a written preliminary determination of necessary revisions to the RMP. If the AA issues a preliminary determination, the owner or operator must respond in writing. The response is to state that the owner or operator will implement the revisions contained in the preliminary determination in accordance with the specified timetable or shall state that the owner or operator rejects the revisions in whole or in part. For each rejected revision, the owner or operator must explain the basis for rejecting the revision. After providing the owner or operator an opportunity to respond, the AA may issue the owner or operator a written final determination of necessary revisions to the RMP. The AA must also develop a time table for implementing these revisions. Thirty days after completion of the actions detailed in the implementation schedule, the owner or operator will be in violation unless the owner or operator revises the RMP. The public shall have access to the preliminary determinations, responses, and final determinations, excluding information which has been designated as trade secret. June, 1999 Page 8-1 ~,~LUFr 8.3 Inspections The AA must inspect every stationary source that is required to be registered by the CalARP regulations at least once every three years to determine whether the stationary source is in compliance with the CalARP regulations. 8.4 Availability of Information to the Public The RMP shall be available to the public, excluding those components which have been designated as trade secret. 8.5 Permit Content and Permitting Authority Section 2775.6 of the CalARP regulations is applicable to any stationary source that is subject to the CalARP regulations and to Part 70 or 71 of Title 40 of the Code of Federal Regulations (CFR). The 40 CFR Part 70 or 71 permit ('q'itle V" air permit) must contain: (1) A statement listing 40 CFR Part 68 as an applicable requirement; (2) Conditions that require the source owner or operator to submit: (A) A compliance schedule for meeting the requirements of the CalARP regulations by the date provided in Section 2735.4(a)(1) of the CalARP regulations, or, (B) As part of the compliance certification submitted under Section 70.6(c)(5) of 40 CFR, a certification statement that the source is in compliance with all requirements of the CalARP regulations, including the registration and submission of the RMP. Any additional relevant information requested by the AA, the State Office of Emergency Services (OES), or the appropriate Air Pollution Control District (APCD)/Air Quality Management District (AQMD) must be submitted by the owner or operator. The appropriate APCD or AQMD shall, at a minimum: (1) Verify from the AA that the source owner or operator has registered and submitted an RMP when required. (2) Verify from the AA that the source owner or operator has submitted a source certification or in its absence has submitted a compliance schedule. June, 1999 Page 8-2 ,~-dLUFr Initiate enforcement action based on the above-listed requirements, as appropriate. June, 1999 Page 8-3 z~LUFr ITl --I 0 Z 9.0 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. A "qualified person" is defined as "a person who is qualified to attest, at a minimum to: (1) the validity and appropriateness of the process hazard analyses (PHA) performed pursuant to Section 2760.2; (2) the completeness of a risk management plan; and (3) the relationship between the corrective steps taken by the owner or operator following the PHAs and those hazards which were identified in the analyses". The following certifications have been provided. On behalf of Pillsbury Bakeries and Foodservice, 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. i~' ~--) Raj Rangaswamy Signature Print Name Plant Manager r~ / ~ Title Date June, 1999 Page 9-1 ~LUFr As a qualified person, I have reviewed and can attest to the validity and appropriateness of the PHAs performed in June, 1991 and reviewed in March, 1992 and the revalidation of the PHAs in June, 1999; and the relationship between the corrective steps taken by the owner or operator following the PHAs and those hazards which were identified in the analyses. I also certify that the RMP for Pillsbury Bakeries and Foodservice is complete. Further, to the best of my knowledge, information, and belief formed after reasonable inquiry, the information submitted is true, accurate, and complete. Signature Karl W. Luft, P.E. Print Name Principal Mechanical Engineer LUFT Engineers & Environmental Consultants, Inc. Title Date June, 1999 Page 9-2 ~LUFr Z X APPENDIX B State-Only Requirements APPENDIX B External Events Analysis Section 2745.7(q) of the CalARP regulations requires that the owner or operator submit information regarding the external events analysis. This information is not required by the federal accidental release prevention program (40 CFR Part 68), and therefore, does not need to be submitted to the U.S. EPA. The following external events analysis information is to be submitted by the owner or operator: (1) (2) (3) (4) The types of natural and human caused external events considered in the PHAs; The magnitude or scope of external events which were considered. If seismic events are applicable, the parameters used in consideration of the seismic analysis and which edition of the Uniform Building Code was used when the process was designed; For each external event, with a potential to create a release of a regulated substance that will reach an endpoint offsite, Sections (e)(1) through (e)(6) of Section 2745.7 should be applied. These sections state as follows: (e)(1) The expected date of completion of any changes resulting from the PHA; (e)(2) Major hazards identified; (e)(3) Process controls in use; (e)(4) Mitigation systems in use; (e)(5) Monitoring and detection systems in use; and, (e)(6) Changes since the last PHA. The date of the most recent field verification that equipment is installed and maintained as designed. The PHA considered release events due to the following natural and human causes: June, 1999 Page B-1 ~LUFr Natural · Fire Fires caused by natural ignition sources, such as lightning, have the potential to raise the temperature and pressure of the contents of pressure vessels high enough to cause a release from the vessel's pressure safety valves. Fires can also cause support structures to fail resulting in line failures due to impact or improper support. · Lightning In addition to causing fires, lightning can interfere with electronic control signals or cause equipment to short out electrically and result in control system failures. Extreme temperatures (high or Iow) Extreme temperatures, both high and Iow, can cause electronic control systems, such as computers and programmable logic controllers, to malfunction or fail. Electric motors may shut down if they are operating at maximum capacity during high temperatures due to the activation of thermal overload protection. Temperature extremes may also affect process cooling, such as cooling towers and air to air heat exchangers, sufficiently to cause process parameters to deviate from design intent. Temperature extremes may also cause power failures. Earthquakes (seismic) Seismic events may cause ground accelerations that could result in the following: Structural damage to equipment and/or supports resulting in line failures due to improper support or impact from falling debris. Force rotating equipment, such as compressors, to shut down due to high vibration. Power outages. · Flooding Flooding can cause electrical and electronic equipment to short out resulting in control system failures. Flooding can also undermine support structures and cause line failures due to improper support. June, 1999 Page B-2 ~LUFr · High winds High winds can result in flying debris and cause damage to equipment or structures. High winds can also cause structure damage due to oscillating motions (natural frequencies) or by downing trees and power poles. Power outages may also occur if the power lines touch each other. Human Caused · Fire Human caused fires have the same impacts on processes as the naturally caused fires discussed previously, Examples of ignition sources for human caused fires include sparks from welding/grinding operations and improperly stored combustible materials (near high heat sources). Operator error Operator errors can be caused by plant personnel, contractors, and even vendors. In the process hazard analyses, operator error is usually identified by the specific action of the operator or the result of the specific act. Examples of operator errors by plant personnel, and contractors performing similar duties, would include the following: Improper valve alignment including - Block valves being left open - Isolation valves left closed - Misdirecting flow of fluids - Trapping liquids with high thermal expansion properties (such as ammonia or propane) Not following standard operating procedures or safe work practices. Utilizing improper replacement parts. Vehicle impacts (cars, trucks, cranes, forklifts, etc.). Examples of operator errors by vendors could include the following: Overfilling storage tanks. Supplying contaminated product. June, 1999 Page B-3 ,.dLUFr Supplying replacement pads that are not within requested specifications, leading to component failure. Based on the PHAs performed in June, 1999, no changes were recommended. The release events (either natural or human caused) identified during the PHAs for the ammonia refrigeration system that have the potential to reach the endpoint (200 ppm) offsite include: Line failures on pipelines from external events Releases associated with system overpressure due to a fire in the building Leaks from valve packings The major hazards identified and the process controls, mitigation systems, and monitoring and detection systems in use are listed in Table B.1. For the purpose of analyzing failures associated with external events, it was assumed that the external event would be of sufficient magnitude and scope to cause the deviation or failure. Seismic analyses were incorporated into the design of the Pillsbury Bakeries and Foodservice facility, using the 1988 edition of the UBC and the parameters of Seismic Zone No. 4. All changes that have been made to the refrigeration system since it was installed have been designed to the applicable editions of the UBC and the parameters of Seismic Zone No. 4 in effect at the time of installation. The most recent field verification that the equipment is installed and maintained as designed was performed in May, 1999. June, 1999 Page B-4 ~L,UF~' Tal .1 Date PHA Recommendations Major Hazards Process Controls In Mitigation, Systems In Monitoring/Detection Release Event Completed Identified Use Use Systems In Use ~Pipeline designed and installed per UMC & Toxic release. Failure ASME B31.5 and Ammonia monitoring & of pipeline due to physically located away detection system with Line Failure N/A external event. None from vehicular traffic, equipment shutdowns. Valve Packing -- Leak N/A Toxic release. None None None Pressure Relief Valve Release & Sprinkler systems, fire Emergency extinguishers, materials of Refrigerant Toxic release, construction for engine Ammonia monitoring & Control Box (Fire Overpressure due to fire room (concrete). Diffusion detection system with Dump) Release N/A in building. None system installed in 1992. equipment shutdowns. I"1"1 Z X C> APPENDIX C Sensitive Receptor Information EDR - Offsite Receptor Report Pillsbury Bakeries+Food Svc. 6800 McDivitt Dr. Bakersfield, CA 93313 Inquiry Number: 370389.1s May 17, 1999 Environmental Data Resources, Inc. · · .:.~edr'company · an.;~. The Source For Environmental Risk Management Data 3530 Post Road Southport, Connecticut 06490 Nationwide Customer Service Telephone: 1-800-352-0050 Fax: 1-800-231-6802 Internet: www.edrnet.com TABLE OF CONTENTS SECTION PAGE Executive Summary Census Map Census Findings Receptor Map Map Findings Records Searched/Data Currency Tracking Addendum 2 3 4 5 6 7 Thank you for your business Please contact EDR at 1-800-352-0050 with any questions or comments. Disclaimer and Other Information This Report contains information obtained from a variety of public and other sources and Environmental Data Resources, Inc. (EDR) makes no representation or warranty regarding the accuracy, reliability, quality, suitability, or completeness of said information or the information contained in this report. The customer shall assume full responsibility for the use of this report. NO WARRANTY OF MERCHANTABILITY OR OF FITNESS FOR A PARTICULAR PURPOSE, EXPRESSED OR IMPLIED, SHALL APPLY AND EDR SPECIFICALLY DISCLAIMS THE MAKING OF SUCH WARRANTIES. IN NO EVENT SHALL EDR BE LIABLE TO ANYONE FOR SPECIAL, INCIDENTAL, CONSEQUENTIAL OR EXEMPLARY DAMAGES. COPYRIGHT (C) 1998 BY ENVIRONMENTAL DATA RESOURCES, INC. ALL RIGHTS RESERVED. Unless otherwise indicated, all trademarks used herein are the property of Environmental Data Resources, Inc. or its affiliates. TC370389.1s Page 1 of 7 EXECUTIVE SUMMARY A search of available records was conducted by Environmental Data Resources, Inc. (EDR). The EDR Offsite Receptor Report provides information which may be used to comply with the Clean Air Act Risk Management Program 112-R. "The rule requires that you estimate in the RMP residential populations within the circle defined by the endpoint for your worst-case and alternative release scenarios (i.e., the center of the circle is the point of release and the radius is the distance to the endpoint). In addition, you must report in the RMP whether certain types of public receptors and environmental receptors are within the circles." The address of the subject property, for which the search was intended, is: PILLSBURY BAKERIES+FOOD SVC. 6800 MCDIVITT DR. BAKERSFIELD, CA 93313 Distance Searched: 1.200 miles from subject property RECEPTOR SUMMARY An X indicates the presence of the receptor within the search radius. Residential Population Estimated population within search radius: 12701 persons. Other Public Receptors Type Within Search Radius Sites Total Day Care Centers: [] Medical Centers: [] Nursing Homes: [] Schools: [] Hospitals: [] Arena: [] Prison: [] Environmental Receptors Type Within Search Radius Sites Total Federal Land: [] TC370389.1s Page 2 of 7 CENSUS MAP - 370389.1s Target Property o 1/4 1/2 1 MUms Roads I I ' r Waterways Census Tracts TARGET PROPERTY: ADDRESS: CITY/STATE/ZIP: I-AT/LONG: Pillsbury Bakeries+Food Svc. 6800 McDivitt Dr. Bakersfield CA 93313 35.3145 / 119.0791 CUSTOMER: CONTACT: INQUIRY #: DATE: Luff Environmental Consultants Mr. John Haley 370389.1 s May 17, 1999 10:35 pm CENSUS FINDINGS Map ID Tract Number Total Population Population in Radius Total Area(sq.mi.) Area in Radius(sq.mi.) T1 0028.05 4252 302.4 3.23 0.23 T2 0028.08 2972 530.7 1.45 0.26 T3 O028.09 8780 6174.5 1.28 0.90 T4 0028.10 10503 5006.7 1.26 0.60 T5 0031.11 1372 686.8 5.03 2.52 TC370389.1s Page 4 of 7 RECEPTOR MAP - 370389.1s LA6OROUGH DR WHITE LN SCHIRRACT WHITE LN SCHIRRACT DISTRICT BLVD ALDRINI DISTRICT BLVD PANAMA LN · A, Target Property /~/ Roads /Y Waterways ." Environmental or Public Receptor /V Federal Lands Linear Features /'V Federal Lands Area PANAMA 1/4 1/2 I Miles TARGET PROPERTY: ADDRESS: CITY/STATE/ZIP: I-AT/LONG: Pillsbury Bakeries+Food Svc. 6800 McDivitt Dr. Bakersfield CA 93313 35.3145/119.0791 CUSTOMER: CONTACT: INQUIRY#: DATE: Luft Environmental Consultants Mr. John Haley 370389. ls May 17, 1999 10:38 pm MAP FINDINGS Map ID Direction Distance Distance (ft.) Elevation Site EDR ID Database 1 WNW 1-2 mi 5833 Higher Name: NCES ID: Address: School ID: Telephone: Local Code: School Type: School Level: County: TEVIS JUNIOR HIGH 060639009338 3901 PIN OAK PARK BLVD BAKERSFIELD, CA 93311 5781 805-664-7211 Mid-size Central City Regular Elementary and Secondary Schools Middle KERN Lowest Grade: 07 Highest Grade:08 060639009338 CCD TC370389.1s Page 6 of 7 RECORDS SEARCHED/DATA CURRENCY TRACKING CENSUS Source: U.S. Census Bureau Telephone: 301-457-4100 1990 U.S. Census data was used to estimate residential population following these EPA guidelines: "Census data are presented by Census tract. If your circle covers only a portion of the tract, you should develop an estimate for that portion...Determine the population density per square mile (total population of the Census tract divided by the number of square miles in the tract) and apply that density figure to the number of square miles within your circle." FED LAND: Federal Lands S~urce: USGS Telephone: 703-648-5094 Federal lands data. Includes data from several Federal land manangement agencies, including Fish and Wildlife Service. Bureau of Land Management, National Park Service, and Forest Service. Includes National Parks, Forests, Monuments; Wildlife Sanctuaries, Preserves, Refuges; Federal Wilderness Areas. Date of government version: 09/09/97. HCFA: Provider of Services Listing Source: The Health Care Financing Administration Telephone: 410/786-3000 A listing of hospitals with Medicare provider number, produced by The Health Care Financing Administration (HCFA), a federal agency within the U.S. Department of Health and Human Services. HCFA runs the Medicare and Medicaid programs. Date of government version: 06/01/98. CCD: Common Core of Data Source: National Center for Education Statistics 555 New Jersey Avenue NW Washington, DC 20208-5651 The Common Core of Data (CCD) is the National Center for Education Statistics' primary database on elementary and secondary public education in the United States. CCD is a comprehensive, annual, national statistical database of all public elementary and secondary schools and school districts, which contains data that are comparable across all states. Date of government version: 1995-96. GNIS: Geographic Names Information System Source: USGS Telephone: 703-648-5094 The Geographic Names Information System (GNIS), developed by the USGS in cooperation with the U.S. Board on Geographic Names (BGN), contains information about almost 2 million physical and cultural geographic features in the United States. The GNIS is our Nation's official repository of domestic geographic names information. Date of government version: 03/01/98. PRV_SCH: Private Schools EDR indicates the location of buildings and facilities - private schools ~ where individuals who are public receptors are likely to be located. DAYCARE: Daycare Centers EDR indicates the location of buildings and facilities - daycare centers - where individuals who are public receptors are likely to be located. MEDCEN: Medical Centers EDR indicates the location of buildings and facilities - medical centers - where individuals who are public receptors are likely to be located. NURSING: Nursing Homes EDR indicates the location of buildings and facilities - nursing homes - where individuals who are public receptors are likely to be located. ARENA: Arenas EDR indicates the location of buildings and facilities - arenas - where individuals who are public receptors are likely to be located. PRISON: Prisons EDR indicates the location of buildings and facilities - prisons - where individuals who are public receptors are likely to be located. BOP: Bureau of Prisons Facilities Source: Federal Bureau of Prisons List of facilities operated by the Federal Bureau of Prisons. Date of government version: 07/01/98. TC370389.1s Page 7 of 7