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HomeMy WebLinkAboutRISK MANAGEMENT (2)BAKERSFIELD FIRE DEPARTMENT FIRE INCIDENT REPORT FDID: 15005 Date: 05/23/93 Dispatch: 1714 First Co: E9 Arrival: '- Incident No:.93-007373-000 Multi-Agency:. 1717 End: 1959 Days: 0 Response: 0 03 District: 12316 Temperature: 000 (F) Situation(s): 42. Aid: 8 Alarm Method: 1~ Weather: 1 Property Mangmnt: 1 TOXIC CONDITION NO FIRE SERVICE ASSISTANCE RECEIVED OR PROVIDED TELEPHONE DIRECT TO FIRE DEPARTMENT CLEAR PRIVATE TAX-PAYING PROPERTY Address/Location: Room/Apartment: City/State: , Hazard Zone: 6800 MC DIVITT DR Zip: 93313 Census Tract: 0000.00 Personnel Apparatus Paid: 0013 Engine: 002 Truck: 01 Volunteer: 0000 .Medical: 00 'Other: 02 General Use: 52 Specific Use: 568 Bldg Occupancy: B4 Struct. Type: 1. Struct. Status: '2 Occupied?: 1 SERVICE USE RESTAURANT SUPPLIES SERVICES ICE PLANT, POWER PLANT, PUMPING PLANT . BUILDING WITH ONE SPECIFIC PROPERTY USE ~ IN USE WITH FURNISHINGS IN PLACE, ROUTINELY U Code: OC Name: HEINZ FOODS INC. Address: 6800 MC DIVITT DR. Cit~: Bakersfield ST: CA YES P~E O P L E I NVOLVE D OCCUPANT · Phone: ( ) Zip: 93313 CASUALTIES Fire Service. Casualties: 'Injuries: 000 Non Fire Service casualties: Injuries: 000 Fatalities: 000 Fatalities: 000 COMPLETE FOR HAZARDOUS MATERIALS OE$: 28-110 Area of Release: 61 MACHINERY ROOM, AREA Release Level: A01 Rel Factor(s): 54 OT~ER PART FAILURE, LEAK, BREAK Contr. Factor(s): 6'23 MALFUNCTION OR EQUIPMENT Estimated ~ Chemicals Release: 001 BAKERSFIELD FIRE DEPARTMENT~ Incident Number: 93-007373-000 Incident Date: 05/23/93 Alarm Time: 1.714 Equip. Involved: 00 EQUIPMENT iNVOVLED/UNDETERMINED,NOT REPORTED Action(s) Taken: 34 PROVIDE MANPOWER Disposition: 8 INCIDENT SCENE RELEASED TO PROPERTY OWNER/MAN Haz Mat ID Sources Used (personnel): 32 RESPONSIBLE OWNER, MANAGER, SUPERVISOR :Haz Mat ID Sources Used (reference): 14 PLACARDS OR SIGNS ON BUILDING,ROOM,CONTAINER Fire Service Haz·Mat Casualties: Injuries: 000 Non-Fire Service Haz Mat Casualties: Injuries: 000 CHEMICALS Chem. Name: AMMONIA Hazard Class: 2 Chemical Abstract #: Physical State: 3 QTY ReleaSed: 00000 Extent of Release: 4 Contamination: ~1 Container: Type: 22 Material:, i .Use: 1 Features: 2 Cap: 00000 Fatalities: 000 Fatalities: 000 DOT ID: ? FLAMMABLE,~NoNFLAMMABLE AND ,CRYOGENIC GASES 7664-41-7 GAS Units: 1,5 CUBIC FEET CONFINED TO STRUCTURE OF ORIGIN AIR PIPE OR PIPELINE· IRON, STEEL & OTHER IRoN ALLOYS FIXED 'USE .-- Units~ DFFICER INCIDENT REPORT IDENTIFICATION Member 'making report: WELBORN, D. R. Officer in charge: WELBORN, D. R. Shift: B Report Date: 05/23/93- Member Signature: Officer in charge: · Page 1 BAKERSFIEL~IRE DEPARTMENT INCIDENT. Date: 05/23/93 )RT NARRATIVE -incident: 93-007373'000 WE RECIEVED A REPORT OF AN AMMONIA LEAK,WITH ONE INJURY,AT HEINZ FOODS INC. 6800 McDIVITT DR. UPON OUR ARRIVAL WE FOUND A LEAK IN THE SYSTEM INSIDE THE STRUCTURE. TWO WORKERS WERE EXPOSED TO THE GAS BUT REFUSED TREATMENT. HAZ-MAT TEAM RESPONDED AND THE LEAK WAS CONTROLLED BY USE OF THE SYSTEM COMPRESSORS.AND SHUT-OFF VALVES. THE' SITUATION WAS TURNED OVER TO HEINZ CO.REPRESENTATIVES WHEN THE HAZ-MAT TEAM DETERMINED IT SAFE TO DO SO. (STEVE IRWIN) INFLAMATION TO EYES.FROM AMMONIA.(REFUSED TREATMENT OR TRANSPORT). (.FRED LITTRELL) INHALATION OF AMMONIA. (REFUSED TREATMENT'OR TRANSPORT). pROOF OF PUBLICATION State of~california -ss CountY of Kern ~ ~ am a citizen of the United States and a resident of the County-aforesaid: I am Over the age of 18 years, and. not a party to or interested in the.above entitled matter. I am the assistant principal clerk of the printer of The Bakersfield Californian, a ..... newspape~ O'~gene~a-i circula- tion, printed and published daily in the.City of BakerSfield, county of Kern~ and which newspaper has been adjudged a newspaper of general circulation by the Superior Court of the~County of Kern, State of California, under date of February. 5, 1952, 'Case Number' 57610; that the notice, of which the annexed is.a printed copy, has been published in each regular and entire issue of said newspaper and not in any supplement thereof on the following dates, to wit: 9/16 all in the year' 1992 I certify (or declare) under penalty of perjury that. the' foregoing is true and corr- · { v v ~//3i~'ff~ture ~ated at~ Bakersfield, Ca SEPT, 16, 1992 · ROSLYN T. WILLIAMS Proof of Publication of: 16766 A RISK MANAGEMENT vontlon Program (RMPP) has/ b~en prepared by Pestrltto Foods,] Wu6. located at GSa0 McDivitt DF.,[ Bakersfield, CA,~Th~_~ _RMPP de- s6~ibes~a-n~ ~d ~0~tr%ls dr- sighed, to prevent :a .ha~ardons material raeeidont. This RMPP will be available for public review for the next 45 days at the Bakers- fleM Fire Depar~nent, Hazardous -Materials Division 2130 G St, Ba- kersfleld, CA,9320L C~ntact Ba~ bara Brenner for information I regarding .tlda RMPP. ,. ~September-16~ 1992 (16766) ' RECEIVED SEP 1 7 1992 HAT, ~=4AT. OtV. PROOF OF PUBLICATION CITY of BAKERSFIELD "wE' CARE" FIRE DEPARTMENT S.D. JOHNSON FIRE CHIEF Al Sautner Plant. Manager Pestritto Foods 6800 McDivitt Dr. Bakersfield,' CA 93313 June 17, 1992 2101 H .STREET BAKERSFIELD, 933ql 326-3911 Mr. Sautner: Pestritto Foods has submitted 'risk management planning information marked "confidential" to the Bakersfield Fire Department Hazardous Materials Division. Pursuant to Division 20, Chapter 6.95, Section 25538(a) of the California Health and Safety Code, "if a business°believes that any information required to be reported by ~this article, involves the release of a trade secret, the business shall provide the information to the administering agency and shall notify the administering agency in writing of that belief". Designation of a document as "confidential" is not adequate for purposes of protecting' information as a trade secret. Please review all of the documents which you have submitted t° the Bakersfield Fire Department Hazardous Materials Division containing information designated "cOnfidential". Supply written notification to this agency Specifying which information qualifies as trade secre(as defined by the California Government Code, Section 6254.7 and Section 1060 of the Evidence Code. Clearly state the reasons why the information is considered trade secret. Risk management planning information, for whidh a substantiated trade secret claim has not been filed by July 17, 1992 will be released to the public upon request. Public requests for disclosure of trade secret information will be processed in accordance with the requirements of Chapter 6.95, Section 2511. Please contact the Hazardous Materials Division at 326-3979 if you have any questions regarding trade secrets. · Sincerely, / Hazardous Materials Coordinator Approved as tO form Michael G. AIIford, Deputy City Attorney Item # NH3 Equip. Guide Word Deviation 1 Fill No No Flow Connections L~ L~ UU U U LV.J ~UUU U e UL-~ -PESTRITTO FOODS,' ING.-HAZOP REVIEW SUMMARY, Possible Cause Fill valve closed or blocked Consequence Will relieve thru truck Comments Typical vendor truck recirculation system settings are below 250 psig. Dead head pressure on typical vendor pump is 225 psig. PSV on NH3 receiver is set @ 300 psig. Delivery hoses are tested once per year at twice the receiver pressure or at least 500 psig. SG**-Relief system on vendors truck · SG-Operator training ,, **SG=Safeguard More More Flow Less Less Flow Reverse Reverse Flow Safety valve fails ~,- Hose failure, truck pulls away without disconnecting ~ ~Operator opens open-ended valve Partially plugged or blocked line Delivery pump falls Maximum flow through PSV Release contents of hose. Back check valve prevents ammonia leak from receiver Max release thru orifice Slow product transfer. Worst case, delivery system relieves back to truck. Flow could be back to delivery truck Very rare incident-PSV vent thru scrubber tank Back check valve will be screwed into isolation valve on controlled pressure receiver during filling operation. SG-Truck is equipped with excess flow valve. SG-Back check valve installed on fill hose SG-SCBA on site for emergency response SG-Ambient ammonia monitor and engine room scrubber system. SG-Pestritto Foods personnel.witness loading SG-Operator Training SG-AII open ended valves ars plugged or capped SG-Ambient ammonia monitor and engine room scrubber system. SG-Operator Training No public consequence SG-Operator Training SG-Delivery truck relief system No public consequence SG-Back check valve on vendor's hose Page 1 PESTRITTO FOODS, INC.-HAZOP REVIEW SUMMARY Item # NH3 Equip. Guide Word. Deviation Possible Cause Consequence Comments I Fill More More Pressure Connections (Cont.) Vendor tanker overfills receiver Additional compressors start up. If continued, compressors shut down on high discharge prsssure or temperature There is sufficient gas volume in system to avoid hydraulicing vessels, if vessels ars not valved out (isolated) Worst case, PSV may lift. Normal vendor pressure to fill tank is 120 to150 psig. Dead head press. is 225 psig. SG-Pestritto Maint. staff always witnesses loading. SG-Sight glass to observe level of NH3 SG-PSV relieve through scrubber tank SG-Operator Training Less Less pressure Vendor truck pump failure - insufficient pressure No product transfer No public consequence Other Truck hits valves (Not possible since valves are on bottom of receiver - receiver is isolated in building) · Thermosyphon No Receiver More No Flow More Flow System idle, power outage Relief valve fails-lifts Opening emergency dump valve Opening of unplugged valves '¥ Sight glass failure Gauge failure System equalizes pressure Maximum flow through PSV Release to scrubber tank Max release through orifice Discharge until system can be isolated Discharge until system can be isolated No public consequence Very rare incident SG-Relief system vents to scrubber tank Emergency dump valve is located in a locked emergency refrigerant control box SG-Operator Training SG-AII open ended valves are plugged SG-Ambient sensor and engine room scrubber SG-Operator Training SG-Bullseye type sight glass is rssistant to impact. SG-SCBA on site for emergency response SG-Operator Training SG-Ambient sensor and engine room scrubber SG-Gaugss have isolation valves SG-Ambient sensor and engine room scrubber SG-SCBA on site for emergency response SG-Operator Training Page 2 Item # NH3 Equip. 2 Thermosyphon Receiver (Cont.) PESTRITTO FOODS, INC.-HAZOP REVIEW SUMMARY Guide Word Deviation ~ Possible Cause Less Less flow High pressure liquid line plugged or blocked More More Pressure Overfilling Less - Less Pressure Liquid ammonia trapped in oil cooler (valves closed on NH3 line). Compressor failures/shutdown Consequence Less cooling of the refrigerated rooms Compressors shut down on high discharge pressure/temperatura Additional compressors start up. If continued, compressors shut down on high discharge pressura or temperature There is sufficient gas volume in system to avoid hydraulicing vessels, if vessels are not valved out (isolated) Worst case, PSV may lift. Overpressure liquid ammonia pipe System equalizes pressures Comments Room temperatures are monitored closely. Refrigeration problem would 'be detected rapidly. SG-High temperature/pressure shutdowns on compressors. Normal vendor pressure to fill tank is 120 to150 psJg. Dead head press. is 225 psig. SG-Pestritto Maint. staff always witnesses loading. SG-Sight glass to observe level of NH3 SG-PSV relieve through scrubber tank SG-Opemtor Training SG-Thermal relief valves installed on NH3 line. SG-Operator Training No public.consequence Mo re Less More Temperature Evaporative condenser motor fails Failure can be fan motor or water' recirculation pump failure Fire in building Less Temperature Compressors malfunction Compressor discharge does not condense. Thermostats still call for cooling. Compressors eventually shut down on high discharge head or high discharge temperature Ammonia refrigeration control panel can balance system pressures. Worst case, PSV relieves Less temperature means less pressure and less cooling duty. SG-High head shut down common to all compressors. SG-Two sets of fans on the evaporative condenser SG-High discharge temperature shutdown SG-Operator Training SG-Ammonia system emergency control panel SG-Operator Training SG-PSV vents through scrubber tank SG-Most of the building materials ara nonflammable SG-Comprsssor control panel alarms SG-Operator Training Room temperatures are monitored closely. Refrigeration problem would be detected rapidly. Page 3 .. Item # 2 NH3 Equip. Guide Word Thermosyphon More Receiver (Cont.) PESTRITTO FOODS, INC.-HAZOP REVIEW SUMMARY Deviation Possible Cause Consequence More Composition Leak in compressor oil cooler Ammonia in oil system. Compressors may shut down on Iow oil pressure or high oil temporatu re. MOre Less More Level Less Level Level pilot sensor failure/high pressure liquid I!ne blocked or plugged Evaporative condenser failure Compressor discharge not condensing Receiver fills with liquid, may lose some of the refrigeration capacity where the liquid ammonia would have been in service. May shut down compressor on high discharge pressure/temperature Without condensation, pressure builds. Compressors shut down on high discharge temperature or pressure. Level controller fails Uquid ammonia to controlled pressure receiver. Receiver has plenty of capacity Other Liq. Ammonia No line Maintenance No Flow Draining oil Une blocked, or isolated Oil will be drained through the oil pot (vs. draining oil through a valve on the vessel) If liquid NH3 line, pressure would increase in line due to liquid expansion More More Flow Power failure System equalizes to 80 - 100 psig Discharge until leak isolated Low volume leaks, odor easily deteCted Comments SG-Ambient sensor in engine room and automated scrubber system SG-SCBA on sight for emergency response SG-Opsrator Training SG-Operator Training SG-High discharge temperature shutdown Room temperatures are monitored closely. Refrigeration problem would be detected rapidly. SG-High discharge temperature shutdown SG-Operator Training SG-High head shut down common to all compressors. SG-Controlled pressure receiver capacity. SG-Operator Training SG-Level Eyes SG-Operator Training SG-Oil drain pot designed to drain oil. SG-Operator Training SG-Pipelinss installed per ANSI/ASME 31.5 SG-Ambient sensor in engine room and automated scrubber system SG-SCBA on s'rte for emergency response Would require several valves to be closed simultaneously in order to isolate this line. No public consequence SG-Ambient sensor in engine room and automated scrubber system· · SG-SCBA on site for.emergency response SG-Oporator Training . Page 4 PESTRITTO FOODS, INC.-HAZOP REVIEW SUMMARY Item # 3 NH3 Equip. Liq. Ammonia line (Cont.). Guide Word More~ Deviation Possible Cause More Flow ~ Pipe failure Consequence ~eaSe co~ ~size of opening ~ Worst credible case, liquid phase release Comments SG-Pipelinss installed per ANSl/ASME 31.5 SG-Ambient sensor in engine room and automated scrubber system SG-SCBA on site for emergency response SG-Opsrator.Training Less Fiow Line blocked or closed Lsss cooling capacity for freezers Room temperatures are monitored ~losely. Refrigeration problem would be detected rapidly. Shell and tUbe heat exchanger (Glycol chiller) More No More Pressure~ Liquid line is i~olated (bloCked on both ends) with line full of liquid ammonia . No Flow Heat exchanger isolated Failure of solenoid valve for NH3 supply Power failure Could.rupture linel Release contents of line into engine room "Flooded" type heat exchanger could trap liquid ammonia. Normal gas volume will accomodate liquid ammonia expansion; Gas volume controlled by level control boot compressor suction would emPty NH3 from heatexchanger. Loss of refrigeration capacity. System equalizes to 80 - 100 psig SG-Pipelines installed per ANSI/ASME 31.5 SG-Ambient sensor in engine room and automated scrubber system ., SG-SCBA on site for emergency response SG-Operator Training Would require several valves to be closed simultaneously in order to isolate this line. SG-PSV relieve through scrubber tanl~ ' SG-Operat°r Training No public consequence No public consequence More More Flow Solenoid failure Level switch failure Tube failure ir{ heat exchanger Higher heat exchange rate,'illycol system pressure may increase if glycol freezes. Any excess NH3 entrained in gas stream ,,~ould be removed by intercooler. Ammonia and glycol would be mixed and pumped through the system Could result in Iow release rate in glycol exPansiontank.~ ' Page 5 ' public concern · SG-Operator Training. SG-High level alarm.- SG-Ambient sensor in engine room and automated scrubber system SG-SCBA on sIte for emergency response SG-Operator Training PESTRI'I-rO FOODS, INC.-HAZOP REVIEW SUMMARY Item # 4 NH3 Equip. Shell and tube heat exchanger (Glycol Chiller) (Cont) Plate heat exchanger (Dough mixer) Guide Word Less More Less More Deviation Less Flow More Level Less Level More Flow Possible Cause Solenoid failure Level switch failure Solenoid failure Level switch failure Solenoid failure Level switch failure Float switch failure, solenoid switch failure Hole in heat exchanger Consequence Glycol system warms up, less refrigeration duty. Higher heat exchange rate, glycol system pressure may increase if glycol freezes. Any excess NH3 entrained in gas stream would be removed by intercooler. Glycol system warms up, less refrigeration duty. Liquid ammonia would overflow into the intercooler. Ammonia will enter process water and ruin dough batch. Comments Room temperatures are monitored closely. Refrigeration problem would be detected rapidly. No public concern .SG-Operator Training SG-High level alarm Room temperatures are monitored closely. Refrigeration problem would be detected rapidly. No public consequence Would be discovered immediately in production area. Ammonia would be absorbed in the process water, resulting in a slow release. SG-Operator Training SG-SCBA on site for emergency response Less Less Row Float switch failure, solenoid valve Less refrigeration duty available failure No public consequence More More Level Solenoid failure Level switch failure Higher heat exchange rate, glycol system pressure may increase if glycol freezes. Any excess NH3 entrained in gas stream would be removed by intercooler. No public concern SG-Operator Training SG-High level alarm Less Less Level Solenoid failure Level switch failure Glycol system warms up, less refrigeration duty. Room temperatures are monitored closely. Refrigeration problem would be detected rapidly. .. Controlled Pressure Receiver More Less More Flow Float valve failure, pilot sensor failure Less Flow Float valve fallure~,~Pilot sensor fallura Higher liquid level in receiver. Receiver is sized to accomodate all liquid NH3. Less cooling of the refrigerated rooms Compressors shut down on high discharge pressure/temperature No public consequence No public consequence Page 6 Item # PESTRn-I'O FOODS, INC.-HAZOP REVIEW SUMMARY NH3 Equip. Guide Word Deviation Possible Cause Consequence comments 7 8 Controlled Pressure Receiver (Cont.) Ammonia Purger Intercooler More More Pressure Failure of pressure reducing valve More More Level Float valve failure, pilot sensor 'failure Less Less Level Float valve failure, pilot sensor failure More Moro Flow Less Less Row~ Liquid NH3 solenoid valve fails open or float switch fails Air purge solenoid valve fails open or float switch fails Water solenoid valve fails closed More Moro Level Float switch failure Less Less Level No : No Flow More More Flow Float switch/solenoid failure Pipe blocked Power failure suction regulator failure NH3 inlet solenoid valve fails open Increased pressure in receiver. PSVs set higher than normal system operating pressure; therefore,' release not likely. Higher liquid level in receiver. Receiver is sized to accomodate all liquid NH3. - Less cooling of the refrigerated rooms Compressors shut down on high discharge pressure/temPerature Excessive NH3 flow through purger SG-Ambient sensor in engine room and automated scrubber system SG-SCBA on site for emergency response SG-Operator Training SG-PSV release to scrubber tank No public consequence No public consequence No public consequence Excess NH3 flows through water bubbler Ammonia flows into sewer line Ammonia relief check valve sends ammonia to compressor suction Excessive purge cycle. Aqua ammonia to sewer.~ System equalizes pressure. Low rate release into sewer SG-Flow is restricted with orifice SG-Operator training Low rate release into sewer SG-Flow is restricted with orifice SG-Operator training No public consequence No public consequence No public consequence Uquid level in intercooler rises. Activates No public consequence liquid dump cycle. Dumps to Iow suction SG-High level switch emergency shut down accumulator (LSA), LSA dumps to controllec SG-Operator Training pressure receiver. If dump cycle was not sufficient, emergency shut down on high liquid level in intercooler. Page 7 Item # PESTRITTO FOODS, INC.-HAZOP REVIEW SUMMARY NH3 Equip. Guide Word Deviation Possible Cause Consequence Comments Intercooler Less Less Flow (Cont.) Low Suction No Accumulator More More Pressure Less Less Pressure More More Level Less Less Level No Flow More More Flow NH3 inlet solenoid valve fails closed. Booster compressor discharge does not Inlet line partially blocked, condense. Hot gas to high stage Control boot isolated compressor, compressor shut down on high discharge temperature or pressure SG-Compressor shut down controls SG-Operator Training NH3 inlet solenoid valve falls open Liquid level in intercooler riss~. Activates No public consequence liquid dump cycle. Dumps to Iow suction SG-High level switch emergency shut down accumulator (LSA), LSA dumps to controllec SG-Operator Training pressure receiver. If dump cycle was not sufficient, emergency shut down on high liquid level in intercooler. Malfunctioning compressor Less refrigeration capacity No public consequence NH3 inlet solenoid valvefalls open Liquid level in intercooler rises. Activates No public consequence liquid dump cycle. Dumps to Iow suction · SG-High level switch emergency shut down accumulator (LSA), LSA dumps to contmllec SG-Operator Training pressure receiver. If dump cycle was not sufficient, emergency shut down on high liquid level in intercooler. Control column isolated and Iow level float switch is activated Intercooler can hold entire thermal syphon No public consequence receiver charge. SG-Operator Training NH3 inlet solenoid valve fails closed. Booster compressor discharge does not Inlet line partially blocked, condense. Hot gas to high stage Control boot isolated compressor, compressor shut down on high discharge temperature or pressure SG-Compressor shut down controls SG-Opsrator Training Line blocked, system isolated Power outage See more level-lntercooler System pressure equalizes SG-Opsrator Training No public consequence Solenoid valve from intercooler fails in open position Liquid ammonia flows into dump traps. If SG-High level emergency shut down dump traps do not operate fast enough, high SG-Dump traps liquid level switch will operate emergency SG-Operator Training shut down. Page 8 Item # 9 NH3 Equip. Guide Word Deviation PESTRITTO FOODS, INC.-HAZOP REVIEW SUMMARY poSSible Cause .' '. Consequence Comments Low Suction Accumulator (Cont.) LeSS Less flow Reverse Reverse Flow More More PreSSure Hand expansion valve improperly set, plugged line': See more level.lntercooler Cold storage temp will rise Check valve on Phillips dump fails Inlet to compreSSOr closed -- Second Phillips dump works mbre often. Worst case, E.~D.SD on high liquid level. · PreSSure increase in refrigerant return lines. Refrigeration system performance decrease., Worst case, PSV lifts SG-Operator Training Would be discovered quickly No public consequence SG-High level emergency shut down SG-Operator Training ~ ' SG-Operator Training SG-PSV release to scrubber tank LeSS Less pressure Normal operation More More Level Check valve on Phillips dump fails Second Phillips dump works more often. Worst case, ESD on high liquid level. No public consequence SG-High level emergency shutdown SG-Operator Training LeSS LeSS Level Normal operation 10 Evaporators No More 'More LeSS No Flow Une blocked or isolated. 'Operator error Power failure More Flow -~Evaporator leak More pressure'~ Une blocked, system isolated Operator error~ Le~ Flow Malfunctioning solenoid valve Hand expansion valve improperly set Pressure increase in refrigerant return lines. SG-Operator Training Refrigeration system performance decreases System equalizes to 80 - 100 psig No public consequence Release to holding freezer SG-SCBAs on site for emergency response SG-Evacuation plan SG-Operator training Less refrigeration capacity. Worst case, ammonia expansion bursts evaporator and releases contents of evaporator to holding freezer. SG-Operator Training SG-SCBA on site for emergency response Cold storage temperature will rise Would be discovered quickly Page 9 PESTRI'I-rO FOODS, INC.-HAZOP REVIEW SUMMARY Item # NH3 Equip. Guide Word Deviation Possible Cause Consequence Comments 11 Compressors No No Flow Power failure System equalizes pressure No public consequence Less More Flow -~r Discharge line failure Less Flow Suction regulator doses Release to engine room. Maximum release is compressor throughput. Loss of refrigeration capacity SG-Pipelines installed per ANSI/ASME 31.5 SG-Ambient sensor in engine room and automated scrubber system SG-SCBA on site for emergency response SG-Operator training No public consequence More More Pressure Discharge not condensing Compressor discharge does not condense. Compressors eventually shut down on high discharge head or high discharge temperature SG-High head shut down common to all compressors. SG-Two sets of fans on the evaporative condenser SG-High discharge temperature shutdown SG-Operator Training Discharge valve closed or blocked System shuts down on high pressure No public consequence SG-Operator Training SG-High pressure shut down switch Less Less Pressure Compressor failure Loss of refrigeration capacity No public consequence More More Temperature Oil cooler malfunction Compressor shut down on high oil temperature. No public consequence SG-Operator Training SG-High oil temperature shut down switch SG-High discharge temperature shutdown Page 10 COMPUTER GENERATED VAPOR DISPERSION MODEL DATA DISPERSION MODEL DATA TABLE 3 CONFIDENTIAL SUPPLEMENTARY MATERIAL FOR FIRE DEPARTMENT USE ONLY SITE DATA INFORMATION: Location: BAKERSFIELD, CALIFORNIA Building Air Exchanges Per Hour: 0.64 (Unsheltered single storied) Date & Time: Fixed at December 15, 1991 & 0800 hours CHEMICAL INFORMATION: Chemical Name: AMMONIA, ANHYDROUS Molecular Weight: 17.03 kg/kmol TLV-TWA: 25.00 ppm IDLH: 500.00 ppm Footprint Level of Concern: 50 ppm Boiling Point: -28.17° Fahrenheit Vapor Pressure at Ambient Temperature: greater than 1 atm Ambient Saturation Concentration:' 1,000,000 ppm or 100.0% ATMOSPHERIC INFORMATION:(MANUAL INPUT OF DATA) Wind: 5 mph from SSE No Inversion Height Stability Class: C Air Temperature: 40° Fahrenheit Relative Humidity: 50% Ground Roughness: Urban or forest Cloud Cover: 7 tenths SOURCE STRENGTH INFORMATION: Direct Source: 25.4 pounds Source Height: 0 Release Duration: 1 minute Release Rate: 0.423 pounds/sec Total Amount Released: 25.4 pounds Note: This chemical may flash boil and/or result in two phase flow. · Use both dispersion modules to investigate its potential behavior. FOOTPRINT INFORMATION: (GAUSS SELECTED) Dispersion Module: Gaussian User specified LOC: 50 ppm Max Threat Zone for LOC: 201 yards Max Threat Zone for IDLH: 63 yards For more detailed information, check the Time Dependent Conc/Dose information at specific locations CONFIDENTIAL' ' SUPPLEMENTARY MATERIAL FOR FIRE DEPARTMENT USE ONLY SITE DATA INFORMATION: Location: BAKERSFIELD, CALIFORNIA Building Air Exchanges Per Hour: 0.64 (Unsheltered single storied) Date & Time: Fixed at December 15, 1991 & 0800 hours CHEMICAL INFORMATION: Chemical Name: AMMONIA, ANHYDROUS Molecular Weight: 17.03 kg/kmol TLV-TWA: 25.00 ppm IDLH: 500.00 ppm Footprint Level of Concern: 50 pprn Boiling Point: -28.17° Fahrenheit Vapor Pressure at Ambient Temperature: greater than 1 atm Ambient Saturation Concentration: 1,000,000 ppm or 100.0% ATMOSPHERIC INFORMATION:(MANUAL INPUT OF DATA) ....... Wind:'5 mPh.from SSE .~ .. No Inversion Height. Stability Class: C Air Temperature: 40© Fahrenheit Relative Humidity: 50% Ground Roughness: Urban or forest Cloud Cover: 7 tenths SOURCE STRENGTH INFORMATION: Puddle Area: 150 square feet Puddle Mass: 97.1 pounds Soil Type: Default Ground Temperature: 40© Fahrenheit Initial Puddle Temperature: Ground temperature Release Duration: 6 minutes Max Computed Release Rate: 61.8 pounds/min Max Average Sustained Release Rate: 18.7 pounds/min (averaged over a minute or more) Total Amount Released: 97.1 pounds FOOTPRINT INFORMATION: (GAUSS SELECTED) Dispersion Module: Gaussian User specified LOC: 50 ppm Max Threat Zone for LOC: 171 yards Max Threat Zone for IDLH: 53 yards For more detailed information, check the Time Dependent Conc/Dose information at specific locations DISPERSION MODEL DATA TABLE 4 CONFIDENTIAL SUPPLEMENTARY MATERIAL FOR FIRE DEPARTMENT USE ONLY SITE DATA INFORMATION: Location: BAKERSFIELD, CALIFORNIA Building Air Exchanges Per Hour: 0.64 (Unsheltered single storied) Date & Time: Fixed at December 15, 1991 & 0800 hours CHEMICAL INFORMATION: Chemical Name: AMMONIA, ANHYDROUS Molecular Weight: 17.03 kg/kmol TLV-TWA: 25.00 ppm IDLH: 500.00 ppm Footprint Level of Concern: 50 ppm Boiling Point: -28.17° Fahrenheit Vapor Pressure at Ambient Temperature: greater than 1 atm Ambient Saturation Concentration: 1,000,000 ppm or 100.0% ATMOSPHERIC INFORMATION:(MANUAL INPUT OF DATA) Wind: 5 mph from SSE No Inversion Height Stability Class: C Air Temperature: 40° Fahrenheit Relative Humidity: 50% Ground Roughness: Urban or forest Cloud Cover: 7 tenths SOURCE STRENGTH INFORMATION: Direct Source: 2.54 pounds/sec Source Height: 0 Release Duration: ALOHA limited the duration to 1 hour Release Rate: 152 pounds/min Total Amount Released: 9,140 pounds. Note: This chemical may flash boil and/or result in two phase flow. Use both dispersion modules to investigate its potential behavior. FOOTPRINT INFORMATION: (GAUSS SELECTED) Dispersion Module: Gaussian User specified LOC: 50 ppm Max Threat Zone for LOC: 494 yards. Max Threat Zone for IDLH: 155 yards For more detailed information, check the Time Dependent Conc/Dose information at specific locations CONFIDENTIAL SUPPLEMENTARY MATERIAL FOR FIRE DEPARTMENT USE ONLY SITE DATA INFORMATION: Location: BAKERSFIELD, CALIFORNIA Building Air Exchanges Per Hour: 0.64 (Unsheltered single storied) Date & Time: 'Fixed at December 15, 1991 & 0800 hours CHEMICAL INFORMATION: Chemical Name: AMMONIA, ANHYDROUS Molecular Weight: 17.03 kg/kmol TLV-TWA: 25.00 ppm IDLH: 500.00 ppm Footprint Level of Concern: 50 ppm Boiling Point: -28.17° Fahrenheit Vapor Pressure at Ambient Temperature: greater than 1 atto Ambient Saturation Concentration: 1,000,000 ppm or 100.0% ATMOSPHERIC INFORMATION:(MANUAL INPUT OF DATA) Wind: 5 mph from SSE No Inversion Height. Stability Class: C Air Temperature: 40° Fahrenheit Relative Humidity: 50% Ground Roughness: Urban or forest ClOud Cover: 7 tenths SOURCE STRENGTH INFORMATION: Puddle Area: 1000 square feet Puddle Mass: 582.6 pounds Soil Type: Default Ground Temperature: 40° Fahrenheit Initial Puddle Temperature: Ground temperature Release Duration: 6 minutes Max Computed Release Rate: 371 pounds/min Max Average Sustained Release Rate: 112 pounds/min (averaged over a minute or more) Total Amount Released: 583 pounds FOOTPRINT INFORMATION: (GAUSS SELECTED) Dispersion Module: Gaussian User specified LOC: 50 ppm Max Threat Zone for LOC: 421 yards Max Threat Zone for IDLH: 130 yards For more detailed information, check the Time Dependent Conc/Dose information at specific locations DISPERSION MODEL DATA TABLE 5 CONFIDENTIAL SUPPLEMENTARY MATERIAL FOR FIRE DEPARTMENT USE ONLY SITE DATA INFORMATION: Location: BAKERSFIELD, CALIFORNIA Building Air Exchanges Per Hour: 0.64 (Unsheltered single storied) Date & Time: Fixed at December 15, 1991 & 0800 hours CHEMICAL INFORMATION: Chemical Name: AMMONIA, ANHYDROUS Molecular Weight: 17.03 kg/kmol TLV-TWA: 25.00 ppm IDLH: 500.00 ppm Footprint Level of Concern: 50 ppm Boiling Point: -28.17° Fahrenheit Vapor Pressure at Ambient Temperature: greater than 1 atm Ambient Saturation Concentration: 1,000,000 ppm or 100.0% ATMOSPHERIC INFORMATION:(MANUAL INPUT OF DATA) Wind: 5 mph from SSE ..... No Inversion Height Stability Class: C Air Temperature: 40° Fahrenheit Relative Humidity: 50% Ground Roughness: Urban or forest Cloud Cover: 7 tenths SOURCE STRENGTH INFORMATION: Direct Source: 325 pounds Source Height: 0 Release Duration: 1 minute Release Rate: 5.42 pounds/sec Total Amount Released: 325 pounds Note: This chemical may flash boil and/or result in two phase flow. Use both dispersion modules to investigate its potential behavior. FOOTPRINT INFORMATION: (GAUSS SELECTED) Dispersion Module: Gaussian User specified LOC: 50 ppm Max Threat Zone for LOC: 658 yards Max Threat Zone for IDLH: 227 yards For more detailed information, check the Time Dependent Conc/Dose information at specific locations CONFIDENTIAL SUPPLEMENTARY MATERIAL FOR FIRE DEPARTMENT USE ONLY SITE DATA INFORMATION: Location: BAKERSFIELD, CALIFORNIA Building Air Exchanges Per Hour: 0.64 (Unsheltered single storied) Date & Time: Fixed at December 15, 1991 & 0800 hours CHEMICAL INFORMATION: Chemical Name: AMMONIA, ANHYDROUS Molecular Weight: 17.03 kg/kmol TLV-TWA: 25.00 ppm IDLH: 500.00 ppm Footprint Level of Concern: 50 ppm Boiling Point: -28.17° Fahrenheit Vapor Pressure at Ambient Temperature: greater than 1 atm Ambient Saturation Concentration: 1,000,000 ppm or 100.0% ATMOSPHERIC INFORMATION:(MANUAL INPUT OF DATA) ....... Wind:..5 mphfrom.SSE .............. Nolnversion Height Stability Class: C Air Temperature: 40° Fahrenheit Relative Humidity: 50% Ground Roughness: Urban or forest Cloud Cover: 7 tenths SOURCE STRENGTH INFORMATION: Puddle Area: 1000 square feet Puddle Mass: 3689 pounds Soil Type: Default Ground Temperature: 40° Fahrenheit Initial Puddle Temperature: Ground temperature Release Duration: 30 minutes Max Computed Release Rate: 198 pounds/min Max Average Sustained Release Rate: 127 pounds/min (averaged over a minute or more) TOtal Amount Released: 3,690 pounds FOOTPRINT INFORMATION: (GAUSS SELECTED) Dispersion .Module: Gaussian User specified LOC: 50 ppm Max Threat Zone for LOC: 449 yards Max Threat Zone for IDLH: 139 yards For more detailed information, check the Time Dependent Conc/Dose information at specific locations DISPERSION MODEL DATA ADVERSE WEATHER CONDITIONS HEAVY GAS MODEL CONFIDENTIAL SUPPLEMENTARY MATERIAL FOR FIRE DEPARTMENT USE ONLY SITE DATA INFORMATION: Location: BAKERSFIELD, CALIFORNIA Building Air Exchanges Per Hour: 0.64 (Unsheltered single storied) Date & Time: Fixed at December 15, 1991 & 0800 hours CHEMICAL INFORMATION: Chemical Name: AMMONIA, ANHYDROUS Molecular Weight: 17.03 kg/kmol TLV-TWA: 25.00 ppm IDLH: 500.00 ppm Footprint Level of Concern: 50 ppm Boiling Point: -28.17° Fahrenheit Vapor Pressure at Ambient Temperature: greater than 1 atm Ambient Saturation Concentration: 1,000,000 ppm or 100.0% ATMOSPHERIC INFORMATION:(MANUAL INPUT OF DATA) Wind: 5 mph from SSE No Inversion Height Stability Class: C Air Temperature: 40° Fahrenheit Relative Humidity: 50% Ground Roughness: Urban or forest Cloud Cover: 7 tenths SOURCE STRENGTH INFORMATION: Direct Source: 325 pounds Source Height: 0 Release Duration: 1 minute Release Rate: 5.42 pounds/sec Total Amount Released: 325 pounds Note: This chemical may flash boil and/or result in two phase flow. Use both dispersion modules to investigate its potential behavior. FOOTPRINT INFORMATION: (HEAVY GAS SELECTED) Model Run: Heavy Gas User specified LOC: 50 ppm Max Threat Zone for LOC: 1,648 yards Max Threat Zone for IDLH: 420 yards For more detailed information check the Time Dependent Conc/Dose information at specific locations. CONFIDENTIAL SUPPLEMENTARY MATERIAL FOR FIRE DEPARTMENT USE ONLY SITE DATA INFORMATION: Location: BAKERSFIELD, CALIFORNIA Building Air Exchanges Per Hour: 0.64 (Unsheltered single storied) Date & Time: Fixed at December 15, 1991 & 0800 hours CHEMICAL INFORMATION: Chemical Name: AMMONIA, ANHYDROUS Molecular Weight: 17.03 kg/kmol TLV-TWA: 25,00 ppm IDLH: 500.00 ppm Footprint Level of ConCern· 50 ppm Boiling Point: -28.17° Fahrenheit Vapor Pressure at Ambient Temperature: greater than 1 atm Ambient Saturation Concentration: 1,000,000 ppm or 100.0% ATMOSPH ERIC IN FORMATION :(MANUAL INPUT OF DATA) Wind: 5 mph from SSE No Inversion Height - Stability Class: C Air Temperature: 40° Fahrenheit Relative Humidity: 50% Ground Roughness: Urban or forest Cloud Cover: 7 tenths SOURCE STRENGTH INFORMATION: Direct Source: 25.4 pounds Source Height: 0 Release Duration: 1 minute Release Rate: 0.423 pounds/sec Total Amount Released: 25.4 pounds Note: This chemical may flash boil and/or result in two phase flow. Use both dispersion modules to investigate its potential behavior. FOOTPRINT INFORMATION: (HEAVY GAS SELECTED) Model Run: Heavy Gas User specified LOC: 50 ppm Max Threat Zone for LOC: 401 yards Max Threat Zone for IDLH: 90 yards For more detailed information check the Time Dependent Conc/Dose information at specific locations. CONFIDENTIAL SUPPLEMENTARY MATERIAL FOR FIRE DEPARTMENT USE ONLY SITE DATA INFORMATION: LoCation: BAKERSFIELD, CALIFORNIA Building Air Exchanges Per Hour: 0.64 (Unsheltered single storied) Date & Time: Fixed at December 15, 1991 & 0800 hours CHEMICAL INFORMATION: Chemical Name: AMMONIA, 'ANHYDROUS Molecular Weight: 17.03 kg/kmol TLV-TWA: 25.00 ppm IDLH: 500.00 ppm Footprint Level of Concern: 50 ppm Bo!ling Point: -28.17° Fahrenheit Vapor Pressure at Ambient Temperature: greater than 1 atm Ambient Saturation Concentration: 1,000,000 ppm or 100.0% ATMOSPHERIC INFORMATION:(MANUAL INPUT OF DATA) Wind: 5 mph from SSE No Inversion Height Stability Class: C Air Temperature: 40° Fahrenheit Relative Humidity: 50% Ground Roughness: Urban or forest Cloud Cover: 7 tenths SOURCE STRENGTH INFORMATION: Direct Source: 2.54 pounds/sec Source Height:.0 Release Duration: ALOHA limited the duration to 1 hour Release Rate: 152 pounds/min Total Amount Released: 9,140 pounds Note: This chemical may flash boil and/or result in two phaSe flow. Use both dispersion modules to investigate its potential behavior. FOOTPRINT INFORMATION: (HEAVY GAS SELECTED) Model Run: Heavy Gas User specified LOC: 50 ppm Max Threat Zone for LOC: 1,016 yards Max Threat Zone for IDLH: 227 yards 'For more detailed information check the Time Dependent Conc/Dose information at specific locations. DISPERSION MODEL DATA ADVERSE WEATHER CONDITIONS UNMITIGATED RELEASE CONFIDENTIAL SUPPLEMENTARY MATERIAL FOR FIRE DEPARTMENT USE ONLY SITE DATA INFORMATION: Location: BAKERSFIELD, CALIFORNIA Building Air Exchanges Per Hour: 0.53 (Unsheltered single storied) Date & Time: Fixed at December 15, 1991 & 0200 hours CHEMICAL INFORMATION:' Chemical Name: AMMONIA, ANHYDROUS Molecular Weight: 17.03 kg/kmol TLV-TWA: 25.00 ppm IDLH: 500.00 ppm Footprint Level of Concern: 50 ppm Boiling Point: -28.17° Fahrenheit Vapor Pressure at Ambient Temperature: greater than 1 atm Ambient Saturation Concentration: 1,000,000 ppm or 100.0% ATMOSPHERIC INFORMATION:(MANUAL INPUT OF DATA) .... Wind: 2.5 mph from SSE ..... No Inversion Height ... . Stability Class: F Air Temperature: 30° Fahrenheit Relative Humidity: 50% Ground Roughness: Urban or forest Cloud Cover: 1 tenths SOURCE STRENGTH INFORMATION: Direct Source: 325 pounds Source Height: 0 Release Duration: 1 minute Release Rate': 5.42 Pounds/sec Total Amount Released: 325 pounds 'Note: This chemical may flash boil and/or result in two phase flow. Use both dispersion modules to investigate its potential behavior. FOOTPRINT INFORMATION: (GAUSS SELECTED) Dispersion Module: Gaussian User specified LOC: 50 ppm Max Threat Zone for LOC: 1379 yards Max Threat Zone for IDLH: 574 yards For more detailed information, check the Time Dependent Conc/Dose information at specific locations CONFIDENTIAL SUPPLEMENTARY MATERIAL FOR FIRE DEPARTMENT USE ONLY SITE DATA INFORMATION: Location: BAKERSFIELD, CALIFORNIA Building Air Exchanges Per Hour: 0.53 (Unsheltered single storied) Date & Time: Fixed at December 15, 1991 & 0200 hours CHEMICAL INFORMATION: Chemical Name: AMMONIA, ANHYDROUS Molecular Weight: 17.03 kg/kmol TLV-TWA: 25.00 ppm IDLH: 500.00 ppm Footprint Level of Concern: 50 ppm Boiling Point: -28.17° Fahrenheit Vapor Pressure at Ambient Temperature: greater than 1 atm Ambient Saturation Concentration: 1,000,000 ppm or 100.0% ATMOSPHERIC INFORMATION:(MANUAL INPUT OF DATA) · Wind: 2.5 mph from SSE ....No Inversion Height Stability Class: F Air Temperature: 30° Fahrenheit Relative Humidity: 50% Ground Roughness: Urban or forest Cloud Cover: 1 tenths SOURCE STRENGTH INFORMATION: Puddle Area: 1000 square feet Puddle Mass: 3689 pounds Soil Type: Default Ground Temperature: 30° Fahrenheit Initial Puddle Temperature: Ground temperature Release Duration: 20 minutes Max Computed Release Rate: 205 pounds/min Max Average Sustained Release Rate: 184 pounds/min (averaged' over a minute or more) Total Amount Released: 3,690 pounds FOOTPRINT INFORMATION: (GAUSS SELECTED) Dispersion Module: Gaussian User specified LOC: 50 ppm Max Threat Zone for LOC: 1.7 miles Max Threat Zone for IDLH: 752 yards For more detailed information, check the Time Dependent Conc/Dose information at specific locations CONFIDENTIAL i SUPPLEMENTARY MATERIAL FOR FIRE DEPARTMENT USE ONLY SITE DATA INFORMATION: Location: BAKERSFIELD, CALIFORNIA Building Air Exchanges Per Hour: 0.53 (Unsheltered single storied) Date & Time: Fixed at December 15, 1991 & 0200 hours CHEMICAL INFORMATION: Chemical Name: AMMONIA, ANHYDROUS Molecular Weight: 17.03 kg/kmol TLV-TWA: 25.00 ppm IDLH: 500.00 ppm Footprint Level of Concern: 50 ppm Boiling Point: -28.17° Fahrenheit Vapor Pressure at Ambient Temperature: greater than 1 atm Ambient Saturation Concentration: 1,000,000 ppm or 100.0% ATMOSPHERIC INFORMATION:(MANUAL INPUT OF DATA) -'Wind: 2.5-mph from SSE ...... No Inversion Height Stability Class: F Air Temperature: 30° Fahrenheit Relative Humidity: 50% Ground Roughness: Urban or forest Cloud Cover: 1 tenths SOURCE STRENGTH INFORMATION: Direct Source: 325 pounds Source Height: 0 Release Duration: 1 minute Release Rate: 5.42 pounds/sec Total Amount Released: 325 pounds Note: This chemical may flash boil and/or result in two phase flow. 'Use both dispersion modules to investigate its potential behavior. FOOTPRINT INFORMATION: (HEAVY GAS SELECTED) Model Run: Heavy Gas User specified LOC: 50 ppm Max Threat Zone for LOC: 1.6 miles Max Threat Zone for IDLH: 623 yards For more detailed information check the Time Dependent Conc/Dose information at specific locations. DISPERSION MODEL DATA ADVERSE WEATHER CONDITIONS *10,000 ppm MODELS CONFIDENTIAL SUPPLEMENTARY MATERIAL FOR FIRE DEPARTMENT USE ONLY SITE DATA INFORMATION: Location: BAKERSFIELD, CALIFORNIA Building Air Exchanges Per Hour: 0.64 (Unsheltered single storied) Date & Time: Fixed at December 15, 1991 & 0800 hours CHEMICAL INFORMATION: Chemical Name: AMMONIA, ANHYDROUS Molecular Weight: 17.03 kg/kmol TLV-TWA: 25.00 ppm IDLH: 500.00 ppm Footprint Level of Concern: 10000 ppm Boiling Point: -28.17° Fahrenheit Vapor Pressure at Ambient Temperature: greater than. 1 atto Ambient Saturation Concentration: 1,000,000 ppm or 100.0% ATMOSPHERIC INFORMATION:(MANUAL INPUT OF DATA) Wind: 5 mph from SSE No Inversion Height Stability Class: C Air Temperature: 40° Fahrenheit Relative Humidity: 50% Ground Roughness: Urban or forest Cloud Cover: 7 tenths SOURCE STRENGTH INFORMATION: Direct Source: 325 pounds Source Height: 0 Release Duration: 1 minute Release Rate: 5.42 pounds/sec Total Amount Released: 325 pounds Note: This chemical may flash boil and/or result in two phase flow. Use both dispersion modules to investigate its potential behavior. FOOTPRINT INFORMATION: (GAUSS SELECTED) Dispersion Module: Gaussian User specified LOC: 10000 ppm Max Threat Zone for LOC: 50 yards Max Threat Zone for IDLH: 227 yards Note: Footprint was not drawn because effects of near-field patchiness make plume presentation unreliable for short distances. CONFIDENTIAL SUPPLEMENTARY MATERIAL FOR FIRE DEPARTMENT USE ONLY SITE DATA INFORMATION: Location: BAKERSFIELD, CALIFORNIA Building Air Exchanges Per Hour: 0.64 (Unsheltered single storied) Date & Time: Fixed at December 15, 1991 & 0800 hours CHEMICAL INFORMATION: Chemical Name: AMMONIA, ANHYDROUS Molecular Weight: 17.03 kg/kmol TLV-TWA: 25.00 ppm IDLH: 500.00 ppm Footprint Level of Concern: 10000 ppm Boiling Point: -28.17° Fahrenheit Vapor Pressure at Ambient Temperature: greater than 1 atm Ambient Saturation Concentration: 1,000,000 ppm or 100.0% ATMOSPHERIC INFORMATION:(MANUAL INPUT OF DATA) · ' Wind: 5 mph from SSE ........ No Inversion Height Stability Class: C Air Temperature: 40° Fahrenheit Relative Humidity: 50% Ground Roughness: Urban or forest Cloud Cover: 7 tenths SOURCE STRENGTH INFORMATION: Direct Source: 325 pounds Source Height: 0 Release Duration: 1 minute Release Rate: 5.42 pounds/sec Total Amount Released: 325 pounds Note: This chemical may flash boil and/or result in two phase flow. Use both dispersion modules to investigate its potential behavior. FOOTPRINT INFORMATION: (HEAVY GAS SELECTED) Model Run: Heavy Gas User specified LOC: 10000 ppm Max Threat Zone for LOC: 59 yards Max Threat Zone for IDLH: 420 yards For more detailed information check the Time Dependent Conc/Dose information at specific locations. Fire Department 2101 "H" Street Bakersfield, CA 93301. Fax Phone No. (805) 395-1349 Office (805) 326-3941 .. Date: CtJll ,19 q~ PLEASE ROUTE AS SOON AS POSSIBLE TO: Company/Organization: ~_~c~a.~ /'~om;c0 "~,X~,o,'-~ Fax No. Sending Message to: FROM: Name: Contact Person: Number of Pages (including cover sheet): ~-- Description of Materials Sent: "-'~o~o\:c, No~c~, Special Instructions:"" CITY of BAKERSFIELD "WE CARE" FIRE DEPARTMENT S. D. JOHNSON FIRE CHIEF September 11, 1992 2101H STREET BAKERSFIELD, 93301 326-3911 The Bakersfield Californian Legal Notice Division P.O. Bin 440 Bakersfield, CA 93302 Dear Sir: Please publish the following public notice one time only. A Risk Management and Prevention Program (RMPP) has been prepared by Pestritto Foods, Inc. located at 6800 McDivitt Dr., Bakersfield, CA. The RMPP describes programs and controls designed to prevent a hazardous material accident. This RMPP will be available fOr public review for the next 45 days at the Bakersfield Fire Department, Hazardous Materials Division 2130 G St. Bakersfield,. CA 93301. Contact Barbara Brenner for information regarding this RMPP. The bill for this service should be sent to the City of Bakersfield Fire Department, Hazardous Materials Division 2130 G St., Bakersfield, CA 93301. Please send me proof of publication of this notice. If you need any further information regarding this legal notice, please Call me at 326-3979. Sincerely, Barbara Brenner Hazardous Materials Planning Technician cc: Ralph Huey FIRE DEPARTMENT S.D. JOHNSON FIRE CHIEF CITY of BAKERSFIELD "WE CARE" September 11, 1992 2101 H STREET BAKERSFIELD, 93301 326-3911 'Karl Luft · Luft Environmental Consulting, Inc. 3701 Pegasus Dr., Suite 121 Bakersfield, CA 93308 Karl: A Risk Management and Prevention Program (RMPP) has been submitted by Pestritto Foods, Inc. located at 6800 McDivitt Dr., Bakersfield, CA. The RMPP describes programs and controls designed to prevent a hazardous material accident. This RMPP will'be available for public review for the next 45 days at the Bakersfield Fire Department, Hazardous Materials Division 2130 G St. Bakersfield, CA 93301. If you need any further information regarding this legal notice, please call me at 326-3979. Sincerely, Barbara Brenner Hazardous Materials Planning Technician cc: Ralph Huey CITY of BAKERSFIELD CAR r'' FIRE DEPARTMENT S. D. JOHNSON FIRE CHIEF September 11, 1992 2101H STREET BAKERSFIELD, 93301 326-3911 Al Sautner Plant Manager Pestritto Foods Inc. 6800 McDivitt Dr. Bakersfield, CA '93313 Al: Bakersfield Fire finds the modifications to the risk management and prevention plan (RMPP) prepared by Luff Environmental Consulting regarding the use of anhydrous ammonia at the Pestritto plant, 6800 McDivitt Dr., to be complete in scope and content. Bakersfield Fire Department will conduct follow up inspections to verify compliance with the risk management measures described in this plan. · Notice of completion of this RMPP will be published in the Bakersfield Californian. Pestritto's RMPP will then be subject to a 45 day review period during which Bakersfield Fire will consider all public comments regarding the adequacy of this RMPP. Please call me if I can provide any further assistance or clarification regarding the risk management plan or code compliance requirements.. Sincerely, Barbara Brenner Hazardous Materials Planning Technician CC; Ralph Huey Karl Luff LUFT ENVIRONMENTAL CONSULTING 3701 Pegasus D~'ive, Suite 121 · Bakersfield, California 93308 · (805) 399-5838 August 7, 1992 Barbara Brenner Hazardous Materials Planning Technician Bakersfield City Fire Department 2101 "H" Street Bakersfield, CA 93301 Ms. Brenner: RECEIVED 4UG 1 3 1992 HAZ. MAT. DIV. Your June 24, 1992 letter regarding Pestritto Foods Inc.'s Risk Management and Prevention prOgram (RMPP) indicated that the proposed revisions to the RMPP and the responses to your questions were adequate, with the exception of response numbers 11 and 13. As such, we have provided the revised pages (without the underline format) for the RMPP. Comments regarding response numbers 11 and 13 are also enclosed. If you have any questions concerning the enclosed, please contact me or Todd Rook at your convenience. Karl W. Luft Principal Mechanical Engineer cc: Larry Wuethdch - Pestritto Foods, Inc. w/enclosures Al Sautner - Pestritto Foods Inc. - Bakersfield w/enclosures LEC-92-0227 PF-02 RESPONSES TO THE BAKERSFIELD CITY FIRE DEPARTMENT'S LETTER DATED JUNE 24, 1992 1. BCFD Comment '~rhe other responses .and the revisions are adequate with the exception of numbers 11 and 13. The statement on page XII-6 of the RMPP that 'the facility is surrounded on all sides by light industrial buildings' is inaccurate." Response'~ ,.~o,~,,'~ '-'~ ~,..~ ~-c~ ~,~ e~ ,p~, ~ The statement on page XlI-6 of the RMPP actually reads '~'he PFI facility is located on McDivitt Drive in a commercial/light industrial area." This is an accurate statement and is the same language that was incorporated in the previously approved RMPP for Pestritto Foods Inc. BCFD Comment "Bakersfield Fire does not require risk management plans to be prepared by registered engineers. Your registration as a professional mechanical engineer is included on the literature and statements of qualifications submitted to us for preparation of RMPPs by Luft Environmental. We require the registration number and stamp to accompany your signature on the RMPP certification because you have included this professional registration as part of your qualifications." Response: Since the Bakersfield City Fire Department (BCFD) does not require RMPPs to be prepared by registered engineers, professional engineering registration should not be required on this RMPP. BCFD has not required professional engineering registration on previously approved RMPPs prepared by Luff Environmental Consulting. The responsibilities for the design ~f the original facility and the recent expansion were taken by Tri-Com Refrigeration', Inc. and Preston Refrigeration Company, respectively. The certified plans and specifications for the refrigeration system were submitted to the Bakersfield City Building Department and the Bakersfield City Fire Department for verification of compliance with the appropriate engineer and regulatory Pestritto Foods/RMPP/August 1992 Page 2 Luff Environmental Consulting codes. As such, additional certification on the refrigeration facilities is not necessary. Also, the hazard and operability study conducted for the purposes of the RMPP was not intended to be a formal engineering design review of the refrigeration system. Professional engineering certification of the RMPP could be misinterpreted as certification that the refrigeration system meets the design intent as far as system performance and/or that all engineering calculations were verified in the RMPP preparation process. Luft Environmental Consulting does not wish to misrepresent its role in this project from a professional engineering perspective. Pestritto Foods/RMPP/August 1992 Page 3 Luff Environmental Consulting of Bakersfie d Fire Department 2101 "H" Street Bakersfield, CA 93301 Fax Phone No. (805) 395-1349 Office (805) 326-3941 Date: PLEASE ROUTE AS SOON AS POSSIBLE TO: Name: ~-~ ~ ~-c~ ~C Company/Organization: j_o~/;~ ~o~,co~c~e ~-x~.~) Fax No. se~n~ting Message to: ~'~fi 4.-5 (c~,~/ FROM: Name: ~kr~5~'~ ,,~r-< Contact Person:'~" ~hf~c-~ Number of Pages (including cover sheet]: Description of Materials Sent: ~-~ Special Instructions:"" direction from the north,northwest at 6.4 miles per hour. A chemical release - during these average atmospheric conditions represents an offsite consequence 'that would pote'ntiatl~7 'have'the greateSt' affect on sensitive populations. For modeling purposes, however, winds from the south-southeast at 5.0 miles per hour were also considered because they represent the worst case or "pessimistic" atmoSPheric conditions. The PFI.facility is located on McDivitt Drive in a commercial?light industrial area. ,~;~, ~ Pursuant to Section. 25534, Califorma' Health and safety Code, "[e]very RMPP... shall give consideration to the proximity of the facility to schools, 'residential areas', general, acute care hospitals, long-term health care facilities, and child day care facilities." Sensitive population sites considered in this offsite consequence analysis included residences, schools, emergency and health care facilities. Figure 3 shows an oven/iew of the sensitive population sites near the PFI plant. ~?-The distances between the PFI facility and the sensitive populations are summarized in Table 2. The nearest resident is approximately a .quarter of a mile north of the PFI facility. 'There is a hospital to the northeast of the PFI facility, over a mile away. The nearest school is roughly 1.24 miles to the west of the plant. A Bakersfield City Fire Department station is located 1.31 miles northwest of the PFI facility. Most of'the ALOHA limitations discussed previously-have minimal effects on the model results.' The ALOHA limitatiOn regarding terrain steering effects and wind shifts caused by topography is not a problem in the area being modeled because the terrain is generally flat and unobstructed by large hills or valleys. The ground roughness' of the area is determined to be urban terrain, as the facility is s,..~urrounded on...a, ii 'sides b~/light industrial buildings. The effects of concentration ~atChiness within the first 50 to 100 yards from the'source will be minimal because there are no resident populations within this pre-Gaussian area. D. RESULTS OF THE ALOHA DISPERSION MODELING The Haz0P study generated release events for the ammonia system based the design of the facility, potential operator error and external events, such as an earthquake. These release events were reviewed to determine whether there was a high likelihood of occurrence or a significant offs[te consequence if the release were to occur. The releases associated with a high likelihood of occurrence were very Iow release rates and originated within the engine room which is equipped with the emergency ventilation system. There would be little or Pest'dtto Foods, Inc. RMPP March, 1992 Page Xll-6 Luft Environmental Consulting LUFT ENVIRONMENTAL CONSULTING 3701 Pegasus Drive, .Suite 121 · BakerSfield, California 93308 · (805)399-5838 August 14, 1992 Bakersfield City Fire Department 2101 H Street Bakersfield, CA 93301 Attn: Barbara Brenner RECEIVED AUG 1 7 199~:~ HAz, ~A.T, DIV. Enclosed Please find Section XII of the RMPP submitted for Pestritto Foods, Inc. The enclosed pages, completely replace all previous submissions. Section XII(C) has been changed per your phone conversation with Todd Rook of our staff this morning. ShOuld .you haVe any questions regarding the enclosed material, please call Todd Rook, or meat (805) 399-5838. Karl W. Luff Principal Mechanical Engineer cc: Larry Wuethdch, Pestritto Foods, Inc with enclosures Al Sautner, Pestritto Foods, Inc with enclosures Enclosures PF-02 LEC-92-0233 FIRE DEPARTMENT S. D. JOHNSON FIRE CHIEF CITY of BAKERSFIELD "WE CARE" AuguSt12,1992 2101 H STREET BAKERSFIELD, 93301 326-3911 Karl Luff Luff Environmental Consulting, Inc. 3701 Pegasus Dr., Suite 121 Bakersfield, CA 93308 Karl: Ir4 reviewing, our file-for Pestritto Foods, I noticed that I did not state a due date for submittal of the final revisions to 'the RMPP modification for. the?eXpanded refrigeration system. The CA Health and Safety Code allows 60 days for the correction of deficiencies in RMPPs. Therefore, the two revisions noted in my letter dated 6-24-92 will be due by 8-24-92. I look forward to the'completion of Pestritto's RMPP. of any assistance. Please call me if I' can be Sincerely, Barbara Brenner Hazardous Materials Planning Technician cc: Ralph Hueyl FIRE DEPARTMENT S. D. JOHNSON FIRE CHIEF CITY-of BAKERSFIELD "WE CARE" June 24, 1992 2101H STREET BAKERSFIELD, 93301 326-3911 Karl Luff Luff Environmental Consulting 3701 Pegasus Dr., Suite 121 Bakersfield, CA 93308 Karl: We have completed review of the responses to our questions and the revisions to Pestritto Food's RMPP submitted on 6-2-92. Al Sautner has verified that the ladder to the top of the new ~piral freezer has been installed. Because,this equipment has already been installed, we will'not require it to be included in the RMPP implementation schedule. Al also indicates that the wiring of the ammonia detector into the fire alarm system was performed by the alarm company. That is why this connection did not appear on the electrical diagrams for' the system installation. We will add this information to Pestritto's hazardous materials business plan instead of, requiring mention of remote monitoring in the RMPP. The other responses and the revisions are adequate with the exception of numbers 11 and 13. The statement on page XlI-6 of the RMPP that "the facility-is surrounded on all sides by light industrial buildingS" is inaccurate. The Pestritto plant has no immediately adjacent neighbors directly to the north. An ammonia plume moving t° the north would not encounter urban roughness until it reached the housing tract. Therefore, ammonia concentrations may be higher at these residences than predicted using the urban' roughness parameter. Bakersfield Fire does not require risk management plans to be Prepared by registered engineers, Your registration as a professional mechanical engineer is included on the literature and statements of qualification submitted to us for preparation of RMPPs by Luff Environmental. We require the registration number and stamp to accompany your signature on the RMPP certification because you have included this professional registration as a part of your qualifications. Once we have received the correction to page Xll-6 and the revised certification page, Bakersfield Fire will find the Pestritto Foods RMPP complete. Sincerely, Barbara Brenner , Hazardous Materials Planning Technician cc: Ralph Huey MEMORANDUM "WE CARE" June 17, 1992 TO: FROM: SUBJECT: Ralph Huey, Hazardous Materials Coordinator Barbara Brenner, Planning Technician Pestritto RMPP Modifications, Findings The consulting firm refuses to include information in the RMPP regarding manual switches in the engine room to control roof top valves, visual monitoring equipment and the ladder to access the roof of the new spiral freezer. Pestritto staff report that the ladder has been installed. The other items have been verified during inspections by this department. Because these items do not need to be included on the RMPP implementation schedule,' inclusion in the RMPP would primarily serve to document the owner's additional commitment to safe operations. The consulting firm still has not verified the interconnection of the fire alarm system and the' ammonia detection system. They continue to maintain that the ammonia detection system is not monitored 24 hours/day.. Facility staff indicate that they hired the alarm company to wire the ammonia detector into the remote monitoring system. Remote' monitoring capability increases the emergency response capability of Pestritto Foods. Remote monitoring of the ammonia detection sYstem is another example of the owner's commitment to safety which has been left out of this RMPP. Failure to include the items outlined above in the RMPP is detrimental to possible public perception of Pestritto's commitment to safety. This Administering Agency has this information and can add it to the facility's hazardous materials business plan. The Administering Agency is satisfied that the ammonia refrigeration system is safe and well controlled. 'Therefore, the intent of the legislature regarding the purpose of risk management planning has been met. It would be a waste of the handler's resources to continue to argue semantics with a consulting firm in order to have these items specifically covered in the RMPP. o "['he provision of air dispersion modeling b.t 100 and 200 ppm .meets the requirement to provide exposure concentrations within the LOC dispersion plume. The consulting firm continues to avoid discussion of the concentration Within the IDLH plume. The data provided predict that ammonia.concentrations 50 yards~ downwind of the release will be about 10,000 ppm. This gives one inter plume concentration for the IDLH plume. Because exact points were not specified by ~this Administering Agency for the inter plume concentrations, this data is acceptable. The~ statement on page XlI-6 of the RMPP that the facility is surrounded on all sides by light industrial buildings is inaccurate. There are no buildings between the housing tract and the Pestritto plant on the north side. Correction will be required. The facility owner will be notified that documents marked "confidential" Pertaining to this RMPP will not be protected as trade secret. Written., documentation` of "~ trade secret status must be submitted to this agen, cy in order to Protect specific, trade secrets. Other questions posed by this Administering Agency in regard to the Pestritto RMPP and supporting analyses have been adequately addressed.' LUFT ENVIRONMENTAL CONSULTING 3701 Pegasus Drive, Suite 121 · Bakersfield, California 9330'8 n'Jue (805) 399-5838 2, 1992 Barbara Brenner Hazardous Materials Planning Technician Bakersfield City Fire Department 2101 "H" Street Bakersfield, CA 93301 Ms. Brenner: 1997 Enclosed for your review are the responses to your March 31, 1992 letter regarding Pestritto Foods Inc.'s Risk Management and Prevention Program (RMPP) and the proposed changes to the RMPP. For convenience, we have provided the proposed changes to the RMPP in an underlined format to help you identify the changes. We have also provided a non-underlined version that can be inserted into the RMPP, if these changes are acceptable to you. Please note that we have revised the description of the air model and deleted the vapor puff discussion. This description more accurately reflects the current ALOHATM air dispersion model, If you have any questions concerning the enclosed, please contact me or Todd Rook at your convenience. Principal Mechanical Engineer Larry Wuethrich - Pestritto Foods, Inc. w/enclosures Al Sautner - Pestritto Foods Inc. - Bakersfield w/enclosures LEC-92-0152 PF-02 RESPONSES TO THE BAKERSFIELD CITY FIRE DEP LETTER DATED MARCH 31, 1992 RTMENT'S JUN 2 1992 Several items of safety equipment and system control devices have not been included in the RMPP. Gages have been added in the engine room to allow easy visual monitoring of system pressures without traveling out to view the gages in the diffusion system control box. Manual contrOl switches have been installed to operate roof top isolation valves from the engine room. A ladder will be installed on the roof to facilitate access to the top of the new spiral freezer. Response: a.0~'Gages are not considered safety or control devices as they are passive indicators only. As stated on page VI-3, the ammonia system is visually monitored on a daily basis. Visual monitoring includes reading gages attached to the refrigeration system. b.?.~ The above described control switches, which were installed after the RMPP was submitted, were not installed for safety purposes or as a mitigation measure in the event of a release. These switches were installed to allow manual operation of the refrigeration system if the .._programmable logic controller (PLC) fails. Installation of this control panel would allow a qualified operator to run the refrigeration and defrost cycles manually by opening and closing selected solenoid valves. It should be noted that the original HazOp study did include the inadvertent operation of these solenoid valves in the hazard analysis. All solenoid valves in the Pestritto refrigeration system are normally closed valves. ~.~!~n nf-the system__in...the event of a leak was ..~inco.rpor_a_t_ed in the origina_l_des___[gn__u_p_q_o_a~ivation__of the emergen___cy ventilat_ion s_ystem by the PLC. Additionally, manual operation 'of Pestritto Foods/RMPP/May 1992 Page 1 of 7 Luft Environmental Consulting switch "Sl" in the ememencv-r.e/riaeration control box-will-atso-de- ~ener.(:lize all_sol~v~l~/esLand._pro'-~~v System isolation. The isolation capabilities of the system have not changed since the original design. Co A ladder installed on the roof to facilitate access to the top of the new spiral freezer is not a refrigeration system safety or contrOl device. The addition of the ladder does not alter the potential for an' accident involving hazardous materials to occur, 'nor does the ladder control any of the refrigeration system operating parameters. However, the addition of the ladder will facilitate safer access to the roof of the spiral freezer. 2. Comment: The capability of several safety devices haVe not been detailed fully. ae It is my understanding that the ammonia sensor and fire protection system are monitored remotely on a 24 hour/day basis. The monitoring company contacts plant staff and public emergency responders if an alarm is activated. be A back check valve on the controlled pressure receiver line is mentioned in the s~_m~mary of the hazard analysis. This back check valve is not mentioned in the RMPP as a safety device. Response: . , ~ U~a~ a~.~'The fire protection system is monitored remotely on a 24 hour/day ~:) basis. The ammonia monitoring system is not monitored remotely. "~ ~O~.f O Since the plant is operated 24 hours per day, plant personnel are ( ,~~~ likely to initiate emergency response procedures prior to a~ivation of the local ammonia alarm. Plant personnel can dete~ ammonia in .~ ~ concentrations of between 5 and 25 ppm, which is much lower than the 200 ppm ammonia sensor setting. Additionally, it is likely that plant pemonnel will dete~ smoke long before the fusible links in the sprinkler system melt to initiate water flow and the fire alarm. Although the back check valve on the controlled pressure receiver line is mentioned on page XI-5 of the hazard analysis summary as a safety dev. ice, Section' V has been modified to incorporate a Pestritto Foods/RMPP/May 1992 Page 2 of 7 Luff Environmental Consulting discussion on the back check valve. 3. Comment;: e I find no coverage of the management of change as outlined in your s~_~mmary dated 3-2-92. Response: Although Management of Change was implicitly incorporated in Section VIII, this section has been changed to specifically discuss Management of Change at the Pestritto facility. Procedures for handling the management of change have been in place since the plant began operation. The recent refrigeration system upgrade with the associated drawings, operating procedures, training procedures, and RMPP updates, demonstrates that the management of change program at the Pestritto plant works very well. Additionally, a record of change was added to the front of the RMPP supporting document. Comment: The age of the equipment is not included in the description of the equipment. ~ Response: The text on page. IV-1 of the RMPP supporting document states that the plant "began operation in July, 1991". A list of the new equipment added during the refrigeration system upgrade occurs on the same page. The RMPP states that .the new equipment is being added currently, i.e. as of the date of the RMPP revision. The EPA definition of LOC does not include any judgements regarding levels of discomfort to receptors. (pg. XII-6) The definition of IDLH must include a description of the population it applies to - healthy adults. Response: Upon review of the EPA Te(;hnical Guidance for Hazard Analysis. the Pestritto Foods/RMPP/May 1992 Page 3 of 7 Luft EnvirOnmental Consulting language in the Pestritto Foods offsite consequence analysis has been changed to accurately .reflect the language used by the EPA. References to the level of discomfort have been removed. 6. Comment: Table 2 places the nearest residence .24 miles from the Pestritto plant. The offsite consequence analysis conclusions on page XII-8 state that the 50 pPm plume travels about 650 yards and does not impact any sensitive receptors. These two pieces of information are contradictory as .24 miles = 422 yards. It appears that sensitive receptors would be impacted by the 50 ppm pi-me. Response: Review of the maps presented in the .Pestritto Foods offsite consequence analysis revealed that one sensitive receptor site did not appear on any of the maps. The language of the analysis and the maps have been changed to accurately reflect the location of this sensitive receptor. 7. Comment: The maps which show the impact on sensitive populations due to emmonia release at Pestritto do not accurately reflect the location of the nearest residences. There are apartments directly north of the plant. The maps shoTM housing to the north east and north west but do not indicate the nearest sensitive receptors. Response: Please refer to the response given in item 6 above. Comment: ' The modeling included in the offsite consequence analysis does not include the possibility of a 3" line release at night. This item was specifically mentioned in my letter dated 3-5-92. Response: The modeling in'the offsite consequence analysis includes the possibility of a 3" line failure under adverse weather conditions. Models of a 3" line Pestritto Foods/RMPP/May 1992 Page 4 of 7 Luft Environmental Consulting failure occurring under the worst possible weather conditions were supplied to the Bakersfield City Fire Department at their request. The submission was included in a package of model runs conducted for a variety of modeling conditions to support emergency planning by the Fire Department as agreed. ~ _ , _. Th_.?.e air dispersion rh'odel__j~_r~o_Lsjgni.f~'c~.atly_s.e~si~ti~e t_~o the time of day_~a release occurs. Typically, the time of day does not effect the computed maximum threat zones. However, the model may show a very slight variation in the rate of evaporation from a pooled source release. Parameters such as cloud cover and ground temperature have the greatest impact for creating a nighttime or daytime release scenario. High cloud cover and Iow ground temperature are similar to nighttime conditions. Bright sunshine and elevated ground temperature are indicative of daytime conditions. Comment: ~)~/The offsite analysis makes no mention of the levels of consequence exposure expected in each zone, within each of the ph~mes, as required by Section 25534(d)(2). Response: The exposure concentrations required by the BCFD (50 and 500 ppm) and plume travel distances are stated on page XlI-8 of the RMPP supporting document. Tables 3, 4, and 5 indicate plume concentrations and distances ~,~,.~for all model runs included in the RMPP. Plume concentrations are clearly ~'[0~,~' indicated in the title blocks of Figures 4 and 5. As requested by the BCFD, circles on the maps clearly indicate BCFD's interpretation of the zones of vulnerability. The extent of the plume concentrations are identified in the title block of the respective Figure. For simplicity, the text in the RMPP has been modified to further clarify the offsite impact to the populations identified in Section _25534.1. 10. Comment: The offsite consequence analysis does not state the duration of the continuous smmonia hose release or the duration of the evaporation of the pool created by the controlled pressure receiver release. Duration of these releases must be stated and considered when determining Pestritto Foods/RMPP/May 1992 Page 5 of 7 Luff Environmental Consulting possible consequences to receptors. Response: Upon review of the offsite consequence analysis, the language in the Pestritto Foods off$ite consequence analysis has been modified to include the expected duration of the modeled releases. Comment: ~/°X'The use and effect of the urban terrain parameter needs to be discussed in the model parameter section. While most of the terrain around Pestritto is urban, ammonia plumes travehng' toward the north will not encounter urban terrain until they contact the housing C~.~o~ract. It will not be necessary to include models and maps for the rural c-haracteristics of the northerly dispersion. Howe~sion~of the urban terrain parameter and possible' d~-~ations in the predicted ~spersion distances i'~clu~ded. . ~ Response: The urban and rural terrain Parameters are discussed on page XII-4. Text on page XIl-~states that the urban terrain parameter was chosen and why it was chosen. 12. Comment= Document the reasons why the release of the remainder of the ammonia in the system would evacuate so slowly (over several days or weeks) following the initial release. ReSponse: Refrigeration systems are insulated to retard heat transfer to the refrigerant. A drop in system pressure in the event of a catastrophic release like the 3" line failure would cause the refrigerant to cool to the atmospheric boiling point (-28.17 °F). Since heat is required to increase the boiling rate of the ammonia and the system is insulated to retard heat gain, the ammonia will boil very slowly. The initial discharge of ammonia from the hypothetical 3" line break is high due to the pressure inside the controlled pressure receiver. A majority of Pestritto Foods/RMPP/May 1992 Page 6 of 7 Luft Environmental Consulting the remaining ammonia will be inside the freezer coils where heat gain is the slowest since there is an insulated, large cold thermal mass to keep the ammonia cold. Also, as the ammonia boils, its temperature remains at its boiling point of -28.17° F (at atmospheric pressure). Because Luft Environmental's qualifications as an RMPP preparer include your registration as a Professional Mechanical Engineer, the State Registration. Board informs me that it is appropriate for the certification page to include your registration number. Response: If the BCFD is now requiring that RMPP be prepared by registered engineers,~_w~ will in~.hJdo_th~ r~ni.~tr~tinn_numb~r nrr_th~ ~-ertification page. f' ' Pestritto Foods/RMPP/May 1992 Page 7 of 7 Luft Environmental Consulting SITE DATA INFORMATION: Location: BAKERSFIELD, CALIFORNIA Building Air Exchanges Per Hour: 0.64 (Unsheltered single storied) Date & Time: Fixed at December 15, 1991 & 0800 hours CHEMICAL INFORMATION: Chemical Name: AMMONIA, ANHYDROUS Molecular Weight: 17.03 kg/kmol TLV-TWA: 25:.00 ppm IDLH: 500.00 ppm Footprint Level of Concern: 100 ppm ', Boiling Point:-28.17° Fahrenheit Vapor Pressure' at Ambient Temperature: greater than 1 arm Ambient Saturation Concentration: 1,000,000 ppm or 100..0% ATMOSPHERIC INFORMATION:(MANUAL INPUT OF DATA) Wind: 5 mph from SSE No Inversion Height Stability Class: C Air Temperature: 40° Fahrenheit Relative Humidity: 50% Ground Roughness: Urban or forest Cloud Cover: 7 tenths SOURCE STRENGTH INFORMATION: Direct Source: 325 pounds Source Height: 0 Release Duration: 1 minute Release Rate: 5.42 pounds/sec Total Amount Released: 325 pounds Note: This chemical may flash boil and/or result in two phase flow. Use both dispersion modules to investigate its potential behavior. FOOTPRINT IN FORMATION: Dispersion Module: Gaussian User specified LOC: 100 ppm Max Threat Zone for LOC: 496 yards Max Threat Zone for IDLH: 227 yards For more detailed information, check the Time Dependent Conc/Dose information at specific locations SITE DATA INFORMATION: Location: BAKERSFIELD, CALIFORNIA Building Air Exchanges Per Hour: 0.64 (Unsheltered single storied) Date & Time: Fixed at-December 15, 1991 & 0800 hours CHEMICAL INFORMATION: Chemical Name: AMMONIA,' ANHYDROUS Molecular Weight: 17.03 kg/kmol TLV-TWA: 25.00 ppm IDLH: 500.00 ppm Footprint Level of Concern: 200 ppm Boiling Point:-28.17° Fahrenheit Vapor Pressure at Ambient Temperature: greater than 1 atm Ambient Saturation Concentration: 1,000,000 ppm or 100.0% ATMOSPHERIC INFORMATION:(MANUAL INPUT OF DATA) Wind: 5 mph from SSE No Inversion Height Stability Class: C Air Temperature: 40° Fahrenheit Relative Humidity: 50% Ground Roughness: Urban or forest Cloud Cover: 7 tenths SOURCE STRENGTH INFORMATION: Direct Source: 325 pounds Source Height: 0 Release Duration: 1 minute Release Rate: 5.42 pounds/sec Total Amount Released: 325 pounds Note: This chemical may flash boil and/or result in two phase flow. Use both dispersion modules to investigate its potential behavior. FOOTPRINT INFORMATION: Dispersion Module: Gaussian User specified LOC: 200 ppm Mnx Thrent Zone for LOC: 359 yards Max Threat Zone for IDLH: 227 yards For more detailed information, check the Time Dependent Conc/Dose information at specific locations SITE DATA INFORMATION: Location: BAKERSFIELD, CALIFORNIA Building Air Exchanges Per Hour: 0.64 (Unsheltered single storied) Date & Time: Fixed at December 15, 1991 & 0800 hours CHEMICAL INFORMATION: Chemical Name: AMMONIA, ANHYDROUS Molecular Weight: 17.03 kg/kmol TLV-TWA: 25.00 ppm IDLH: 500.00 ppm Footprint Level of Concern: 100 ppm Boiling Point:-28.17° Fahrenheit Vapor Pressure at Ambient Temperature: greater than 1 atm Ambient Saturation Concentration: 1,000,000 ppm or 100.0% ATMOSPHERIC INFORMATION:(MANUAL INPUT OF DATA) Wind: 5 mph from SSE No Inversion Height Stability Class: C Air Temperature: 40° Fahrenheit Relative Humidity: 50% Ground Roughness: Urban or forest Cloud Cover: 7 tenths SOURCE STRENGTH INFORMATION: Puddle Area: 1000 square feet Puddle Mass: 3689 pounds Soil Type: Default Ground Temperature: 40° Fahrenheit Initial Puddle Temperature: Ground temperature Release Duration: 30 minutes Max Computed Release Rate: 198 pounds/min Max Average Sustained Release Rate: 127 pounds/min (averaged over a' minute or more) Total Amount Released: 3,690 pounds FOOTPRINT INFORMATION: Dispersion Module: Gaussian User specified LOC: 100 ppm Max Threat Zone for LOC: 316 yards Max Threat Zone for IDLH: 139 yards For more detailed information, check the Time Dependent Conc/Dose information at specific locations SITE DATA INFORMATION: Location: BAKERSFIELD, CALIFORNIA Building Air Exchanges Per Hour: 0.64 (Unsheltered single storied) Date & Time: Fixed at December 15, 1991 & 0800 hours CHEMICAL INFORMATION: Chemical Name: AMMONIA, ANHYDROUS Molecular Weight: 17.03 kg/kmol TLV-TWA: 25.00 ppm IDLH: 500.00 ppm Footprint Level of Concern: 200 ppm Boiling Point: -28.17° Fahrenheit Vapor Pressure at Ambient Temperature: greater than 1 arm Ambient Saturation Concentration: 1,000,000 ppm or 100.0% ATMOSPHERIC INFORMATION:(MANUAL INPUT OF DATA) Wind: 5 mph from SSE No Inversion Height Stability Class: C Air Temperature: 40° Fahrenheit' Relative Humidity: 50% Ground Roughness: Urban or forest Cloud Cover: 7 tenths SOURCE STRENGTH INFORMATION: Puddle Area: 1000 square feet Puddle Mass: 3689 pounds Soil Type: Default . Ground Temperature: 40° Fahrenheit Initial Puddle Temperature: Ground temperature Release Duration: 30 minutes Max Computed Release Rate: 198 pounds/min Max Average SuStained Release Rate: 127 pounds/min (averaged over a minute or more) Total Amount Released: 3,690 pounds FOOTPRINT INFORMATION: Dispersion Module: Gaussian User specified LOC: 200 ppm Max Threat Zone for LOC: 222 yards Max Threat Zone for IDLH: 139 yards For more detailed information, check the Time Dependent Conc/Dose information at specific locations CJ SAFETY EQUIPMENT. 1. Pressure Relief Valves All of the compressors and each pressure vessel are equipped with pressure relief valves. Within the facility there are three pressure relief settings, two high pressure settings and a Iow pressure setting. The high pressure systems have spring loaded pressure relief valves set at 250 and 300 psig. The Iow pressure system has spring loaded pressure relief valves set at 150 psig. All pressure relief valves discharge into a dedicated pressure relief header. This header directs the ammonia flow into a scrubber tank where the ammonia vapors released from the pressure relief valves will be absorbed in the water. An ammonia sensor is located in the pressure relief header to monitor for the presence of ammonia. This sensor will alarm if there is 200 ppm of ammonia in the line and notify the operators that a pressure relief valve has operated (or is leaking). , 2. Ammonia Emergency Control Box An ammonia emergency control ~box is located northeast of the engine room: The thermosyphon receiver, Iow suction accumulator, intercooler; and the controlled pressure receiver all have pressure lines which are.connected to the control box. Inside the contrOl box, valves connect each of these pressure lines to each other. In the event of an overpressure situation in one of the systems, these valves can be operated to relieve the pressure from the ' overpressured system and distribute it to one or more of the other systems. This balancing of the pressures can be done without releasing ammonia to the atmosphere. Under an extreme overpressure situation, such as a major fire, there is also an emergency dump valve that will discharge the ammonia vapors to the scrubber tank. The pressure relief valves will also discharge ammonia into the scrubber tank automatically if the. system pressure reaches the relief valve set points. ' 3, Back Check Vplve A check valve is installed durin0 ammonia deliveries on the line used for filling the controlled .oressure receiver. The installation of this valve prevents Pestdtto Foods, Inc. RMPP June, 1991 Page V-4 Luft Environmental Consulting the reverse flow of ammonia ¢out of the controlled .or~ssure receiver~ in the event of a delivery_ hose failure. 4. Respiratory Protection Personnel responsible for emergency response will be trained in the use of self contained breathing apparatuses (SCBA). At least two SCBAs will be on site for response to emergency situations. D. FIRE PROTECTION SYSTEM Portable fire extinguishers are available throughout the plant. PFI management personnel are trained in the use of hand held fire extinguishers. The inside of the facility is also blanketed by a sprinkler system which meets or exceeds the requirements imposed by the Bakersfield City Fire Department. E. EMERGENCY SHUTDOWN SYSTEMS The emergency shutdown switch for the compressors is located outside the building, and is labelled "S1 ." This manually operated remote switch shuts down all power to the compressors. All pressure relief valves vent to a header which discharges .to a water tank located northeast of the engine room. When the pressure relief valves release ammonia into the header, the ammonia breaks through a foil rupture diaphragm and flows into the water tank where it will be absorbed. An ammonia sensor is located inside the header to detect releases from the pressure relief valves. This sensor is connected to a control panel where both audio and visual alarms will be set off. An ambient ammonia sensor monitors the inside of the building. If the concentration of ammonia reaches 200 ppm, an alarm will sound and an emergency fan will be automatically started to direct air out of the engine room and into an evaporative condenser where the ammonia will be absorbed in the water. A control switch for manual operation of this fan is located on the outside of the building adjacent to the compressor emergency kill switch and is labelled "S2." There is also a control switch for manual' operation 'of the scrubber pump located adjacent to the compressor emergency kill switch, which is labelled "S3." Pestritto Foods, Inc. RMPP June, 1991 Page V-5 Luft Environmental Consulting contrOl box. The emergency ventilation system consists of a high flow rate fan (19,150 cubic feet per minute) that discharges into the evaporative condenser. Once the system is activated (either automatically or manually), the fan pulls air out of the engine room and blows it into the evaporative condenser which circulates 1000 gallons per minute of water. At the same time, the evaporative condenser drain line is directed away from the sewer and into the ammonia scrubber tank located outside. The water in the evaporative condenser absorbs the ammonia vapor and is returned to the scrubber tank. A water pump on the tank is also started at this time to circulate water from the scrubber tank to the evaporative condenser. This water pump may also be started manually with switch S3 located next to S1 and S2 inside the emergency refrigeration control box. B. MANUAL MONITORING The ammonia system will be monitored on a routine basis. Plant operations personnel will physically inspect the system on a daily basis during the operation of the plant to verify the proper function and operation of equipment. Additionally. since the facility is o0erated 24 hours .Der day and ammonia is detectable at a.o.Droximately 5 p.Dm. the facility will be monitored for ammonia leaks by olant personnel on a continuous basis. Records of the physical inspections will be kept for a minimum of five years. In addition to the routine daily inspections, the physical condition of the ammonia equipment will be monitored during scheduled plant shutdowns. When there is a scheduled shutdown of the plant, the ammonia system may also undergo inspection and maintenance during the plant shutdown., All. records of maintenance, both preventative and response, on the ammonia system will be recorded for future reference. These maintenance records will be kept for a minimum of five years. Pestdtto Foods, Inc. RMPP March, 1992 Page VI-3 Luft Environmental Consulting B. INVENTORY CONTROL AND RECORDKEEPING PROGRAMS HaZardous Materials Inventories Pursuant to Sections 25503.5, 25504,-and 25509 of the Health & Safety Code, PFI will conduct and maintain hazardous materials inventories. These inventories will be submitted to the Administering Agency and will be updated annually or sooner, if required. The inventories will also be maintained for five years. Maintenance Records Maintenance activities will be documented and the records will be submitted to the Plant Manager for retention. Maintenance activity records include the preventative maintenance records, equipment monitoring and repair records, testing records, and equipment calibration records. All maintenance records will be retained for five years. Operations Records Daily operations logs are maintained for the plant. These records are retained by the Plant Manager. These records will be maintained for five years. Safety 'and Training Records All employee training is documented and employee particiPation is recorded with attendance sheets. Similarly, the monthly safety meetings are documented. These records are submitted to the Plant Manager for review and retention. All safety or environmental incidents will be evaluated and an "Incident Report" will be prepared as necessary. Similarly, all incidents requiring first aid or which result in injury are recorded. These records are maintained by the Plant Manager for a period of five years. C. MANAGEMENT OF CHANGE PFI has initiated a management of change .orogram for the refrigeration system. If a change tother than like replacement) is .Dro0osed for the ammonia refrigeration system. PFI's management, o0eration~ .oersonnel. and maintenance p~rs0nnel Pestritto Foods, Inc. RMPP March, 1992 Page VIII-2 Luff Environmental Consulting will assess the impact of the proposed change on the refrigeration system. The proposed modification will be reviewed for potential hazards associated with the eouioment chan(]es, control schemes, and operations and maintenance procedure changes. Implementation of a change will also initiate a review training reouirements for the affected employees and modifications to operating procedures and maintenance procedures, if reo_uired. All significant chanoes to the refrigeration system will be documented. Pestritto Foods, Inc. RMPP March, 1992 Page VIII-3 Luft Environmental Consulting occur within the first 50 yards from the source. Under all. meteorological conditions, ALOHA predicted that the concentration of the plume would drop to less than 10,000 ppm within 100 yards for each release scenario. Since the nearest sensitive receptor is more than 100 yards from the facility, the Gaussian model was used to estimate the offsite consequences of a potential release. Also, ALOHA selected the Gaussian model instead of the Heavy Gas model for each release scenario. If anhydrous ammonia is released as a liquid, a portion of the liquid will flash to the vapor phase immediately. The amount of liquid ammonia that will flash to the vapor phase is dependent on the storage pressure prior to the release. For each release of liquid ammonia, the percentage of ammonia flashing to the vapor phase was calculated. The balance of the release would form a liquid pool that would evaporate over a period of time depending on ambient conditions. The air dispersion model calculates the evaporation release rate based on the input meteorological parameters. Therefore, a release of liquid anhydrous ammonia would generate two vapor dispersion models; one for the initial flash of the release and the'second for the evaporation of the liquid pool. Results were modeled for concentrations set at 50 ppm and 500 ppm as specified in the "Outline of RMPP Requirements", prepared by the Bakersfield City Fire Department Hazardous Materials Division. The 50 p.Dm value is one tenth of the Immediately Danaerous to Life and Health concentration An ambient concentration of ammonia of 500 ppm is considered as Immediately Dangerous to Life or Health (IDLH). At 500 ppm, there is.severe irritation of the eyes, nose and throat, but there are no lasting effects for a short exposure of less than 30 minutes. Since ammonia has a perceptible odor as Iow as 5 ppm, it is unlikely that a person would become unknowingly overexposed.4 The meteorological conditions used to determine maximum impact distances and times were based on data collected by the U.S. Weather Service at Meadow Fields Airport in Bakersfield, California. The data in Table 1 summarizes the meteorological data for both average and adverse conditions. On an annual basis, the predominant meteorological conditions are with a wind 4American Industrial Hygiene Association, October, 1988: Emergency Response Planning Guidelines. AIHA ERPG Committee, 475 Woff Ledges Parkway, Akron, OH 44311. Pestdtto Foods, Inc. RMPP March, 1992 Page Xll-5 Luff Environmental Consulting The releases associated with the delivery hose failure has the potential to occur on an infrequent basis. Ammonia will be delivered to the plant periodically to recharge the ammonia system. Only during ammonia delivery could the delivery hose failure release event develop. In order to generate a worst case release event; the hose failure was assumed to occur outside of the engine rOom. Results of the dispersion models for a 10 second and continuous release are show. n in Tables 3 and 4 respectively. The evaporation of the lio. uid pool created by the delivery_ hose failure release event would last approximately 6 .minutes after the release is stooped. For the 3 inch liquid line event, the 500 ppm plume travels slightly over two hundred yards under adverse weather conditions as shown in Table 5 and Figure 4. The 50 ppm plume for the same events is shown in Table 5 and Figure 5. As stated eadier, when anhydrous ~,mm0nia i~ released as a liquid, a portion of the lia. uid will flash to the vapor phase immediately. The balance of the release would form a Pool and begin to evaporate. The 50 Dpm plume associated with the vapor release travels iust over 650 yards (0.37 miles) and has the potential to reach the nearest residence 'which is approximately 0.24 miles north of the ,V~~,~u facility. Additional modeling indicates that the concentration level may be as high as 100 DDm (for a duration of approximately one minute) at the nearest residerlee ~{x.'-'~ ~,, due to the flashing vapor release, An exposure of 100 ppm is well below the ~,~.~."~-~ Emergency Response Planning Guidelines Level 2 (ERPG-2) concentration of ',~ 200 Dom e,t 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 actiorl"[ Since the initial flashing vapor release would last approximately 1 minute, there should be no significant adverse health effects associated with this release, The evaporation of the liquid pool. created by the 3 inch line'failure, would last approximately 30 minutes. The 50 ppm plume associated with the evaporation of this liouid DO01 travels approximately 450 vards and has the potential to reach the nearest residence, The nearest resident would not be sub!ected to a concentration of 100 ppm from the evaporation release, 5American Industrial Hygiene Association, April, 1988: Emergency Response Planning Guidelines. AIHA ERPG Committee, 475 Wolf Ledges Parkway, Akron, OH 44311. Pestdtto Foods, Inc. RMPP March, 1992 Page XII-8 Luft Environmental Oonsulting Additionally. it is not likely that the nearest resident would be exposed to the 50 .Dom plume for the entire time it takes for the lio. uid pool to evaporate. Since the local fire department response time is 10 minutes or less. a water spray could be applied to the vapor cloud to substantially reduce the offsite impact within approximately 10 minutes of the release. In summary, the modeling shows that the sensitive populations near the facility could be exposed to Iow concentrations of ammonia in a worst credible release event. However, there probably would n(;;)t be any significant adverse health effects to these sensitive populations due to the Iow ammonia concentrations in the plumes and relative short exposure times for the sensitive receptors, An external event, such as an earthquake, that would cause the 3 inch liquid line to fail might prevent Pestritto Foods, Inc. personnel and emergency response personnel from stopping a release from the refrigeration system. In the event of the worst case pipe failure, the liquid contents of the controlled pressure receiver would be expelled in less than one minute. Following this initial release, ammonia vapor would continue to vent from the system at a very slow rate until the broken section of pipe could be isolated as the liquid ammonia in the rest of the refrigeration system would continue to evaporate. A slow release of this type could last several days or weeks depending on the loCation and severity of the pipeline failure. However, a slow release would not impact populations surrounding the facility as a 500 ppm plume would not be expected to extend beyond the boundaries of the. facility. Also, a slow release could be readily repaired by personnel wearing personal protective equipment such as respirators. Pestdtto FoOds, Inc. RMPP March, 1992 Page xII-9 Luft Environmental Consulting C. SAFETY EQUIPMENT 1. Pressure Relief Valves I I I i I I All of the compressors and each pressure vessel are equipped with pressure relief valves. Within the facility there are three pressure relief settings, two high pressure settings and a Iow pressure setting. The high pressure systems have spring loaded pressure relief valves set at 250 and 300 psig. The Iow pressure system has spring loaded pressure relief valves set at 150 psig. All pressure relief valves discharge into a dedicated pressure relief header. This header directs the ammonia flow into a scrubber tank where the ammonia vapors released from the pressure relief valves will be absorbed in the water. An ammonia sensor is located in the pressure relief header to monitor for the presence of ammonia. This sensor will alarm if there is 200 ppm of ammonia in the line and notify the operators that a pressure relief valve has operated (or is leaking). i 2. Emergency Refrigeration Control Box An emergency refrigeration control box is located east of the scrubber tank, I adjacent to the parking lot. The thermosyphon receiver, Iow suction accumulator, intercooler, and the controlled pressure receiver all have pressure lines which are connected to the control box. Inside the control I box, valves connect each of these pressure lines to each other. In the event of an overpressure situation in one of the systems, these valves can be I operated to relieve the pressure from the overpressured system and distribute it to one or more of the other systems. This balancing of the pressures can be done without releasing ammonia to the atmosphere. I Under an extreme overpressure situation, such as a major fire, there is also an emergency dump valve that will discharge the ammonia vapors to the i scrubber tank. The pressure relief valves will also discharge ammonia into the scrubber tank automatically if the system pressure reaches the relief valve set points. ! ! 3. Respiratory Protection Personnel responsible for emergency response are periodically trained in I I Pestritto Foods, Inc. RMPP March, 1992 Page V-4 Luft Environmental Consulting I I I i I I I I I I I I I I I i I I the use of self contained breathing apparatuses (SCBA). SCBAs will be on site for response to emergency situations. D. FIRE PROTECTION SYSTEM At least two Portable fire extinguishers are available throughout the plant. PFI management personnel are trained in the use of hand held fire extinguishers. The inside of the facility is also blanketed by a sprinkler system which meets or exceeds the requirements imposed by the Bakersfield City Fire Department. E. EMERGENCY SHUTDOWN SYSTEMS The emergency shutdown switch for the compressors is located inside the emergency refrigeration control box, and is labelled "S1." This manually operated remote switch shuts down all power to the compressors. Ail Pressure relief valves vent to a header which discharges to a water tank located east of the machine room. When the pressure relief valves release ammonia into the header, the ammonia breaks through a foil rupture diaphragm and flows into the water tank where it will be absorbed. An ammonia sensor is located inside the header to detect releases from the pressure relief valves. This sensor is connected to a control panel where both audio and visual alarms will be set off. Two ambient ammonia sensors monitor the inside of the machine room. If the concentration of ammonia reaches 200 ppm, an alarm will sound and the emergency ventilation system will be automatically started to direct' air out of the engine room and into an evaporative condenser where the ammonia will be absorbed in the water. A control switch for manual operation of this fan is located inside the emergency refrigeration control box adjacent to the compressor emergency kill switch and is labelled "S2." There is also a control switch for manual operation of the scrubber pump located adjacent to the compressor emergency kill switch, which is labelled "S3." F. STANDARD OPERATING PROCEDURES An operating manual that covers the basic operation of the PFI ammonia refrigeration system was supplied by the refrigeration contractor. In addition to the basic operation of the system, the manual includes a description of' normal start up, emergency shut downs, and the control system alarm set points. Pestritto' Foods, Inc. RMPP March, 1992 Page V-5 Luft Environmental Consulting I I I ! G. PREVENTATIVE MAINTENANCE PROGRAM I I I I I I I I I I I ! I Scheduled and preventative maintenance will be performed on all equipment in accordance with the equipment manufacturer's recommendations, as described in the operations manual supplied by the refrigeration contractor. Additional maintenance will be performed on an as needed basis. i H. OTHER OPERATING AND MAINTENANCE PROGRAMS In addition to the standard operating and maintenance procedures, "tailboard briefings" or "job procedure discussions" will be conducted prior to commencing non-routine tasks. This procedure ensures that the operation and maintenance personnel understand the job specific potential hazards and how to react if a hazard develops. Pestritto Foods, Inc. RMPP March, 1992 Page V-6 Luft Environmental Consulting I I I I i I I I I I I I I I I I I I I VI. DETECTION, MONITORING AND CONTROL SAFETY SYSTEMS Detection, monitoring, or automatic control systems to minimize potential acutely hazardous materials accident risks are discussed in this section, as required by SectiOn 25534 (c)(4) of Chapter 6.95. Pursuant to Section 25534 (k), monitoring programs are also addressed. A. AUTOMATED MONITORING 1. Pressure Each compressor is equipped with a pressure activated shut-off switch that monitors the vapor discharge pressure. If the vapor discharge pressure becomes too great, the switch activates to shut off the compressor. The switch must be manually reset to restart the compressor. The compressor discharge header also contains a pressure activated switch that controls the evaporative condenser fans. At 155 psig discharge pressure, the switch turns on the Iow speed condenser fan. If ambient temperatures are Iow enough or if refrigeration demand is Iow, the Iow speed fan will shut off at 150 psig. When refrigeration demand or ambient temperatures are high, a high speed condenser fan will start up at 170 psig discharge pressure. Oil pressure for each compressor is also monitored. On existing equipment, if the oil pressure falls below a pre-designated setting, the compressor will be shut down automatically according to the manufacturer's procedure. The new compressors are shut down automatically' if the difference between the inlet and discharge oil pressures falls below a pre-designated setting. The oil pressure shut-off must be manually reset to restart the compressor. All ammonia vessels including receiver tanks, accumulators, suction traps, 0il pots, and dump traps are equipped with automatic pressure relief valves. The valves activate when the pressure exceeds 150 to 300 psig depending on the vessel. If the pressure relief valves operate, the ammonia is released into a header pipe and sent to an ammonia scrubber tank system. If ammonia is released into the pressure relief header, an ammonia sensor Pestritto Foods, Inc. RMPP March, 1992 Page VI-1 Luff Environmental Consulting I I I I i I I i I I I I I I I I I I I. (set at 200 ppm) will activate audio and visual alarms. These alarms will notify operations personnel that a pressure relief valve has operated. 2. Temperature Monitoring Each compressor is equipped with a temperature activated shut-off switch that monitors the temperature of the discharge vapor. If the temperature in the compressor discharge line exceeds a preset value, the switch activates . to shut down the compressor. Also, the switch will activate to shut off the compressor if the oil temperature becomes too Iow during operation. The temperature sWitch must be manually reset to restart the compressor. Compressor oil temperature is also monitored. If the compressor overheats during operation, the switch activates to shut off the compressor. The switch must be manually reset to restart the compressor. 3. Interlocks The ammonia refrigeration system is controlled by a programmable logic controller (PLC). As such, there are several electronic interlocks built into the system to prevent potential equipment damage. If the PLC calls for a system shutdown, all liquid ammonia solenoid valves will close in addition to shutting down the compressors. · High liquid level in intercooler shuts down high stage compressors. · High liquid level in accumulator shuts down booster compressors. System shutdown on compressor emergency shutdown. · System shutdown on triggering ambient ammonia sensor. 4. Ambient Ammonia Sensing The engine room that contains the bulk of the ammonia refrigeration system is monitored by two ambient ammonia sensors. If the ammonia level in the room reaches 200 ppm for any reason, an emergency ventilation system will be activated. This system may also be manually activated from the remote emergency switches located inside the emergency refrigeration control box. Pestritto Foods, Inc. RMPP March, 1992 Page VI-2 Luft Environmental Consulting I I I i I I The emergency ventilation system consists of a high flow rate fan (19,150 cubic feet per minute) that discharges into the evaporative condenser. Once the system is activated (either automatically or manually), the fan pulls air out of the engine room and blows it into the evaporative condenser which circulates 1000 gallons per minute of Water. At the same time, the evaporative condenser drain line is directed away from the sewer and into the ammonia scrubber tank located outside. The water in the evaporative - condenser absorbs the ammonia vapor and is returned to the scrubber tank. A water pump on the tank is also started at this time to circulate water from the scrubber tank to the evaporative condenser. This water pump may also be started manually with switch S3 located next to S1 and S2 inside the emergency refrigeration control box. i I I I i I I I I I I I B. MANUAL MONITORING The ammonia system will be monitored on a routine basis. Plant operations personnel will physically inspect the system on a daily basis during the operation of the plant to verify the proper function and integrity of equipment. Records of the inspections will be kept for a minimum of five years. In addition to the routine daily inspectiOns, the physical condition of the ammonia equipment will be monitored during scheduled plant shutdowns. When there is a scheduled shutdown of the plant; the ammonia system may also undergo inspection and maintenance during the plant shutdown. All records of maintenance, both preventative and response, on the ammonia system will be recorded for future reference. These maintenance records will be kept for a minimum of five years. Pestritto Foods, Inc. RMPP March, 1992 Page VI-3 Luft Environmental Consulting I I I I ! I I I I I I I I I I I I I I B. INVENTORY CONTROL AND RECORDKEEPING PROGRAMS Hazardous Materials Inventories Pursuant to Sections 25503.5, 25504, and 25509 of the Health & Safety Code, PFI will conduct and maintain hazardous materials inventories. These inventories will be submitted to the Administering Agency and will be updated annually or sooner, if required. The inventories will also be maintained for five years. Maintenance Records Maintenance activities will be documented and the records will be submitted to 'the Plant Manager for retention. Maintenance activity records include the preventative maintenance records, equipment monitoring and repair records, testing records, and equipment calibration records. All maintenance records will be retained for five years. Operations Records Daily operations logs are maintained for the plant. These records are retained by the Plant Manager. These records will be maintained for five years. Safety and Training Records All employee training .is documented and employee participation is recorded with attendance sheets. Similarly, the monthly safety meetings are documented. These records are submitted to the Plant Manager for review and retention. All safety or environmental incidents will be evaluated' and an "Incident Report" will be prepared as necessary. Similarly, all incidents requiring first aid or which result in injury are recorded. These records are maintained by the Plant Manager for a period of five years. Pestritto Foods, Inc. RMPP March, 1992 Page VIII-2 Luff Environmental Consulting I I I i I I I I I I I I I I I I ! I I Xll. OFFSITE CONSEQUENCE ANALYSIS Section 25534 (d)(2), Division 20, California Health and Safety Code states that "[t]he RMPP shall consider... If]or the hazards identified in the hazard and operabilitY studies, an offsite consequence analysis which, for the'most likely hazards, assumes pessimistic air dispersion and other adverse environmental conditions and which includes a clearly prepared map noting the location of the facility which shows the populations considered . . . and the zones of vulnerability including the levels of expected exposure in each zone." Additionally, SeCtion 25534.1 requires that "[e]very RMPP... shall give consideration to the proximity of the facility to schools, residential areas, general acute care hospitals, long-term health care facilities, and child day care facilities." This Section addresses.these requirements. For the release cases identified in the HazOp study, an air dispersion model was performed for the HazOp release events utilizing adverse (pessimistic) and average meteorologiCal conditions. Both sets of meteorological data were used to provide a basis for eValuating the offsite consequences of the release events. The air dispersion model and its results are discussed in this Section. A. GENERAL MODEL INFORMATION The pollutant dispersion results were generated by the CAMEO~3.0-ALOHA 5.0 model developed by the Hazardous Materials Response Branch of the National Oceanic and Atmospheric Administration (NOAA). CAMEOTM is the Computer- Aided Management of Emergency Operations program which was designed to help emergency planners and first responders both plan for, and safely handle, chemical accidents. ALOHA stands for Areal Locations Of Hazardous Atmospheres and serves as a tool for estimating the movement and dispersion of an atmospheric pollutant. NOAA recently updated ALOHA to include both a Gaussian dispersion model and a heavy gas model. .The Gaussian dispersion model plots the distribution of a pollutant gas from a series of Gaussian equations as described by Turner in the "W(~rkbook of Atmospheric Dispersion Estimates"1. The Gaussian equation describes a bell- shaped or normal curve. Concentration distribution at ground level is calculated and the bell-shape spreads out and gets wider and flatter as the pollutant drifts 1Turner, D. Bruce, 1974. Workbook of Atmospheric Dispersion Estimates. National Technical Information Service, Springfield, Virginia. Pestritto Foods, Inc. RMPP March, 1992 Page Xll-1 Luft Environmental Consulting ! I I I I I I I I I i I I I I I I I I downwind. The heavy gas dispersion model uSes calculations found in the Widely accepted DEGADIS2 model. The model has been simplified to provide quicker results during emergency use, but is still accurate to within ten percent of the original DEGADIS model. In both models, the pollutant concentration to be calculated is set to a particular numerical value such as parts per million (ppm), or can be the value of a toxicological parameter such as those set in the Emergency Response Planning Guidelines issued by the American Industrial Hygiene Association3. The models will give results using either an instantaneous source releaSe or a continuous source release. When the release of the pollutant occurs during one short time peri°d, it is modeled as.an instantaneous release. An instantaneous release is handled as a series of puffs. As the wind carries the puff away, the puff spreads out in all directions (see Figure 1). The puff of vapor becomes larger an~a-~ less dense as it drifts, but the core which exceeds the concentration value given will eventually get smaller. The plume ends when the spreading has reduced central concentration of the puff to below the value being calculated. vapor puff Part of the puff that exceeds ~ thresho~ntr~ Pollutant ~ ~ [~y ,~ ~'~ ~ ,.._ SourceX ~ ~ ~ ~ , FIGURE 1 - Top View of a Footprint from an Instantaneous Spill 2Spicer, Tom and Jerry Havens, 1989. Users Guide for the DEGADIS 2.1 Dense Gas Dispersion Model, EPA-450/4-89-019. U.S. EPA, Cincinnati, Ohio. 3American Industrial Hygiene Association, October, 1988: Emergency Response Planning Guidelines. AIHA ERPG Committee, 475 Wolf Ledges Parkway, Akron, OH 44311. Pestritto Foods, Inc. RMPP March, 1992 Page XlI-2 Luff Environmental Consulting I I I I I I ! I I I I '1 I I I I I ! · .A continuous release occurs when a pollutant is being released over a longer period of'time. A continuous release results in a concentration curve termed a footprint (see Figure 2). The area inside the curve is the region that is predicted to have ground level concentrations above the limit set by the modele~'. Pollutant Source ~ FIGURE 2 - Footprint from a Continuous Source Spill The ALOHA model incorporates several assumptions regarding chemical source, meteorological data and terrain. In the heavy gas model, the chemical spill is assumed to have occurred at ground level. The Gaussian model has the option of using elevated sources. For both models, all concentrations are calculated at ground level. MeteorologiCal data includes atmospheric stability, wind speed and wind direction. Atmospheric stability classes are identified by the letters A to F with class A being the most unstable and class F the most stable. Unstable conditions result in a large amount of mixing of the atmosphere, causing the pollutant chemical to produce a shorter threat distance but a wider plume. However, this condition also includes more variable wind directions, resulting in a threat zone that may tend to mea~nder. Stable conditions result in longer but narrower plumes that travel in one direction. The stability can be influenced by both heating and mechanical stirring of the atmosphere. Heating.of the sudace layer of the atmosphere leads to unstable conditions and ground cooling results in more stable conditions. Mechanical stirring is caused by the winds, with strong winds tending to Cause neutral stability (classes C ·and D). Wind speed and wind direction are input directly by the modeler; although the air model checks that wind speeds are consistent with the. stability class chosen. ~lf_t~he wind ~eed and stability class are inconsiste.~n~,~O~p~pJp_.m~di_s~persion is calcul_~.te__d. ~-,~)~C,~ lO~{-O~c0~r~ Pestritto Foods, Inc. RMPP Page Xll-3 Luff Environmental Consulting March, 1992 ! I I I I I I. I 'i I i I I I I I I I The turbulence caused as the-wind flows over and arOund obstacles is included in the model and termed ground roughness. The model adjusts for mixing consistent with stability class' by allowing for either rural grOund roughness, a terrain with few obstacles, or an urban ground roughness, characterized by many obstacles. The effects of terrain on the speed and direction of the plume are not included in the model. The model assumes that the winds are uniform throughout the plume. ' B. LIMITATIONS OF ALOHA DISPERSION 'MODEL Even with all the above mentioned factors included in the plume concentration calculations, as with all dispersion models, the ALOHA model does have several limitations. It is important to remember that the model has a nominal accuracy of a factor of 2, so a predicted concentration of 50 ppm may actually be in the range of 25 to 100 ppm. This degree of accuracy is consistent with other dispersion models..The model also does not accurately represent several conditions which are discussed below. As mentioned earlier, the ALOHA model does not include terrain steering effects caused by topography or wind shifts and the model assumes that all winds are constant throughout the plume. Wind variation can reduce the accuracy of the results when the plume travels more than a mile from the source. The model will only calculate plume dispersion results at distances less than 6.4 miles (10 km). Also, dispersion models are not accurate at Iow wind speeds (less than.1 mile per hour) or at very stable atmospheric conditions, which produce these Iow' wind speeds.' ALOHA does not allow a wind speed of less than one meter per second (2.237 miles per hour).' Another situation not handled well by ALOHA (or air models in general) is concentration patchiness in the area 50 to 100 yards from the source. In this vicinity, the pollutant may meander and be more patchy than the model can predict. After about 100 yards, a plume will experienced enough mixing eddies to reduce the irregular concentrations within the plume. At this point, the model will predict the pollutant concentrations within the accuracy of the model. Pestritto Foods, Inc. RMPP March, 1992 Page Xll-4 Luff Environmental Consulting I I I I i I I ! I I I I I I I I I I I MODEL PARAMETERS FOR PESTRITTO FOODS, INC. For the release cases identified in the HazOp study, an air dispersion model was used to evaluate the offsite consequences of the release events. The air dispersion modeling was performed utilizing both adverse and average meteorological conditions. By applying both sets of'data to'the release events, the modeling results provide qualitative information to help evaluate the offsite consequence associated with the worst credible release events. Anhydrous ammonia is a gas composed of three parts hydrogen and one part nitrogen (NH3). It has a molecular weight of 17.03 and is lighter than air. When stored under sufficient pressure at ambient temperature, ammonia is liqUefied. Ammonia exists in both liquid and vapor phases in the refrigeration system, depending on system pressure and temperature. Anhydrous ammonia is shipped as a nonflammable gas and is an irritant to the eyes, skin and mucous membranes. Ammonia has a perceptible odor.as Iow as 5~ ppm and is readily detectable at 10 ppm. A release of anhydrous ammonia vapors under'pressure may result in the formation of an aerosol mist which behaves as a heavy gas (heavier than air). However, the ammonia behaves in a normal Gaussian distribution once the concentrations in air. drop to about 10,000 ppm. For a small release, this will occur within the first 50 yards from the source. Under all meteorological conditions, ALOHA predicted that the concentration of the plume would ~rop to less than 10,000 ppm within 100 yards for each release scenario. Since the nearest sensitive receptor is more than 100 yards from the facility, the Gaussian model was used to estimate the offsite consequences of a potential release. Also, ALOHA selected the Gaussian model instead of the Heavy Gas model for each release scenario. If anhydrous.ammonia is released as a liquid, a portion of the liquid will flash to the vapor phase immediately. The amount of liquid ammonia that will flash to the vapor phase is dependent on the storage pressure prior to the release. For each release of liquid ammonia, the percentage of ammonia flashing to the vaPor phase was calculated. The balance of the release would form a liquid pool that would evaporate over a period of time depending on ambient conditions. The air dispersion model calculates the evaporation release rate based on the input meteorological parameters. Therefore, a release of liquid anhydrous ammonia would generate two vapor dispersion models; one for the initial flaSh of the Pestritto Foods, Inc. RMPP March, 1992 Page Xll-5 Luft Environmental Consulting I I i ! I I I I I I I I I I I I I I I release and the second for the evaporation of the liquid p0ol. .Results were modeled for concentrations set at 50 ppm and 500 ppm as specified in the "Outline of RMPP Requirements", prepared by the Bakersfield City Fire Department Hazardous Materials Division. The 50_p_pm value is the EPA Level of Concern~__(LOC____)_ con_cen___tr, ati.on_at_w, hich'-there-she.ald-be-ne-discomfert~ or _impairment of health fp__r ~p_[_o!p_nged e_~xp_o~sure of more_than 30 minutes. An ambient concentration of ammonia of 500 ppm is considered as Immediately Dangerous to Life or Health (IDLH). At 500 ppm, there is severe irritation of the eyes, nose and throat, but there are no lasting effects for a short exposure of less than 30 minutes. Since ammonia has a perceptible odor as Iow as 5 ppm, it is unlikely that a person would become unknowingly overexposed.4 The meteorological conditions used to determine maximum impact distances and times were based on data collected by the U.S. Weather Service at Meadow Fields Airport in Bakersfield, California. The data in Table 1 summarizes the meteorological data for both average and adverse conditions. On an annual basis, the. predOminant meteorological conditions are with a wind direction from the north-northwest at 6.4 miles per hour. A chemical release during these average atmospheric conditions represents an offsite consequence that would potentially have the greatest affect on sensitive populations. For modeling purposes, however, winds from the south-southeast at 5.0 miles per hour were also considered because they represent the worst case or "pessimistic" atmospheric conditions. The PFI facility is located on McDivitt Drive in a commercial/light industrial area. Pursuant to Section 25534, California Health and Safety Code, "[e]very RMPP... shall give consideration to the proximity of the facility to schools, residential areas, general acute care hospitals, long-term health care facilities, and child day care facilities." Sensitive population sites considered in this offsite consequence analysis included residences, schools, emergency and health care facilities. Figure 3 shows an overview of the sensitive population sites near the PFI plant. The distances between the PFI facility and the sensitive populations are Summarized in Table 2. The nearest resident is approximately a quarter of a mile 4American Industrial Hygiene Association, October, 1988: ' Emergency Response Planning Guidelines. AIHA ERPG Committee, 475 Wolf Ledges Parkway, Akron, OH 44311. Pestritto Foods, Inc. RMPP March, 1992 Page XII-6 Luff Environmental Consulting I I ! ! I I I I I I I i I I i I' I I I TABLE 1 MEADOWS FIELD METEOROLOGICAL DATA Bakersfield, CA MONTH WIND SPEED WIND DIRECTION (aPR) (FROM) JAN 5,20 NW FEB 5,80 ENE MAR 6.50 NW APR 7.10 NW MAY 7.90 NW JUN 7.9O NW JUL 7.20 NW AUG 6.80 NW SEP 6.20 WNW ocT 5.5O NW NOV 5.10 ENE DEC 5.00 ENE AVG. 6.40 NW I I ! i I I I I I I I I I I ! I I I I SITE Nearest Nearest Nearest Nearest Residence Hospital School Fire TABLE 2 PESTRITTO FOODS INC. SENSITIVE POPULATION SITES DISTANCE FROM PLANT (Miles) 1.10 1.24 Station 1.31 CRITICAL WIND DIRECTION (Wind From) South Southwest East Southeast ! I I I I I I I I I I i I I I I I I I north of the PFI' facilitY. There is a hospital to the northeast of the PFI facility, over a mile away. The nearest school is roughly 1.24 milesto the 'west of the plant. A Bakersfield City Fire Department station is located 1.31 miles northwest of the PFI facility. Most of the ALOHA limitations discussed previously, have minimal effects on the model results. The-ALOHA limitation regarding terrain steering effects and wind shifts'caused by topOgraphy is not a problem in the area being modeled because the terrain is generally flat and unobstructed by large hills or Valleys. The ground roughnesS of the area is determined to be urban terrain, as the facility is surrounded .on all sides by light industrial buildings. The effects of concentration patchiness within the first 50 to 100 yards from the source will be minimal, because there are no resident populations within this pre-Gaussian area.. D; RESULTS OF THE ALOHA DISPERSION MODELING The HazOp study generated release events for the ammonia system based on the design of the facility, potential operator error and external events, such as an earthquake. These release event~s_w_e_re reviewed to determine whether t_here~..~--- was a hi_gh lik~b.o_o.d_o.f_o.c~cur, r_e~ce or a significant offsite consequence if the release were to_~occur. The releases associated ~i~a high ~Ti-h-5~0-~ _o_[f occurrence were very Iow release rates and originated within the engine room Which is-equipped with the emergency ventilation system. There would be little or no offsite consequences associated with these release events. "~*,d~ ~/~0~ / Five release events were identified in the HazOp study as having potential offsite consequences that warranted air dispersion modeling. These releases were identified as follows: 1. Failure of the ammonia delivery hose during a delivery. 2. Thermosyphon receiver tank line failure. 3. Pressure relief valve release. 4. Controlled pressure receiver tank line failure. 5. A release from the oil drain pot. Air dispersion modeling was pedormed for the delivery hose failure (for two different release durations) and the failure of the 3 inch liquid line between the controlled pressure receiver and the spiral freezer. Pestritto Foods, Inc. RMPP Mamh, 1992 Page Xll~7 Luft Environmental Consulting I I I I i I I I i I I I I I I I I I I Of the events identified above, failure of the 3 inch liquid line and the filling hose failure were considered the potential worst case releases by the HazOp team. The pipeline failure was not considered a likely event since all of the system pipelines were designed and installed per the Uniform Building Code and American Society of Mechanical Engineers codes. However, air dispersion modeling was performed for the pipeline failure release event to provide emergency responders with a representation of a worst case, though unlikely event. The pressure relief valve release event was not considered likely to occur since there is little or no combustible material in the engine room, and the engine room has a fire suppression sprinkler system. Additionally, the pressure relief header discharges into a passive scrubbing system. For this reason, air dispersion modeling was not performed on this release event. Similarly, compressor oil is drained from the system through the oil pot periodically. This release event, if it occurred, would take place within the engine room. Since the engine room is equipped with the emergency ventilation system, the offsite consequences associated With this release would be substantially mitigated. Additionally, since the vapor release rate from the oil pot discharge is nearly identical to the vapor release rate from the delivery hose, the release from the oil pot was not modeled. The releases associated with the delivery hose failure has the potential to occur on an infrequent basis. Ammonia will be delivered to the plant periodically to recharge the ammonia system. Only during ammonia delivery could the delivery hose failure release event develop. In order to generate a worst case release event, the hose failure was assumed to occur outside of the engine room. Results of the dispersion models for a 10 second and continuous release are shown in Tables 3 and 4 respectively. ~ For the 3 inch liquid line event, the 500 ppm plume travels slightly over two hundred yards under adverse weather conditions as shown in Table 5 and Figure 4. The 50 ppm plume for the same events is shown in Table 5 and Figure 5. The 50 ppm plume travels just over 650_yards and does not impact any sensitive receptors. In summary, the modeling sl~ows that there probably would not be any significant adverse effects to the ser~sitive population areas 'caused by the Pestritto Foods, Inc. RMPP Page Xll-8~ ~. \~'~-"'~" --Luft Environm.,ental Consulting I I I I I I I I ! I I I I I I I I I I credible worst case releases of anhydrous ammonia. An external event, such as an earthquake, that would cause the 3 inch liquid line to fail might prevent Pestritto Foods, Inc. personnel and emergency response personnel from stopping a release from the refrigeration system. In the event of a pipe failure, the liquid contents of the controlled pressure receiver would be expelled in less than one minute. Following this initial, release, ammonia vapor would continue to vent from the system at a very slow rate until the broken section of pipe could be isolated as the liquid ammonia in the rest of the refrigeration system would continue to evaporate. A slow release of this type could last several days or weeks depending on the location and severity of the pipeline failure. However, a slow release would not impact populations surrounding the facility as a 500 ppm plume would not be expected to extend beyond the boundaries of the facility. Also, a slow release could be readily repaired by personnel wearing personal protective equipment such as respirators. Pestdtto Foods, Inc. RMPP March, 1992 Page Xll-9 Luft Environmental Consulting I I I I !- I I I I I I I I I ! I I I I ~II~PESTRITTO FOODS CONTROL PRESSURE RECEIVER LINE FAILURE AMMONIA RELEASE 325 LBS VAPOR-3689 LBS LIQUID ADVERSE WEATHER 'CONDITIONS 50 PPM PLUME CONCENTRATION  & 8 FlflEi &  ' 1~ WHITE LANE ¢3 ' ~ , 'TO L~J n" ~ 0 n- ~ ) S DISTRICT BLVD  I I I I I I I I I I I I I I ! I I I I ! I I I I I I I I I I I I I I I I .I ~l,,,,,..J...,.4"' I I I I I I I I I I I I PANAMA ~NE LEGEND ~ ~h - School ~ - Residential Area r~ - Fire stalJon N I~1 - Proposed School ~--~ - Hospital ', ', ', ', - Railroad 0.5 Mile = 1 Inch Figure $ - Map shows the impact on the sensitive populations sites of an ammonia release due to a control pressure receiver line failure. Vaaor Source: 325 lbs Ammonia Adverse Weather conditions Modelled Liauid Source: 3689 lbs Ammonia Total Disoersion Distance for 50 .Dom Plume: V .aDor Release: 658 yards [.IGC: 449 yards (shaded) Stability_ Class: C Wind S_Deed: 5.0 mph Wind Direction: From the SSE TemDerature: 40°F Ground RoUghness: Urban LEC/PF-02/3-92 MEMORANDUM' "WE CARE" May 29, 1992 TO: FROM: SUBJECT: valerie Pendergrass Barbara Brenner Pestritto Foods RMPP billing A total of 5.0 'hours were spent'reviewing the hazard, risk and consequence analyses and/or the RMPP 'documents for the~e~l~r~&~ ~L~i~d~and anhydrous ammonia RMPPs. 5 hours x 45 $ per hour = 225 $. Please enter this amoUnt into the computer so that a bill.will be generated. Note the date that the entry is made on this memo and file it in Pestritto's RMPP file when you are done. cc: Ralph Huey FIRE DEPARTMENT S. D. JOHNSON FIRE'CHIEF CITY of BAKERSFIELD "WE CARE" March 311 1992 .2101 H STREET BAKERSFIELD, 93301 326:3911 Karl Luff Luff Environmental Consulting 3701 pegasus Drive, Suite 121 Bakersfield, CA 93308 Karl: I have completed review of the modified RMPP submitted on behalf of Pestritto Foods. Following is a.listing of deficiencies found in the RMPP document. Several items of safety equipment and system control deviceS have not been included in the RMPP. * Gages have been added in the engin~e room to allow easy visual monitoring of system pressures without traveling out t° view the gages in the diffusion system control box. * Manual control switches have been inStalled to operate roof top isolation valves from the engine room. * A ladder will be installed on the roofito facilitate'access to the top of the new spiral freezer. ,. The capability of several safety devices have not been detailed fully. * It is my understanding that the ammqnia sensor and fire protection system are monitored remotely on a 24 hour/day basis. The monitoring company contacts plant staff and public emergency respdnders if an alarm is activated. * A back check Valve on the controlled pressure receiver line is mentioned in the summary of the hazard analysis. This back check valve is not mentioned in the RMPP as a safety device. I find no coverage of the management of change as outlined in your summary dated 3-2-92. o ,. 10. 11. 12. 'The ageof the equipment is not inclUded in the description of the equipment. The EPA definition of LOc does not include any judgements regarding levels of discomfort to recepto'rs. (pg. XII-6) The definition of-IDLH must include a description of the population it'applies to - healthy adults. Table 2 places the nearest residence .24 miles from the Pestritto plant. The offsite consequence analysis conclusions on page XlI-8 state that the .50 ppm. plume travels about 650 yards and does not impact any sensitive receptors. These two pieces of information are contradictory as .24 miles -- 422 yards. It appears that sensitive receptors would be impacted by the 50 ppm plume. The maps which show the impact on sensitive populations due to an ammonia release at Pestritto do not accurately reflect the location of the nearest residences. There are apartments directly north of the plant. The maps show housing to the north east and north west but do not indicate the nearest sensitive receptors. The modeling included in the offsite consequence analysis does not include the 'possibility of a 3" line release at night. This item was specifically mentioned in my letter dated 3-5-92. The offsite consequence, analysis makes no mention of the levels of exposure expected in each zone, within each of .the plumes, as required bY Section 25534(d) (2). The offsite consequence analysis does not state the duration of the continuous ammonia hose release or the duration of the evaporation of the pool created by the controlled pressure receiver release. Duration of a these releases must be stated and considered when determining possible consequences to receptors. The use and effect of the urban, terrain parameter needs to be discussed in the model parameter section. While most of the terrain around Pestritto is urban, ammonia plumes traveling toward the north will not encounter urban terrain until they contact the housing tract. It will not be necessary to include models and maps for the rural characteristics of the northerly dispersion.. However, a discussion of the urban terrain parameter and possible deviations in the predicted dispersion distances to t'he no,rth must be !ncluded. Document the reasons why the release of the remainder of the ammonia in the system would evacuate so slowly (over several days or weeks) following the initial. release. 13. Because Luft Envirohmentalls qualifications as an RMPP preparer include'your registration .as. a Professional Mechanical Engineer, the State Registration Board informs me that it is appropriate for the certification page to include your registration number. ~ 'The corrected RMPP should be resubmitted by June' 1, .!992. i am available to review drafts of Proposed changes at anytime in the interim. If you have questions regarding the points outlined aboVe, please give me a call: Sincerely, Barbara Brenner Hazardous Materials Planning Technician cc: Ralph Huey ¸Il CITY of BAKERSFIELD "WE CARE" FIRE DEPARTMENT S.D, JOHNSON FIRE CHIEF -March 23; 1992 A1 Sautner · Plant Manager Pestritto FOods, Inc. 6800 McDivitt Dr.~ · Bakersfield, CA 93313 2101H STREET BAKERSFIELD, 93301 326-3911 'Al: Bakersfield Fire' has received the Risk Management and Prevention Program modified to include the expansion of the aDhydrous ammonia refrigeration system at Pestritto. Because the primary issues of'concern identified in review of the preliminary analyses have been resolved in the certified RMPP, Bakersfield Fire will authorize the start up of the new ammonia refrigeration equipment effective immediately. The remainingconcerns regarding the RMPP and consequence analysis will be outlined in a letter to Y0ur consultant, Luft Environmental. These final issues must be resolved prior to a determination by Bakersfield Fire that Pestritto's RMPP is complete. The acutely hazardous materials registration·must be filed with this agency prior to the· receipt ·of anhydrous ammonia at Pestritto which will increase the size of the existing charge. The addition of'the ammonia to your hazardous materials inventory must be filed within 30·days of receipt of the material. Pl. ease call me at 326-3979 if you have any questions or if I can be of assistance. Sincerely, Barbara Brenner ~Hazardous 'Materials Planning Technician cc: Ralph Huey Karl Luft MEMORANDUM "WE CARE" March 13, 1992 ,TO: ' Valerie Pendergrass FROM: Barbara Brenner SUBJECT: Pestritto Foods Inc. A total of 10 hours have been spent to date reviewing modifications to Pestrittos RMPP regarding expansion of the refrigeration system. 10 hours x 45 $ per hour = 450 $. Please enter this amount into the computer so that a bill will be generated for the first quarter of 1992. Note the date that the entry is made on this memo and file it in Pestritto's RMPP file when you are done. cc: Ralph Huey LUFT ENVIRONMENTAL CONSULTING I ECE, IVED i'IAR ! q 1992 Aris'cl... .......... 3701 Pegasus.Drive, Suite 121 · Bakersfield, California 93308 · (805) 399-5838 March 12, 1992 Bakersfield City Fire Department 2101 H Street Bakemfield, CA 93301 Attn: Barbara Brenner Enclosed please' find the updated RMPP for the ammonia refrigeration systrem at the Pestritto Foods, Inc. facility. This updated RMPP complies with Article 2 of Chapter 6.95, Division 20 of the California Health and Safety Code. The addendum also addresses the concerns expressed by the Fire Department during its review of the facility. Also enclosed for your reference are the computer generated vapor dispersion model input parameters and output data for the scenarios considered for the preparation of the offsite consequences portion of the Pestritto Foods, Inc. RMPP. All of the data enclosed is' being supplied to the Bakersfield City Fire Department in accordance with Article 2, Chapter 6.95, Division 20, Section 25534.5 of the California Health and Safety Code. The enclosed computer printouts are supplementary material and should not be considered part of the formal RMPP submission. Should you have any questions regarding the enclosed material, please call Todd Rook, or me at (805) 399-5838, Karl W. Luff Principal Mechanical Engineer cc: Al Sautner, Pestdtto Foods, Inc w/o enclosures Enclosures PF-02 LEC-92-0071 FIRE DEPARTMENT S.D. JOHNSON FIRE CHIEF CITY of BAKERSFIELD "WE CARE" March 5, 1992 2101 H STREET BAKERSFIELD, 93301 326-3911 Karl Luft Luft Environmental Consulting 3701 Pegasus Drive, Suite 121 Bakersfield, CA 93308 Karl: I have completed review of the summary submitted regarding the points discussed in our meeting with the Pestritto staff. The information submitted sufficiently addresses the RMPP changes and action items discussed. Following are my comments regarding concerns which remain at this time. The addition ~of 2 ammonia sensors 'and the commitment by Pestritto management to implement a system for the management of change are risk mitigation measures and should be included in the RMPP in the appropriate section, per Section 25532 of Division 20, Chapter.6.95 of CA Health and safety Code, a "RMPP means all of the administrative and operational programs of a business which are designed to prevent acutely hazardous materials accident risks .including but not limited to , programs which include design safety of new and existing equipment, standard operating Procedures, preventive maintenance programs, operator training and accident investigation procedures, risk assessment for unit operations or operating alternatives, emergency response planning, and internal or external audit procedures to ensure that these programs are being executed as planned". Based on this definition it is appropriate to consider the management ~of change under this statute. During our.meeting, we agreed that the approximate 4000 pound release from the controlled pressure receiver is a reasonable .estimate of an immediate release from the system. Please include in the text of the offsite consequence analysis a summary of the remainder of that discussion. Dave Schmerker of Preston indicated that following the immediate release, the system would continue to release ammonia over an extended period of time unless the area of the rupture is isolated. Note the time period over which the ammonia in system remaining after the initial release would evacuate if Pestritto Staff were unable to respond. The eXisting ,contrOlled pressure receiver modeling does not' appear to include adverse weather conditions. Stabilityclass C is representative of slightly unstable daytime conditions. In the. absence of a seismic analysis, we~find that this type~ of release from the controlled pressure receiver is possible as the result of an earthquake. The possibility of a earhtquake at night requires a reevalUatiOn of adverse weather conditions. For purposes of an Offsite Consequence Analysis, the scenario considered must present a hazard to public offsite. An eXception to this may occur if no such scenarios exist. Bakersfield Fire never implied that the definition of hazard. is limited to an event which adversely 'impacts offsite receptors. Future hazard analyses should continue to include possible sources of peril or,danger to persons within a plant. Bakersfield Fire uses Webster's definition of a hazard which I sent to Luft attached to previous correspondence. I have discussed the type of map required for the identification of zones of vulnerability at length with Todd Rook concerning the Gist-brocades project. The map for the Pestritto project should be prepared ~in a similar format. The RMPP modifications addressing the items outlined in Luft's summary dated 2-26-92 must be submitted and complete prior to operation of the new equipment at Pestritto Foods. Please Call me if you require further clarification on any of these points. Sincerely, Barbara Brenner Hazardous Materials Planning Technician cc: Ralph Huey Fire Department :' 2101 "H" Street~. Bakersfield,' CA 93301 Fax Phone No. (805) 395-1349 Office (805) 326-3941 Date: ,19 q)" 'PLEASE ROUTE AS SOON AS POSSIBLE. TO: Name: ~ L.o.~ / "i~og~) -E_oo Ic- Company/Organization: Lo Fax No. Sending Message to: FROM: Name: 'E~ ~_¢-~.g~..k Contact Person: Number of Pages (including cover sheet)' Description of Materials Sent: "~¢~_~-,-xo_ ,~c. · -Special Instructions: LUFT ENVIRONMENTAL CONSULTING 3701 Pegasus Drive, Suite 121 · Bakersfield, California 93308 · (805) 399-5838 March 2, 1992 BakerSfield City Fire 'Department 2101 H Street Bakersfield, CA 93301 Attn: Barbara Brenner RECEIVED. ilns'd ............ Enclosed please find a summary of the points discussed in our meeting with you on 'January 10, 1992. Changes that will be made to the original RMPP addendum submission are also indicated. As indicated in the enclosed response, some sections of the RMPP will be updated to comply with recent changes in the legal requirements for RMPP supporting documents. A draft of the updated HazOp matrix, with changes underlined, is also attached. Please call with your comments on the enclosed material at your earliest convenience as Pestritto Foods plans to begin testing of the new refrigeration equipment in two weeks. ShoUld you have any questions regarding the enclosed material, please call Todd Rook or me at (805) 399-5838. .. cc: AlS Day Attachments PF-02 LEC-92-006 autner, Pestritto Foods, Inc. 9 Smreker, Preston Refrigeration Co. Principal Mechanical Engineer PESTRITTO FOODS, INC. REFRIGERATION SYSTEM UPGRADE RMPP CHANGES AND ACTION ITEMS February 26, 1992 A meeting involving personnel, from the hazardous materials division of the Bakersfield City Fire Department, the management of the Pestritto Foods, Inc. Bakersfield Plant, and personnel from Luff Environmental Consulting to discuss an · update to the PFI RMPP took place on JanUary 10, 1992. The points listed below were discussed at the meeting. A summary of the Fire. Department concerns and the actions taken regarding each point are also provided. 1. Added Equipment (Ammonia Handling Only) Equipment is being added to the refrigeration system at Pestritto Foods, Inc. (PFI) to expand the capacity of the plant.' The following anhydrous ammonia handling equipment will be installed: Evaporative Condenser on roof of new machine room expansion High Stage Screw Compressor Booster Screw Compressor Spiral Freezer Coil Ante Room Evaporator Coil The operating pressures of the system will nOt change due to the refrigeration system expansion. The operating pressures are as follows: '8.7 inches of Hg suction to compressors 23.8 psig Iow stage discharge 180 psig high stage discharge 30 psig controlled pressure receiver 2. Hazard and Operability Study The Bakersfield City Fire DePartment (BCFD) expressed concern over the completeness and adequacy of the hazard and operability study conducted for the original 'RMPP in light of the' new equipment. The BCFD requested that the HazOp matrix and the hazard and operability study be reviewed in a thoroUgh manner and that specific differences between'old and new equipment be identified. · PFI/RMPP/Feb., 1992 Page 1 of 7 Luft Environmental Consulting The HazOp matrix was reviewed in detail; It was found that the installation of the new equipment presents 'risk and release scenarios that are substantially similar to the ones documented in the original RMPP. The new equipment does cause'a very slight increase in the probability of a minor leak occurring (as from a valve packing) but does not increase the risk to the public from a possible accident. No significant differences in operation between the new installation and the existing equipment were found. During the review of the original HazOp matrix, it was determined that some of the original study node deviations discussed during the HazOp-were nOt documented in the matrix. Also, the emergency ammonia control box had not been included in the matrix. ^ corrected HazOp matrix is attached. Changes and additions to the matrix have been underlined to facilitate review of the new HazOp matrix. None of the changes noted in the HazOp review have a signifiCant.affect on the hazards identified in the original RMPP supporting document. 3. Emergency Ventilation System The BCFD requested that verification be provided that shows that the emergency ventilation system in the machine room is adequately sized to accommodate the increased ammonia charge and emergency reliefs on-the new equipment. , Item number 2 of the letter dated August 26, 1991 from Luff Environmental Consulting to the Bakersfield City Fire Department addresses the emergency ventilation system. Notes on drawing number 901106 R-9A regarding exhaust system sizing and. scrubber tank sizing indicate that the full refrigeration system and machine room expansion were included in the original design. The ventilation requirements for ammonia were based on a controlled pressure receiver volume of 509 cubic feet, which has not changed since the vessel was installed. The machine room expansion increases the available floor space by approximately 800 square feet and the total room volume by approximately 19,200 cubic feet. The total machine room volume after expansion is approximately 49,920 cubic feet.. The emergency ventilation system is capable of moving air at 19,150 cubic feet per minute. At that rate, the emergency ventilation system will change the air in the expanded room in less than 3 minutes. Since the original design includes system expansion and the ventilation system drawing was approved by the Building Department and the Fire Department, no further analysis is required. 4. Scrubber Tank System The BCFD requested that verification-be provided that shows that the scrubber tank PFI/RMPP/Feb., 1992 Page 2 of 7 Luft Environmental Consulting system is adequately sized to accommodate the increased ammonia charge and emergency reliefs on the new equipmen(: Item number 2 of the' 'letter dated August 26, 1991 from Luft Environmental' Consulting to the Bakersfield City Fire Department addresses the scrubber tank system. The original system drawingS indicate that the scrubber tank system was designed with full systemexpansion taken into account. Notes on drawing number 901106 R-9A indicate that the scrubber tank was designed for a total ammonia charge of 15,000 pounds. The current system charge and the expansion will not exceed 15,000 pounds as the total system charge after expansion is estimated to be 8,500. Pounds. Since the original scrubber system design accounts for the current and future system exPansion and the scrubber tank system drawing was approved by the Building Department and the Fire Department, no further analysis is required~ 5. Control :Panel Location The addition to'the machine., room has increased the diStance from the most likely building exit to the emergency ammonia contrOl panel. This increased distance has the Potential to increase the time for PFI personnel to respond in certain emergencies. The BCFD requested a review of the location and the associated increase in resPonse time in the event of an emergency situation. An on-site review of the placement of the control box indicated that the distance from the most likely' building eXit to the control panel will 'be. increased by approximately 80 feet after the expansion. The total distance (approximately 180 feet) represents a time of approximately 40 seconds, ~at a normal walking pace, to reach the control panel. The time required for a PFI employee to reach the control box and unlock it in an emergency is well under one minute. As first.responders, the trained Pestritto Foods Inc. personnel will have ample opportunity to begin spill mitigation measures well before public responders arrive. An instructiOn sheet for the operation of the emergency control panel is provided inside the control box so that responding Personnel will not have to rely on memory to effectively operate the control panel during an emergency situation. The cOntrol panel is expected to be used only in an extreme overpressure situation as might be present during a fire. ~ A fire in the machine room is not likely since there is very little combustible material in the machine room. Additionally, the machine room is equipped with a fire' suppression sprinkler system. Since emergencies that would require use of the control panel are not' likely, the inCreased time required to reach the control panel does not present a significant increase in risk or exposure time to the public. PFI/RMPP/Feb., 1992 Page .3 of 7 Luft Environmental Consulting It should also be noted that, in the event of an-overpressure situation,, each vessel is equipped with a presSure relief valve that vents to the scrubber tank system. These relief valves are required to be sized for fire conditions and will properly. relieve the ammonia vessels without operator intervention. . 6. Release Scenarios The maximum ammonia charge in the original system was reported as 7000 pounds in the business plan submitted to the BCFD. The RMPP identifies 4,362 pounds as the maximum release from the most likely hazard. The BCFD requested documentation to support the contention that the release calculations were based on a full system,charge including proposed expansions rather than current capacity. · No new modes of failure were identified during the review of the HazOp matrix, hazard and operability study, and the existing release scenarios. The release scenarios that were modeled for the original RMPP are summarized below. "Existino Disoersion Model~ FILLING HOSE FAILURE 2.54 lb/sec vapor 9.71 lb/sec liquid 100 sq. ft. pool THERMOSYPHON RECEIVER (3 INCH LINE) 113.7 lb vapor 372.2 lb liquid · 100 sq. ft. pool CONTROLLED PRESSURE RECEIVER 361 lb vapor 4001 lb liquid 1000 sq. ft. pool As the original RMPP was prepared before the existing system was installed, the assumptions made in the original release scenarios were reviewed..Changes to the existing release scenarios are summarized below. PFI/RMPP/Feb., 1992 Page 4 of 7 Luft Environmental Con,suiting .New Dis_oersion Model~ FILLING HOSE FAILURE N° change. THERMOSYPHON RECEIVER (3 INCH LINE) No Change. CONTROLLED PRESSURE RECEIVER 325 lb vapor 3689 lb liquid '1000 sq. ft. pool The Change in the controlled, pressure receiver model is due to an estimate of the operating level, of the tank that was made before the original equipment was installed. The current operating level of the controlled pressure receiver is between three and four feet. The level of ammonia contained in the vessel for the purposes of release calculations in the original RMPP was assumed to be slightly less than four feet. The vapor and liquid amounts sited above assume an average level of 3.5 feet in the controlled pressure receiver. The existing model, in the original RMPP, is sufficient for current and planned expansions of the refrigeration system for the following reasons. ~First, the modeled ammonia releases are greater than current operating levels would_~e. Second, .the operating level of the controlled pressure receiver should not .change significantly to accommodate future expansion as ammonia added 'to the system to accommodate future expansion will fill new evaporator coils and other piping instead of changing the level of the controlled pressure receiver. Third, the change in the ammonia level due to seasonal variations in refrigeration requirements will be minimal. Lastly, the change in the level of the c°ntrolled pressure receiver from the original assumptions to the current average operating level represent approximately 300 pounds of ammonia. The changes in the dispersion model that would result from altering the release by 300 pounds will be minimal and are well within the factor of 2 accuracy of the CAMEO model. 7. Offsite Consequence Analysis Changes in the California Health and Safety Code as of January 1992 have modified the requirements for the information that must be supplied in the RMPP' PFI/RMPP/Feb;, 1992 Page 5 of 7 Euft Environmental Consulting regarding offsite consequences' that develop from potential releases. The BCFD has indicated that it will require the updated RMPP to conform to the current language in the statute. AIs~o, the BCFD pointed outt...hat a release that does Dot pr~oduce an offsite risk to the public cannot be re.qarded~asa_hazard. The offsite consequence analysis will be updated to include the release events determined by the Bakersfield City Fire Department to be the most likely hazards to occur. Additionally, the presentation of the offsite consequence analysis, in the RMPP will be modified to comply with changes in the California Health and Safety' Code, Division 20, Chapter 6.95, Article 2 as of January 1992. 8. Sections IV, V, and VI of the RMPP Document The BCFD noted that sections IV, V, and VI of the original RMPP supporting document are likely to require changes to reflect the new equipment. A review of the above sections identified several minor changes that were needed to update the RMPP. The appropriate' sections of the RMPP supporting document have been revised to reflect the addition of new equipment. Specific concern over the number and placement of the ambient ammonia sensors in the machine room was expressed by the BCFD. The ambient ammonia sensor for the machine room is currently mounted on the north wall of the room, between the double doors and the louver set west of the double doors. The north wall of the existing machine room will become a partition wail in the expanded machine room. The heat generated by .the equipment in the machine room will cause air to be drawn in through the louvers in the new north wall, past the ammonia sensor, and out the roof vent. Therefore, the current placement of the ammonia sensor is sufficient to detect leaks originating in the existing machine room and the new expansion. It should be noted that two new ambient ammonia sensors will be installed during the current expansion. One will be located in the machine room expansion and the other will be located inside the new blast freezer. 9. Additional Mitigation Measures The RMPP review included an examination of the existing mitigation measures ~and a study of mitigation measures that might be required by the system upgrade. The review indicated that no additional mitigation measures are required at this time. PFI/RMPP/Feb., 1992 Page 6 of 7 Luft Environmental Consulting lO.Management of Change The BCFD requested that a fOrmal method for managing changes to the RMPP be included in the revised RMPP to ensure that items suCh as piping, and instrumentation diagrams are kept current. Management of change for the RMPP supporting document is not specifically required by the statute. Also, PFI currently has an extensive record keeping program in place. However, the management at PFI recognizes the potential,'~ benefits of such a program and will implement a formal management of change/~ program for the revised RMPP supporting document. Il.Operating and Maintenance Procedures Operating and maintenance procedures were not specifically addressed at the meeting. However, the addition of new equipment requires a review of operating,. maintenance, and training procedures at the plant. These procedures will be revised by PFI to ensure adequacy in light of the new equipment. Representatives from Preston Refrigeration Company, will be on site during installation and start-up of the refrigeration system. PFI operations and maintenance personnel will be actively involved in the installation and start-up of the new equipment. ;' Formal training in the operation and maintenance of the new equipment coupled with the on the job training associated with the start-up of both the original and new systems provide an excellent foundation for future, operation of this facility. PFI/RMPP/Feb., !992 Page 7 of 7 Luft Environmental Consulting Irem # 1 NH3 Equip: Fill Connections Guide Word No Less Reverse Deviation No Flow More Flow Less Row Reverse Flow PESTRITTo FOODS, INC.-HAZOP REVIEW SUMMARY REV. Possible Cause Consequence Fill valve closed or blocked Will relieve thru truck Safety valve fails Hose failure, truck pulls away without disconnecting Maximum flow through PSV Release contents of hose. Back check valve prevents ammonia leak from receiver Operator opens open-ended valve Max release thru orifice Partially plugged or blocked line Slow product transfer. Worst case, delivery system relieves back to truck. Delivery pump fails Flow could be back to delivery truck Comments Typical vendor truck recirculation system seffings are below 250 psig. Dead head pressure on typical vendor pump is 225 psig. PSV on NH3 receiver is set @ 300 psig. Delivery hoses are tested once per year at twice the receiver pressure or at least 500 psig. SG**-Relief system on vendors truck SG-Operater training **SG=Safeguard Very rare incident-PSV vent thru scrubber tank Back Check valve will be screwed into isolation valve on controlled pressure receiver during filling operation. SG-Truck is equipped with excess flow valve. SG-Back check valve installed on fill hose SG-SCBA on site for emergency response SG-Ambient ammonia monitor and engine room scrubber system. SG-Pestritto Foods personnel witness loading , SG-Operator Training SG-AII open ended valves are plugged or capped SG-Ambient ammonia monitor and engine room scrubber system. · SG-Operator Training No public consequence SG-Operator Training SG-Delivery truck relief system No public consequence SG-Back check valve on vendor's hose Page 1 of 11 II~m # .1 NH3 Equip. RII Connections (Cont.) Guide Word More Less Other Deviation More Pressure Less pressure PESTRI'I-FO FOODS, INC.-HAZOP REVIEW SUMMARY REV. 1 Possible Cause Consequence Comments Vendor tanker overfills receiver Additional compressors start up. If continued, compressors shut down on high discharge pressure or temperature There is sufficient gas volume in system to avoid hydraulicing vessels, if vessels ara not valved out (isolated) Worst case, PSV may lilt. Normal vendor pressure to fill tank is 120 to150 psig. Dead head press. is 225 psig. SG-Pesb'itto Maint. staff always witnesses loading. SG-Sight glass to observe level of NH3 SG-PSV relieve through scrubber tank SG-Operator Training Vendor truck pump failure - insufficient pressure No preduct transfer , No public consequence Truck hits valves (Not possible since valves are on bottom of receiver - receiver is isolated in building) Thermosyphon Receiver No More No Flow More Flow System idle, power outage Relief valve fails-lifts Opening emergency dump valve Opening of unplugged valves Sight glass failure Gauge failure System equalizes pressure Maximum flow threugh PSV Release to scrubber lank Max release through orifice Discharge until system can be isolated Discharge until system can be isolated No public consequence Very rare incident SG-Relief system vents to scrubber tank Emergency dump valve is located in a locked emergency refrigerant control box SG-Operator Training SG-AII open ended valves are plugged SG-Ambient sensor and engine room scrubber SG-Operator Training SG-Bullseye type sight glass is resistant to impaCt. SG-SCBA on site for emergency response SG-Operater Training SG-Ambient sensor and engine room scrubber SG-Gauges have isolation valves SG-Ambient sensor and engine room scrubber SG-SCBA on site for emergencY response SG-Operater Training · " Page 2 of 11 Item # NH3 Equip. Thermosyphon Receiver (Cont.) Guide Word Less More Less More PESTRI'I-rO FOODS, INC.-HAZOP REVIEW SUMMARY REV. 1 Deviation Possible Cause Less flow High pressure liquid line plugged or blocked Mom Pressure Overfilling Consequence Less cooling of the refrigerated rooms Compressors shut down on high discharge pressure/temperature Additional cempressors start up. If continued, compressors shut down on high discharge pressure or temperature There is sufficient gas volume in system. to avoid hydrauliclng vessels, if vessels are not valved out (isolated) Worst case, PSV may lift. Uquid ammonia trapped in oil ' cooler (valves closed on NH3 line). Less Pressure Compressor failures/shutdown More Temperature Evaporative condenser motor fails Failure can be fan motor or water recimulafion pump failure Rrein building Overpressure liquid ammonia pipe System equalizes pressures Compressor discharge does not condense. Thermostats still call for cooling. Compressors eventually shut down on high discharge head or high discharge temperature Ammonia refrigeration control panel can balance system pressures. Worst case, PSV relieves Less Less Temperature compressors malfUnction Less temperature means less pressure and less cooling duty. Comments Room temperatures are monitored closely~ Refrigeration problem would be detected rapidly. SG-High temperature/pressure shutdowns on compressors. Normal vendor pressure to fill tank is 120 to150 psig. Dead head press. is 225 psig. SG-Pestritto Maint. staff always witnesses loading. : SG-Sight glass to observe level of NH3 SG-PSV relieve through scrubber tank SG-Operator Training SG-Thermal relief valves installed on NH3 line. SG-Operator Training No public consequence SG-High head sh'ut down common to all compressors. SG-Two sots of fans on the evaporative condenser SG-High discharge ~emperature shutdown SG-Operator Training SG-Ammonia system emergency c(~ntrel panel SG-Operator Training SG-PSV vents through scrubber tank SG-Most of the building materials are nonflammable SG-ComPresser centrol panel alarms ' SG-Operator Training Room temperatures are monitored closely. Refrigeration problem would be detected rapidly. Page 3 of 11 Item # NH3 Equip. Thermosyphon Receiver (Cont.) Liq. Ammonia line Guido Word Deviation PESTRI'n'o FOODS, INC.-HAZOP REVIEW SUMMARY REV. 1 Possible Cause Consequence Comments Mom More Composition Leak in compressor oil cooler Ammonia in oil system. Compressors may shut down on Iow oil pressure or high oil temperature. More More Level Less Less Level Level pilot sensor failure/high pressure liquid line blocked or plugged Evaporative condenser failure Compressor discharge not condensing Receiver fills with liquid, may lose some of the refrigeration capacitY where the liquid ammonia would have been in service. May shut down compressor on high discharge pressure/temperature Without condensation, pressure builds. Compressors shut down on high discharge temperature or pressure. Level conb'oller fails Liquid ammonia to controlled pressure receiver. Receiver has plentY of capacity Other Maintenance Draining oil No NO Flow Une blocked, or isolated Oil will be drained through the oil pot (vs. draining oil through a valve on the vessel) If liquid NH3 line, pressure would increase in line due to liquid expansion More ' More Flow Power failure Leak in pipelines, valves Compressor seal leak System equalizes to 80 - 100 psig , Pischam_e to machine room or outside air Low volume leaks, odor easily detected SG-Ambient sensor in engine room and automated scrubber system SG-SCBA on sight for emergency response SG-Operator Training SG-Operator Training SG-High discharge temperature shutdown Room temperatures are monitored closely. Refrigeration problem would be detected rapidly. SG-High discharge temperature shutdown SG-Operator Training SG-High head shut down common to all compressors. SG-Controlled pressure receiver capacitY. SG-Operator Training SG-Level Eyes SG-Operator Training SG-Oil drain pot designed to drain oil. SG-Operator Training SG-Pipelines installed per ANSI/ASME 31.5 SG-Ambient sensor in engine room and automated scrubber system SG-SCBA on site for emergency response Would require several valves to be closed simultaneously in order to isolate this line. No public consequence SG-Ambient sen .sot in engine room and automated scrubber system SG-SCBA on site for emergency response SG-Operator Training Page 4 of 11 ~m # 3 NH3 Equip. Uq. Ammonia line (Cont.) Shell and tube heat exchanger (Glycol chiller) Guide Word More Less More No More Less Deviation More Flow Less FIow More Pressure No Row More Flow Less Flow PESTRI'i-i'O FOODS, INC.-HAZOP REVIEW SUMMARY REV. 1 Possible Cause Pipe failure Consequence Ammonia release to machine room or outside corresponding to size of ooenina Worst credible case, liquid phase release Une blocked or dosed Less cooling capacity for freezers Liquid line is isolated (blocked on both ends) with line full of liquid ammonia Could rupture line. Release contents of line into engine room Heat exchanger isolated Failure of solenoid valve for NH3 supply Power failure "Rooded' type heat exchanger could trap liquid ammonia. Normal gas volume will accomodate liquid ammonia expansion. Gas volume controlled by level control boot Compressor suction would empty NH3 from heat exchanger. Loss of refrigeration capacity. System equalizes to 80 - 100 psig Solenoid failure Level switch failure Tube failure in heat exchanger Solenoid failure Level switch failure Higher heat exchange rate, glycol system pressure may increase if glycol freezes. Any excess NH3 entrained in gas stream would be removed by intercooler. Ammonia and glycol would be mixed and pumped through the system Could result in Iow release rate in glycol expansion lank. Glycol system warms up, less refrigeralJon duty. Page 5 of 11 Comments .SG-Pipalines installed per ANSI/ASME 31.5 SG-Ambient sensor in engine room and automated scrubber system SG-SCBA on site for emergency response SG-Oparator Training Room temperatures are monitored closely. Refrigeration problem would be detected rapidly. SG-Pipelines installed per ANSI/ASME 31.5 SG-Ambient sensor in engin® room and automated scrubber system SG-SCBA on site for'emergency response SG-Operatur Training Would require several valves to bo closed simultaneously in order to isolate this line. SG-PSV relieve through scrubber tank SG-Operator Training No public consequence No public consequence No public concem SG-Operator Training SG-High level alarm SG-Ambient sensor in engine room and automated scrubber system SG-SCBA on site for emergency response SG-Operator Training Room temperatures are monitored dossly. Refrigeration problem would be detected rapidly. Item # NH3 Equip. Guide Word Deviation PESTRI'ITO FOODS, INC.;HAZOP REVIEW SUMMARY REV. 1 Possible Cause Consequence Comments 6 Shell and tube heat exchanger (Glycol chiller) (Cont) Plate heat exchanger (Dough mixer) Controlled Pressure Receiver Moro Less Moro Less More Less Moro Less Moro Level Less Level More Flow Less Flow Moro Level Less Level More Flow Less Flow Solenoid failure Level switch failure Solenoid failuro Level switch failure Float switch failure, solenoid switch failuro Hole in heat exchanger Float switch failure, solenoid valve failure Solenoid failuro Level switch failure Solenoid failure Level switch failuro Float valve failure, pilot sensor failure ODenina emeroencv dumo v~,lve Float valve failure, pilot sensor failure Higher heat exchange rate, glycol system pressuro may increase if glycol freezes. Any excess NH3 enlrained in gas stream would be removed by intercooler. Glycol system warms up, less refrigeration duty. Uquid ammonia would overflow into the intercooler. Ammonia will enter process water and ruin dough batch. Less refrigeration duty available Higher heat exchange rate, glycol system pressure may increase if glycol froezes. Any excess NH3 entrained in gas stream would be removed by intercooler. Glycol system warms up, less refrigeration duty. Higher liquid level in roceiver. Receiver is sized to accomodate all liquid NH3. I:lelease to scrubber tank Less cooling of the refrigerated rooms compressors shut down on high discharge pressure/tern perature No public concern SG-Operator Training SG-High level alarm Room temperaturos are monitored closely. Refrigeration problem would be detected rapidly. No public consequence Would be discovered immediately in produc§on area. Ammonia would be absorbed in the process water, resulting in a slow release. SG-Operator Training. SG-SCBA on site for emergency response No public consequence No public condern SG-Operator Training SG-High level alarm Room temperatures are monitored closely. Refrigeration problem would be detected rapidly. No public consequence Emergency dumo valve is located in a locked emeraencv refriaerant control box SG~Ooerator Trainina No public consequence Page 6 of 11 Item # 6 NH3 Equip. Controlled ~ Pressure · Receiver (Cont:) ~ Ammonia Purger Intercooler Guide WOrd More. More Less Less More Less NO Deviation- More Pressure More Level Less Level More Flow Less Flow More Level Less Level No Flow PESTRrl-rO FOODS, INC.-HAZOP REVIEW SUMMARY REV. 1 Possible Cause Failure of pressure redUcing valve Float valve failure, pilot sensor failure C°nsequence Increased pressure in receiver. PSVs set higher than normal system operating pressure, therefore, release not likely. Higher liquidlevel in receiver. Receiver is. Sized to accomodate all liquid NH3. Comments sG-A'mbient sensor in engine room and automated scrubber system SG-SCBA on site for emergency resp(inse SG-Operator Training SG-PSV release t6 scrubber tank No public consequence .' Float valve failure, pilot sehsor Less cooling of the refrigerated rooms failure Compressors shut down on high discharge pressure/temperature Liquid NH3 solenoid valve fails open Excessive NH3 flow through purger' or float switch fails No public consequence NO public consequence ,Nr PUrge solenoid valve fails open or float switch fails Excess NH3 flows through water bubbler Low rate release into sewer SG-Flow is restricted with orifice SG-Operator training Watersolenoid valve fails closed Float switch failure Float switch/solenoid failure Ammonia flows into sewer line Low rate release into sewer ' SG-Flow is restricted With orifice SG-Operator training Ammonia relief check valve sends ammonia No public consequence to compressor suction Excessive purge cycle. Aqua ammonia to No public consequence sewer. Pipe blocked Power failure Suction regulator failure. System equalizes pressure No public consequence Page 7 of 11 Item # 8 NH3 Equip. Intercooler (Cont.) Guide Word More Less More Less More Less Deviation More Row Less Flow ' More Pre~ure Less Pressure More Level Less Level PESTRITTO FOODS, INC.-HAZOP REVIEW SUMMARY REV. 1 Possible Cause NH3 inlet solenoid valve fails open O~enina emeraencv dumo valve Consequence Comments Liquid level in intercooler rises. Activates No public consequence liquid dump cycle. Dumps to Iow suction SG-High level switch emergency shut down accumulator (LSA), I~SA dumps to controlled SG-Operator Training' pressure receiver. If dump cycle was not sufficient, emergency shut down on high liquid level in intercooler. Release to scrubber tank NH3 inlet solenoid valve fails closed. Booster compressor discharge does not Inlet line partially blocked, condense. Hot gas to high stage control boot isolated Emergency dumo valve is located in a locked {,~rne _rgency refrigerant control box SG-Compressor shut down controls SG-Operator Training compressor, compressor shut down on high discharge temperature or pressure NH3 inlet solenoid valve fails open Malfunctioning cOmpressor NH3 inlet solenoid valve fails open Liquid level in intercooler rises. Activates No public consequence liquid dump cycle. Dumps to Iow suction SG-High leval switch emergency shut down accumulator (LSA), LSA dumps to controlled SG-Operator Training pressure receiver. If dump cycle was not sufficient, emergency shut down on high liquid level in intercooler. Less refrigeration capacity No public consequence Liquid level in intercooler rises. Activates No public consequence liquid dump cycle. Dumps to Iow suction SG-High level switch emergency shut down accumulator (LSA), LSA dumps to controlled SG-Operator Training pressure receiver. If dump cycle was not sufficient, emergency shut down on high liquid level in intercooler. control column isolated and Iow Intercooler can hold entire thermal syphon No public consequence level float switch is activated · receiver charge. SG-Operator Training NH3 inlet solenoid valve fails closed. Booster compressor discharge does not Inlet line partially blocked, condense. Hot gas to high stage Control boot isolated compressor, compressor shut down on high discharge temperature or pressure SG-Compressor shut down controls SG-Operator Training Page 8 of 11 NH3 Equip. Low Suction Accumulator Guide Word No More Less Reverse More Less More Less Deviation No Flow More Flow Le~ flow Reverse Row More Pressure Less Pressure More Level Less Level PESTRrI-I'O FOODS, INC.-HAZOP REVIEW sUMMARY REV. 1 · Possible Cause Consequence Comments Une blocked, system isolated See more level-lntercooler SG-Operator Training Power outage solenoid valve from interCOOler fails in open position System pressure equalizes No public consequence Liquid ammonia flows into dump traps. If SG-High level emergency shut down dump traps do not operate fast enough, high SG-Dump haps liquid level switch will operate emergency ' SG-Operator Traini.ng shut down. Ooenind emem_ency dump valve Hand expansion valve improperly set, plugged line Check valve on Phillips dump fails Release to scrubber tank See more level-lntercooler Cold storage temp will rise Second Phillips dump works more often. Worst case, ESD on high liquid level. Emergency- dumo valve is Ioceted in a locked emerg_ency refrigerant centrol box SG-Ooerator Trainina SG-Operator Training Would be discoVered quickly No public consequence SG-High level emergency shut doWn SG-Operator Training Inlet to compressor closed Pressure.increase in refrigerant return lines. SG-Operator Training Refrigeration system performance decrease= SG-PSV release to scrubber tank Worst case, PSV lifts Normal operation Check valve on Phillips dump fails Second Phillips dump works more often. Worst case, ESD on high liquid level. No public consequence SG-High level emergency shut down SG-Operatol~ Training Normal operation 10 Evaporators No No Flow Une blocked or isolated Operator error ~=ower failure Pressure increase in refrigerant retum lines. SG-Operator Training Refrigeration system performance decreases System equalizes to 80 - 100 psig No public consequence Page 9 of 11 Item # 10 11 NH3 Equip. Evaporators (Cont.) Compms~rs PESTRI'i-I'O FOODS, INC.-HAZOP REVIEW SUMMARY REVi 1 Guide Word Deviation Possible Cause More More Flow Evaporator leak More More pressure Less Less Flow Line blocked, system isolated Operator error Malfunctioning solenoid valve Hand expansion valve improperly set No No Flow Power failure Consequence Release to holding freezer Belease to soiral freezer Release to ante room Comments SG-SCBAs on site for emergency response SG-Evacuation plan SG-Operato[ training High level in intercooler or Iow More More Flow Discharge line failure Less refrigeration capacity. Worst case, ammonia expansion bursts evaporator and. releases contents of evaporator to holding freezer, soiral freezer, or ante room Cold storage temperature will dso System equalizes pressure SG-Operator Training SG-SCBA on site for emergency response WOuld be discovered quickly, No public consequence Less More System eaualizes oressure No oublic conseouence Release to enaine mom or outside. SG-Pipalines installed per ANSI/ASME 31.5 Maximum release is compressor throughput. SG-Ambient sensor in engine room and automated scrubber system SG-SCBA on site for emergency response SG-Operator training Less Flow Suction regulator closes Loss of refrigeration capacity No public consequence More Pressure Discharge not condensing DiSCharge valve dosed or blocked Less Less Pressure C0mpressor failure More More Temperature Oil cooler malfunction Compressor discharge does not condense. Compressors eventually shut down on high discharge head or high · discharge temperature System shuts down on high pressure ' Loss of refrigeration capacity Compressor shut down on high oil temperature SG-High head shut down common to all compressors. SG.Two sets of fans on the evaporative condenser SG-High discharge temperature shutdown SG-Operator Training ' No public consequence SG-Operator Training SG-High pressure shut down switch No'public consequence No public consequence SG-Oparater Training SG-High oil temperature shut down switch SG-High discharge temperature shutdown Page 10 of 11 Item # NH3 Equip. Guide WOrd ~ N....~o Control Panel More PESTRrl-rO FOODS, INC.-HAZOP REVIEW SUMMARY REV. 1 Deviation Possible Cause No Row Normal o~erafion More Flow Ememency Dumo valves ooened Conseq~n~ Release to scrubber tank. Pipe' ruoture due to vehicle impact. Release to outside environment. More Pressure Pressure rise in ammonia vessel. Possible PSV release to scrubber tank More Temoerature See more oressure Possible PSV release to scrubber tank Comments Emergency ooemfion only. SG-Ooerator Trainina SG-Contml box is locked. ~(~-Vehicle barriers. Ho oublic conseauence. Ho oublic conseauence. Page 11 of 11 FIRE DEPARTMENT S. D. JOHNSON FIRE CHIEF CITY of BAKERSFIELD "WE CARE" February 6, 1992 2101H STREET BAKERSFIELD, 93301 326-3911 Dave Smreker Preston Refrigeration Co. 3241 N. 7th Street Kansas City, KS 66115 Mr. Smreker: Bakersfield Fire Department'Hazardous Materials Division has completed review of prints # 2017-R1,2,3 dated 12-31-91 for the expansiOn of the ammonia refrigeration system at Pestritto Foods~ In general the plans appear satisfactory, however there are several conditions which must be met regarding the installation of the valves and piping. Ail piping utilized for the transmission of anhydrous ammonia · shall have welded or brazed connections throughout. [UFC 80.401(c)3A] All pressure relief valves shall be vented to the ammonia absorption system. [UFC 80.401(K)3 With inclusion of the conditions stated above, these plans have been approved. Please ~contact us at (805) 326-3979 to schedule an inspection prior to operation of the new refrigeration system. Sincerely, // / R~lph Huey Hazardous Materials Coordinator Barbara Brenner Hazardous Materials Planning Technician cc: A1 Sautner Risk PESTRITTO FOODS RISK MANAGEMENT & PREVENTION PROGRAM TRAINING Manaqement and Prevention Proqram (RMPP) ' - Ail of the administrative and operational programs of a business which are designed to prevent acutely hazardous materials accident risks, including, but not limited to, programs which examine the design safety of new and existing equipment, standard operating procedures, preventative maintenance programs, operator training and accident investigation procedures, risk assessment and emergency response planning. Anhydrous ammonia is the acutely hazardous material for which Pestritto FOods was required to p~epare a RMPP. PRINCIPLES OF AMMONIA REFRIGERATION a). Equipment and piping b) Phase of ammonia & system pressures c) Isolation of system components II. ARTICLES 80 & 63 OF THE UNIFORM FIRE CODE a) Requirements for use.and storage of a toxic gas b) 'Pestritto's compliance with Article 80 c) Pestritto's compliance with Article 63 III. RMPP DATA CONTAINED INTHE HAZARDOUS MATERIALS BUSINESS PLAN a) Release containment b) Offsite consequences c) Inhouse capabilities d) Plant shutdown and emergency system operation instructions IV. OPERATION OF PESTRITTO'S AMMONIA DIFFUSION AND VAPOR SCRUBBING SYSTEM a) Compressor shutdown b) Operation of the king valve c) Balancing the pressure between the high and low sides d) Ammonia diffusion system operation e) Manual override of automatic scrubber system f) Shutdown of pOwer to the plant ILOwsucTION ACCUMULATORi t . · LINE · ~ ° o 4 PSIG ~ ITHERMOSYP.Oi~ e3e0ePSla i I_ RECEIVER  · · CONTROLLED · · PRESSURE ~,~ · · RECEIVER COOh~R--->[ ~2q PSIG. . ~ ~ ~ HEAT EXCHANGERS ,, FLOODED EVAPORATORS LIQUID AMMONIA = AMMONIA VAPOR SUCTION COMPRESSED GAS PESTRITTO FOODS AMMONIA REFRIGERATION SYSTEM 12/03/91 PESTRITTO FOODS INC 215~O00-~0427 00 - Overall S. it~.-~ <H> RMPP DATA Page 9 <1> Release Containment 1) AUTOMATED SCRUBBER SYSTEM WILL ABSORB AMMONIA RELEASES FROM THE ENGINE ROOM. AMMONIA CONCENTRATIONS OF 200 PPM ACTIVATE THE SYSTEM WHICH EXHAUSTS AIR FROM THE ENGINE ROOM INTO THE EVAPORATIVE'CONDENSER. WATER FROM THE EVAPORATIVE CONDENSER iS THEN CIRCULATED WITH THAT IN THE AMMONIA DIFFUSION SYSTEM WATER STORAGE TANK. MANUAL OVERRIDE INSTRUCTIONS BELOW IN SECTION 4. 2) AMMONIA DIFFUSION SYSTEM MAY BE USED TO BALANCE PRESSURE BETWEEN THE HIGH AND LOW PRESSURE. SIDES OF THE REFRIGERATION SYSTEM. ENTIRE AMMONIA CHARGE MAY BE DIFFUSED INTO WATER STORAGE TANK. SEE OPERATIONAL INSTRUCTION BELOW IN SECTION 4. ........ G THE 4~2F~. CLOSURE OF THE KING VALVE WITH COMPRESSORS RUNNING WILL PUMP AMMONIA INTO RECEIVERS. COMPRESSORS WILL SHUT DOWN AUTOMATICALLY IF HIGH 'TEMPERATURES OR PRESSURES ARE EXPERIENCED. 4) AMMONIA PIPING THROUGH POPULATED AREAS OF THE PLANT INTERIOR IS MINIMAL. SOLENOID VALVES ARE DESIGNED TO CLOSE UPON SYSTEM SHUTDOWN'ISOLATING LINES THAT ENTER THE PLANT. AMMONIA RELEASES WITHIN THE BUILDING ARE EXPECTED TO BE.MINIMAL FOLLOWING SHUTDOWN OF THE REFRIGERATION SYSTEM. 5) PRESSURE RELIEF.VALVES ARE VENTED INTo THE AMMONIA DIFFUSION WATER TANK. <2> Offsite Consequences 1) RELEASE EVENT MODELED USING CAMEO: 3 INCH LIQUID AMMONIA LINE FAILURE, LINE FROM CONTROLLER PRESSURE RECEIVER. WEATHER'CONDITIONS: DAYTIME, WINTER' 40 DEGREES F, WIND = 5 MpH ,~ ATMOSPHERIC STABILITY CLASS C. 500 PPM AMMONIA PLUME PREDICTED TO EXTENT 1338 FEET 50 PPM AMMONIA PLUME PREDICTED TO EXTEND 1.0 MILES 2) THIS MODEL ASSUMES THAT 361 POUNDS AMMONIA IS RELEASED AS VAPOR AND THAT 4001 POUNDS EVAPORATES FROM A 1000 SQUARE FOOT POOL OVER 30 MINUTES. A LARGER VAPOR'RELEASE WOULD CAUSE A LARGER DOWNWIND AMMONIA PLUME. NIGHT TIME WEATHER CONDITIONS WILL ALSO CAUSE INCREASED PLUME SIZE. 3) RELEASES'WITH'IN THE ENGINE ROOM SHOULD BE MITIGATED BY THE SCRUBBER SYSTEM. <3> In House'Capabilities PLANT MANAGER WILL DIRECT IN HOUSE EMERGENCY REsPONsE. PLANT PERSONNEL ARE TRAINED IN THE USE OF SCBA/PROTECTIVE CLOTHING-AND MITIGATION OF AMMONIA-RELEASES FROM THIS REFRIGERATION SYSTEM. PESTRITTO FOODS INC 215-000-000427' 00 - Overall Site ' <H> RMPP DATA Page 10. <3> In House Capabilities (Continued) / 2 SCBA AND 2 LEVEL A RESPONSE SUIT ON SITE FOR USE BY PLANT EMERGENCY RESPONSE PERSONNEL. PLANT STAFFED; 24 'HRS/DAY MON.-FRI., 10 HRS DURING THE DAY ON SATURDAY, UNATTENDED ON SUNDAY~oN~ <4> Plant Shutddwn Instruction · ~ 1) POWER TO EMERGENCY AMMONIA SYSTEMS IS WIRED TO MAIN SOURCE AHEAD OF DISCONNECT FOR POWER TO THE REST OF THE PLANT. PLANT POWER SHUTDOWN SHOULD NOT AFFECT OPERATION OF SCRUBBER. 2)' OPERATION INSTRUCTIONS - EMERGENCY.CONTROL BOX. KEYS TO EMERGENCY CONTROL BOX ARE IN THE LOCK BOX. LOCK BOX IS LOCATED ABOVE THE SPRINKLER SYSTEM CONNECTIONS ON SOUTH SIDE 'OF THE BUILDING. STEP 1: TURN VENTILATION SWITCH ON (S-2) & EVALUATE THE PROBLEM IN THE SYSTEM. IF PROBLEM 'IS IN THE LOW SIDE, DO NOT PUSH EMERGENCY SHUTDOWN SWITCH (S-l). IF PROBLEM IS IN THE HIGH SIDE OF THE SYSTEM, PUSH EMERGENCY SHUTDOWN SWITCH (S-l). STEp 2: OPEN VALVE NO. 3 & USE THE GAUGES TO MAINTAIN THE PRESSURE ON THE LOW SIDE OF THE SYSTEM.BELOW 140 PSIG. VALVE NO. 3 - DISCHARGE VALVE TO WATER DIFFUSER TANK (LOW PRESSURE SIDE OF SYSTEM). STEP 3: OPEN VALVE NO. 1 & use THE GAUGES TO MAINTAIN THE PRESSURE ON THE HIGH SIDE OF THE SYSTEM BELOW 200 PSIG. ~ VALVE NO. 1 - DISCHARGE VALVE TO WATER.DIFFUSER TANK (HIGH PRESSURE SIDE OF SYSTEM). NOTE: STEP 4: AMMONIA FROM THE HIGH SIDE TO THE LOW SIDE OF THE SYSTEM. OPTION IF'DESIRED NOTIFY QUALIFIED PERSON BEFORE PROCEEDING WITH THIS STEP. AL SAUTNER (805) '833-1397 (805) ~98-2685 LEO VADNAIS (805) 836-0995 (805) 398-2684 STAN BRYAN '(805) 393-4725 (805) 398-2693 AMMONIA TRANSFER WITHIN SYSTEM. OPEN VALVE NO. 2 TO TRANSFER EMERGENCY SWIT'CHS: SWITCH NO. 1 (S-l) "EMERGENCY REFRIGERATION SHUTDOWN" SWITCH. THE ENTIRE REFRIGERATION SYSTEM. SWITCH NO. 2 (S-2) "EMERGENCY VENTILATION" SWITCH. SHUTS OFF TURNS ON THE EXHAUST q%.O° -/ ~i2/Q3/91 / PE~q~RITTO FOODS INC ~215-000-0~04 00 -.Overall Site <H> RMPP DATA 27 Page 11 <4> Plant Shutdown, Instruction. (Continued) SWITCH NO. 3 (S-3) "HORN/SILENCE" sWITCH. SCRUBBER SYSTEM IS OPERATING. SILENCE ALARM HORN WHILE SWITCH NO. 4 (S-4) "MANUAL SCRUBBER SYSTEM" SWITCH. OPERATES THE AMMONIA SCRUBBER 'SYSTEM. "HAND-OFF-AUTO" SWITCH NORMALLY IN THE AUTO POSITION UNLESS MANUAL OPERATION IS NEEDED. PESTRITTO FOODS RISK MANAGEMENT & PREVENTION PROGRAM TRAINING Risk Manaqement and Prevention Proqram (RMPP).' - Ail of the administrative and operational pro~rams of a business which are designed to prevent acutely hazardous materials accident risks, including, but not limited to, programs which examine the design safety of new and existing equipment, standard operating procedures, preventative maintenance programs, operator training and accident investigation procedures,' risk assessment and emergency response planning. Anhydrous ammonia is the acutely hazardOus material for which Pestritto Foods was required to p~epare a RMPP. I.. PRINCIPLES OF AMMONIA REFRIGERATION a) Equipment and piping b). Phase of ammonia & system pressures .c) isOlation of'system components ? ARTICLES 80 & 63 OF THE UNIFORM FIRE CODE a) Requirements for use and storage of a toxic gas b) Pestritto's compliance with Article 80 c) Pestritto's compliance with Article 63 III. RMPP DATA CONTAINED IN THE HAZARDOUS MATERIALS BUSINESS PLAN a) Release containment b) Of~site 6onsequences c) Inhouse capabilities d) Pl'ant shutdown and emerc instructions iency system operation OPERATION O~ PESTRITTO'S AMMONIA DIFFUSION AND VAPOR SCRUBBING SYSTEM a) ,Compressor shutdown b) Operation of the~king v~lve c) Balancing the pressure between the high and low sides d) Ammonia diffusion system operation e) Manual override of automatic sCrubber system f) Shutdown of power t° the plant, 4 PSIG FLOODED EVAPORATORS LOW sUCTION~! ACCUMULATOR ~ 'o · CONTROLLED ~ · · PRESSURE ~ · · RECEIVER ~ . ~ · · . ~ ::::::::::::::::::::: · · · · . ,,~,.~,.,~ R E S.~..., ,t, · ':~:~:~"~:~:~:~:~:~:~:~:~:~:~"~ ' , ~'o~'~'~,---~ ~,,~s-,~i .' ..... PESTRITTO FOODS LIQUID AMMONIA AMMONIA VAPOR SUCTION COMPRESSED GAS AMMONIA REFRIGERATION SYSTEM PESTRITTO FOODS INC .215-000-000427 00 - Overall Site <H> RMPP DAT~ ...... Page <1> Release Containment · 1~) AUTOMATED SCRUBBER SYSTEM WILL ABSORB AMMONIA RELEASES FROM THE ENGINE ROOM. AMMONIA CONCENTRATIONS .OF 200, PPM ACTIVATE TH~ SYSTEM WHICH EXHAUSTS AIR FROM THE ENGINE ROOM INTO THE'EVAPORATIVE CONDENSER. WATER FROM THE EVAPORATIVE CONDENSER IS THEN CIRCULATED WITH THAT IN THE. AMMONIA DIFFUSION. SYSTEM WATER STORAGE TANK. MANUAL OVERRIDE INSTRUCTIONS' BELOW IN SECTION 4. 2) AMMONIA DIFFUSION SYSTEM MAy BE USED TO BALANCE PRESSURE .BETWEEN THE HIGH AND'LOW PRESSURE SIDES OF THE REFRIGERATION SYSTEM. ENTIRE AMMONIA CHARGE MAY. BE DIFFUSED INTO WATER STORAGE TANK. 'SEE OPERATIONAL INSTRUCTION BELOW IN SECTION'4. 3) KING VALVE IS LOCATED IN THE ENGINE ROOM ON THE AMMONIA LIQUID LINE. FEEDING THE PLANT. 'CLOSURE OF THE KING VALVE'WITH COMPRESSORS RUNNING WILL PUMP AMMONIA INTO.RECEIVERS. COMPRESSORS WILL SHUT DOWNAUTOMATICALLY IF HIGH TEMPERATURES OR PRESSURE~ ARE EXPERIENCED. -. 4) AMMONIA PIPING THROUGH POPULATED AREAS OF THE PLANT INTERIOR IS MINIMAL. SOLENOID VALVES ARE DESIGNED TO CLOSE UPON'SYSTEM SHUTDOWN ISOLATING LINES THAT ENTER THE PLANT. AMMONIA RELEASES'WITHIN THE BUILDING ARE EXPECTED TO ~'BE MINIMAL FOLLOWING SHUTDOWN OF THE REFRIGERATION SYSTEM. 5) PRESSURE RELIEF VALVES ARE 'VENTED INTO THE AMMONIA DIFFUSION WATER TANK. <2> Offsite Consequencesi 1) RELEASE EVENT MODELED USING CAMEO: '3 INCH LIQUID AMMONIA'LINE FAILURE, LINE FROM CONTROLLER PRESSURE RECEIVER. WEATHER CONDITIONS: DAYTIME, WINTER'- 40 DEGREES F, WIND =. 5 MPH 'ATMOSPHERIC STABILITY CLASS C. 500 PPM AMMONIA PLUME PREDICTED TO EXTENT 1338 FEET 50 PPM AMMONIA PLUME PREDICTED TO EXTEND 1.0 MILES 2) THIS MODEL ASSUMES THAT 361 POUNDS AMMONIA IS RELEASED AS VAPOR AND THAT 4001 POUNDS EVAPORATES FROM A 1000 SQUARE FOOT POOL OVER 30 MINUTES. A LARGER.VAPOR RELEASE WOULD CAUSE A LARGER DOWNWIND AMMONIA PLUME. NIGHT TIME'WEATHER CONDITIONS WILL ALSO CAUSE INCREASED PLUME SIZE. 3) RELEASES WITHIN THE ENGINE ROOM SHOULD BE MITIGATED BY THE SCRUBBER SYSTEM. <3> In House CaPabilities PLANT MANAGER WILL DIRECT IN HoUsE EMERGENCY RESPONSE. PLANT PERSONNEL ARE TRAINED IN THE USE OF SCBA/PROTECTIVE CLOTHING AND MITIGATION OF AMMONIA RELEASES FROM THIS REFRIGERATION S~STEM. PESTRITTO FOODS INC 215-000-000427 00 -'Overall Site <H> RMPP DATA Page <3> In House Capabilities (Continued) 2 SCBA AND 2 LEVEL A RESPONSE SUIT oN SITE FOR USE BY PLANT EMERGENCY RESPONSE PERSONNEL. PLANT STAFFED; 24 HRS/DAY MON.-FRI., 10·HRS DURING THE DAY ON SATURDAY, UNATTENDED ON SUNDAY. <4> Plant'Shutd6wn Instruction 1) POWER TO EMERGENCY AMMONIA SYSTEMS IS'WIRED TO MAIN SOURCE AHEAD OF DISCONNECT FOR POWER TO THE REST OF THE PLANT. PLANT POWER SHUTDOWN SHOULD NOT AFFECT OPERATION OF SCRUBBER. 2) OPERATION INSTRUCTIONS - EMERGENCY CONTROL BOX. KEYS TO EMERGENCY CONTROL BOX ARE IN THE LOCK BOX. LOCK BOX IS LOCATED ABOVE THE SPRINKLER SYSTEM CONNECTIONS ON SOUTH'SIDE OF THE BUILDING. ~ STEP 1: TURN VENTILATION SWITCH ON (S-2) & EVALUATE THE PROBLEM IN THE SYSTEM. IF PROBLEM IS IN THE LOW SIDE, DO NOT PUSH EMERGENCY SHUTDOWN SWITCH (S-l). IF PROBLEM IS IN THE HIGH SIDE OF THE SYSTEM, PUSH EMERGENCY SHUTDOWN SWITCH (S-l). STEP 2: ·OPEN VALVE NO. 3 & USE THE GAUGES TO MAINTAIN THE PRESSURE ON THE LOW SIDE OF THE SYSTEM~BELOW 140 PSIG. VALVE NO. 3 - DISCHARGE VALVE TO WATER DIFFUSER TANK (LOW PRESSURE SIDE OF SYSTEM). STEP 3: OPEN VALVE NO. 1 & USE THE GAUGES TO MAINTAIN THE PRESSURE ON THE HIGH SIDE OF THE SYSTEM BELOW 200 PSIG. VALVE NO. 1 - DISCHARGE VALVE TO WATER DIFFUSER TANK (HIGH PRESSURE SIDE OF SYSTEM). NOTE: OPTION IF DESIRED NOTIFY QUALIFIED PERSON BEFORE PROCEEDING WITH THIS STEP. AL SAUTNER LEO VADNAIS STAN BRYAN (805) 833-1397 (805) 836-0995 (805) 393-4725° (805) 398-2685 (805) 398-2684 (805) 398-2693 STEP 4: AMMONIA TRANSFER WITHIN SYSTEM. OP~.N VALVE NO. 2 TO TRANSFER ' · AMMONIA FROM THE HYGH SIDE TO THE LOW SIDE OF THE SYSTEM. EMERGENCY SWITCHS: SWITCH NO. 1 (S-l) "EMERGENCy REFRIGERATION SHUTDOWN" SWITCH. THE ENTIRE REFRIGERATION SYSTEM. SHUTS OFF SWITCH NO. 2 (S-2) "EMERGENCY VENTILATION" SWITCH. TURNS ON THE EXHAUST PESTRITT0 FOODS INC -215~000-000427 00 - Overall Site <H> RMPP DATA Page <4> Plant Shutdown Instruction (Continued) FAN. · SWITCH NO. 3 (S-3) "HORN/SILENCE" SWITCH. .SCRUBBER SYSTEM IS OPERATING. SILENCE ALARM HORN WHILE SWITCH. NO. 4 (S-4) "MANUAL ,SCRUBBER SYSTEM" SWITCH. OPERATES THE AMMONIA SCRUBBER SYSTEM. "HAND-OFF-AUTO" SWITCH NORMALLY IN THE AUTO POSITION UNLESS MANUAL OPERATION IS NEEDED. + . LINE : · · · ITHERM(~SYPHOI~I 30 PSIG X : |.~c~,w. -l..: -.-. · · - FLOODED EVAPORATORS · + · · ' · · · · - · i >:" ':' A ] · ~e CONTROLLED $ · · PRESSURE , ~ · · 'RECEIVER · · RES · · · · · LIQUID AMMONIA i HEAT EXCHANGERS · ~ ' ..... : ..... ' ...... ;;'-_-:v:-_-,-_-~ PESTRITTO FOODS AMMONIA VAPOR SUCTION COMPRESSED GAS ~ AMMONIA REFRIGERATION SYSTEM 180 PSIG ~ ~-~,,, C-,, ~: · LINE · ,5 · · e · , · · o ' O ~HERMOSYPHO~ 30~SIG [ -r-. 0 · · · ~' ~ · '0 · · eee II~OW SUCTI0~i O · ,e . · FLOODED EVAPORATORS · · · :1~.~o~ ~1 t . . · · · · · ~ · · CONTROLLED ' i ' · · ~RESSURE ~ · · ~'~IVER o o · · LIIJUID. AMMUI~IIA AMMONIA VAPO~ SUCTION COMPRESSED GAS PESTRITTO FOODS AMMONIA REFRIGERATION SYSTEM 4 PSIG sUd~ioN~] UMULATOR INTER '180 PSIG 4 PSlG o; 'O', HEAT EXCHANGERSi ., 'HEAT EXCHANGERS Tri Com Refrigeration, Inc. INSTRUCTIONS FOR E'.MERGENCY CONTROL BOX J INSTRUCTIONS FOR FIRE DEPARTMENT USE Step 2 Step 3 ' Step 4 'EMERGENCY SWITCHES Step 1~ Turn ventilation switch on (S-2) & evaluate'the problem in the system. If problem is in the low. side( do not'push emergency shutdown switch (S-i). If problem is in the high side of the system, push emergency shutdown switch (S-l). : Open valve No. 3 & use the gauges to maintain the pressureon the low side of the system below 140 psig. Valve'No. 3- Discharge valve'to water diffuser tank (low pressure side of System) Open valve No. 1 & use the gauges to maintain the pressure on the high Side of the system below 200 psig. /Valve No. I - Discharge valve to water diffuser tank (high pressure side of system) ' Note: Option if desired Notify qualified person before proceeding with this step. HOME PAGER A1 Sautner (805)833-1397 (805)398-2685 Leo Vadnais (805)836-0995 (805)398-2684 Start Bryan (805)393-4725 (805)398-2693 Ammonia transfer within system. Open valVe No. 2 to transfer. ammonia from the high side to the low side Of'the system. Switch No..1 (S-l) "Emergency Refrigeration Shutdown" switch off the entire refrigeration system. ' Shuts Switch No. 2 (S-2) "Emergency Ventilation"' switch. Turns on the" , ~/'i! , exhaust fan. "?-Switch No. 3 (S-3) "Morn/Silence" switch. Silence alarm horn while scrubber system is operating. · Switch No. 4 (S-4) "Manual Scrubber System,,.switch. Operates. the ammonia scrubber system. "Hand-Off-Auto" switch normally in the AUT° position unless manual operation is needed. 11909 E. Telegraph Road · P.O. Box 3866 · Santa Fe Springs, CA 90670 · (213) 948-3861 / FAX: (213) 949-8249 · Ucense # 461823 B-1, C-38 INDUSTRIAL REFRIGERATION AND COLD STORAGE SPECIAL STS FIRE DEPARTMENT S. D. JOHNSON FiRE CHIEF CITY of BAKERSFIELD "WE CARE" October 8, 1991 2101 H STREET. BAKERSFIELD, 93301 326-3911 Mr. Larry Wueth~ich Pestritto Foods Inc. p.O. Box 328 BlackwOod, NJ 08012 ~Dear Mr. Wuethrich, I have completed review of the Risk Management and Prevention Program (RMPP) regarding the use of anhydrous ammonia at Pestritto's Bakersfield facility located at 6800 McDivitt Dr. The RMPP supporting document prepared by Luft Environmental Consulting is,complete in scope and coverage. Therefore, this RMPP has been iapproved by Bakersfield Fire, Hazardous Materials Division. This RMPP must be fully implemented before operations begin at this facility.. Bakersfield Fire will inspect your facility at least once every three years to verify compliance with the program proposed in the RMPP. Please cai1 me at 326-3979 anytime that I can be of assistance in hazardous materials planning. _~i?cerely ,~--~ . . Barbara Brenner Hazardous Materials Planning Technician CC: Ralph Huey Karl Luft LUFT ENVIRONMENTAL CONSULTING 3701 PegasUs Drive, Suite 121 · Bakersfield, California 93308 · (805) 399-5838 June 28, 1991 Barbara Brenner Hazardous Materials Planning Technician Bakersfield City Fire Department 2101 "H" Street Bakersfield, CA 93301 RECEIVED JUL 0 2 1991 HAZ. MAT. OtV. Ms. Brenner: Enclosed for your review is a confidential draft of the Hazard and Operability (HazOp) matrix for Pestritto Foods Inc.'s 'RMPP. In order to maintain Pestritto's start up schedule, we are currently proceeding with the development of the HazOp study report and RMPP documentation. If you have any questions concerning the enclosed, please contact me at your convenience. Kad W. Luff Principal Mechanical Engineer Larry Wuethdch- Pestdtto Foods, Inc. Larry Rolison - Td-Com Refrigeration Inc. LEC-91-0221 PFc01 FIRE DEPARTMENT S.D. JOHNSON · FIRE CHIEF CITY of BAKERSFIELD · . "WE CARE" February 6, 1992 A1 Sautner' Plant Manager Pestritto Foods 6800 .McDivitt Dr. Bakersfield, CA 93313 2101H STREET BAKERSFIELD, 93301 326-3911 Mr. Sautner: Enclosed is a copy of the conditional approval of the plans for the expansion.of Pestritto's ammonia refrigeration system. As you are aware, Pestritto's Risk Management and Prevention Program must be modified tO reflect the additions to the system. I have also enclosed a formal request for these modifications. The Acutely Hazardous Materials Registration Form which I gave you today at our meeting must be filed prior to the start up of operations. Please give me a call if you have questions regarding any of these requirements. Barbara Brenner Hazardous Materials Planning Technici. an cc: Ralph Huey CITY of BAKERSFIELD "WE CARE" FIRE DEPARTMENT S.D. JOHNSON FIRE CHIEF February 6, 1992 2101H STREET BAKERSFIELD, 93301 326-3911 Dave Smreker Preston Refrigeration Co. 3241N. 7th Street Kansas City, KS 66115 Mr. Smreker: Bakersfield Fire Department Hazardous Materials Division has completed review of prints # 2017-R1,2,3 dated 12-31-91 for the expansion of the ammonia refrigeration system at Pestritto Foods. In general the plans appear satisfactory, however there are several conditions which must be met.regarding the installation of the valves and piping. All piping utilized for the transmission of anhydrous ammonia shall have welded or brazed connections throughout. [UFC 80.401(c)3A] All pressure relief valves shall be vented to the ammonia absorption system. [UFC 80.401(K)3 With inclusion of the conditions stated above, these plans have been approved. Please 'contact us at (805) 326-3979 to schedule an inspection prior to operation of the new refrigeration system. ..Sincerely, // / Hazardous Materials Coordinator Barbara Brenner 'Hazardous Materials Planning Technician cc: A1. Sautner FIRE DEPARTMENT S.D. JOHNSON FIRE CHIEF CITY of BAKERSFIELD "WE CARE" ~ebruary 6, 1992 2101 H STREET BAKERSFIELD, 93301 326-3'911 A1 Sau~ner Plant Manager Pestritto Foods 6800 McDivitt Dr. Bakersfield, CA 93313 Mr Sautner: Your business, Pestritto'Foods, located at 6800 McDivitt Dr., has submitted plans for expansion of the anhydrous ammonia refrigeration system. Pursuant to sections 25534(h) and 25535(d) of the California Health and SafetyJCode, you will be required to submit a revisions to the existing Risk Management and Prevention Program ~RMPP) for the use and handling of anhydrous ammonia. The RMPP revisions shall be based upon a risk assessment which shall consider all of the following: THE RESULTS OF A HAZARD ANALYSIS WHICH IDENTIFIES THE HAZARDS ASSOCIATED WITH THE HANDLING OF THE ACUTELY HAZARDOUS MATERIAL DUE, TO OPERATING ERROR, EQUIPMENT FAILURE AND EXTERNAL EVENTS WHICH MAY PRESENT AN ACUTELY HAZARDOUS MATERIALS ACCIDENT RISK. FOR THE HAZARDS IDENTIFIED IN THE HAZARD ANALYSIS, AN OFFSITE CONSEQUENCE ANALYSIS WHICH ASSUMES PESSIMISTIC AIR DISPERSION AND OTHER ADVERSE ENVIRONMENTAL CONDITIONS. .The RMPP shall include the following elements: A DESCRIPTION'OF EACH ~CcIDENT INVOLVING ACUTELY HAZARDOUS MATERIALS WHICH HAS OCCURRED AT THE FACILITY WITHIN THREE YEARS FROM THE DATE OF THIS RMPP REQUEST. THIS DESCRIPTION SHALL INCLUDE THE UNDERLYING CAUSES OF THE ACCIDENT AND THE MEASURES TAKEN, -'IF ANY, TO AVOID A RECURRENCE OF A SIMILAR ACCIDENT. A REPORT SPECIFYING THE NATURE,. AGE AND CONDITION OF THE EQUIPMENT USED TO HANDLE ACUTELY HAZARDOUS MATERIAL~ AT THE FACIbITY. INCLUDE SCHEDULES FOR TESTING AND MAINTENANCE OF THIS EQUIPMENT. .. 'A DESCRIPTION OF DESIGN, OPERATING AND :MAINTENANCE .'.qCONTROLS-~:.?:~t~:,~i::'-. '"~ -' WHICH MINIMIZE - THE' ,RISK. OF- ANv::~ACCIDENT-i':'INVOLVING~.~-ACUTELY · .?:~.~??~i:.J::i.>'~': :>?~<:'SYSTEMS WHICH "~MINiMI ZE ,THE'%~OTENTIAL"?~RiSKSi~pOSED~i~iBY'?~iACuTELY · : .... ' ADDITIONAL STEPS .?TO BE .TAKEN..BY ~.THE_!-BUSINESS ~?..IN::~ODER :-:- -¥--.- -' RSDUCE.,T S R SK OF AN AcCiDs T- O WN '-:ACUTSnY:]T S S': ' :"' ' ~TERIALS, THESE ACTIONS ~Y INCLUDE A~i'OF THE AUTORTI'C CONTROL DEVICES. ': ..... .- EQUIPMENT MODIFICATIONS, REPAIRS OR.ADDITIONS. '.-~ ..~-: .' CHANGES IN THE OPE~TIONS, .PROCEDURES, '~INTENANCE SCHEDULES OR FACILITY DESIGN. '~'-"-'"' '. ~' ~.:. IDENTIFICATION, BY TITLE, ALL "PERSO~EL;?~:AT.i-.THE BUSINESS ..... ~--'-" .ARE RESPONSIBLE .FOR CARRYING OUT THE SPECIFIC ELEME~S OF.THE ~PP AND A DESCRIPTION OF THEIR RESPECTIVE 'RESPONSIBILITIES. ::. A DETAILED T~INING PROG~ TO INSURE THAT THE RESPONSIBLE PERSONS ARE ABLE TO IMPLEMENT THE ~PP. ' " A ~DESCRIPTION OF AUDITING AND INSPECTION PROG~S DESIGNED TO ~LOW THE HANDLER TO CONFI~..T~T THE RISK ~NAGEMENT A~ PREVENTION PROG~ IS EFFECTIVELY CARRIED OUT. A RECORD' KEEPING PROCEDURE FOR THE RISK MANAGEMENT AND PREVENTION PROGRAM. ' .... THE ACUTELY HAZARDOUS MATERIALS HANDLER SHALL REVIEW THE RISK MANAGEMENT AND PREVENTION PROGRAM AND SHALL MAKE 'NECESSARY REVISIONS TO THE RMPP AT LEAST EVERY THREE YEARS. REVISIONS SHALL BE MADE WITHIN 60 DAYS FOLLOWING A. MODIFICATION WHICH WOULD MATERIALLY AFFECT THE HANDLING OF AN ACUTELY HAZARDOUS MATERIAL.. Hazardous'Materials Planning TeChnician cc: ._ Ralph Huey . '. FIRE DEPARTMENT S.D. JOHNSON FIRE CHIEF CITY of BAKERSFIELD "WE CARE" January 13, 1992 2101 H STREEt' BAKERSFIELD, 93301 326-391 ~1 Robert Perusich Preston Refrigeration Co. 3241 N. 7th St. Trafficway Kansas City, KS 66115 Mr.. Perusich: A set .of plans for the expansion of the Pestritto Foods refrigeration system has been submitted to Bakersfield Fire Department, Hazardous Materials Division. We have discussed and reviewed these plans with the plant staff. It is my understanding that some revisions are being made to clearly reflect the venting of the pressure relief valves to the ammonia absorption system. Several other provisions of the 1988 Uniform Fire Code (UFC), Article 80 also apply to this project. For instance, pipe connections and fittings are to be welded when used for containment of a toxic gaS Such as ammonia. Upon receipt of the amended plans we will check them for compliancg with Article 80 of the UFC and let you know if there are any other items of concern. We would like to meet with You to discUss this project when you are in Bakersfield next week. As our schedules are quite full, please call me as soon as possible to set up a convenient time. I can be reached at (805) 326-3979. Sincerely, Barbara Brenner Hazardous Materials Planning Technician cc: A1 Sautner ~alph Huey RETURN PAYMENTS TO: - ' ,II CITY OF BAKERSFIELD ' Dc E<', ROUND 1A i',~ K · P.O. BOX2057 ' FI~?.F:, - U~,t BAKERSFIELD, CA 93303-2057 AccOUNT NO: [ NSP~CT! 0 ~ TII~E SPFZNI RE'VIEt~ING.1HE iIAZARD. RISK & CO~S~(~IJEXCE ANALYS~ AND 'T~E RHPP DOC~JHENT F05~ A TOTAL OF HOURS AT S45=00 PEf~ HOUR= :, B~[Eing Ctosing Date ],2/31/9~ - THIS BILL 'IS DUE' UPON PZcEIPT. PLEASE MAKE CHECKS PAYABLE TO: F._CiTy OF BAKERSFIELD Previous Bata'nce 0!1-Z1].t7 Total Current TOTAL NOW DUE 1..:[ 92.5 (i 1.192.5{ 1.192_,50 INQUIRIES CONCERNING THIS BILL, PLEASE PHONE: 15 5:~;, 6 3 INVOICE NUMBER '155863 i G!TY C.,O F'"F PESTRITTO FOODS 6800 MCOIVI TT BAKERSFIELD CA 93304 UTO0002 GENERAL OFFICE KANSAS CITY, KANSAS 66115 3241 NORTH 7TH STREET 913/621-1813 FAX 913/621~6762 ENGINEERS AND CONTRACTORS BRANCH OFFICE VAN BUREN, AR 72956 1430 SOUTH 2grH STREET 501/474-0099 FAX 501/474-1612 DRAWING TRANSMITTAL JOB OR ORDER NO. ~l~-~ FOR: REFERENCE.' RETURN APPROVED COPIES HOLDING UNTIL APPROVAL RECEIVED pROCEEDING IN ACCORDANCE WITH THESE DRAWINGS DRAWING NUMBERS AND/OR DESCRIPTION: RELEASED AND' TRANSMITTED BY MEMORANDUM' "WE CARE" December 18, 1991 TO: Valerie Pendergrass FROM: Barbara Brenner SUBJECT: Pestritto Foods RMPP billing The review of Pestritto Foods RMPP is now complete. A total of 26.5 hours were spent reviewing the hazard, risk and consequence analyses and the RMPP document. The total hours x 45 $ per'hour need to be entered into the computer so that a bill will be generated. Please note the date that the entry is made on this memo and file it in Pestritto's RMPP file when you are done. cc: Ralph Huey "WE CARE" FIRE DEPARTMENT S. D. JOHNSON FIRE CHIEF A1 saUtner .. .., .Bakersfield, CA, 93313 A1: December 18, 1991 2101H STREE! BAKERSFIELD, 93301 326-3911 Following is'a list of the items we.discussed'during the RMPP 'inspection which will require your'attention 'regarding follow-up. The ammonia diffusion control box should 'be protected from physical damage.(code section provided) The hazard placarding on the exterior of the engine room needs to be larger. (standard provided) '3. Request that the alarm company notify 911 emergency dispatchers if they KNOW that plant personnel are responding to emergency. The firemen do not want to waSte time trying to locate individuals in route to the plant. Be sure to continue to document"all of the monthly safety, meetings, drills, routine Periodic maintenance and maintenance training. Page V-5 'of the RMPP; ,Section F indicates that a standard operating procedures manual was supplied by the refrigeration contractor. This manual is also said to contain the normal start up, emergency shutdown and control system alarm set point instructions. Please investigate whether or not this manual will be made available. I have attached a copy of the memo sent to Captain Welborn · regarding your lock box. I will follow up on items 1-4 during inspections conducted next year. Please let me know by the end of January, what-the status of item 5 is. If Tri-Com is not going to supply standard operating procedures, this section of the RMPP will have to be revised. Standard procedures are an important to~l for training maintenance staff and insuring continued' safe practice despite turnover of the personnel who received hands on training from the installation contractor. Thank you for all of your cooperation regarding the plant tours'for training of the emergency responders. Please call me, ~326-3979, anytime that I can provide assistance with hazardous materials planning. RMPP INSPECTION PESTRITTO FOODS INC. Hazard Identificati0n: 1. Vessel and line labeling 2. Exterior NFPA placarding~ 3.. Dif.fuser box labeling 0K~ Fire Prevention: 1°. Fire extinguisher 2. Sprinkler system 0~-- Ammonia Safety System and Isolation Valves 1. Ammonia lines limited in populated areas of plant 2. Solenoid valves to isolate evaporators ~ 3. Manual valves to isolate evaporators and condenser 4. King valve on liquid supply lineO~ 5. Ammonia diffusion system 0M 6. Ammonia detector in engine room~ 7. Emergency exhaust and ventilation system ~ 8. Audio/visual control panel for alarm system~whi~h detects releases from pressure relief valves Operating Procedures: 1.~Standard operating procedures by Tri-Com to include; ~start-up, emergency shutdown and alarm set Points Maintenance: Maintenance schedule vs. manufacturers recommendation,s Frequency~of equipment inspections ~-~ ~- , Traininq: · 1. Monthly Safety Meetings 2. Documentation of training provided per Section 9 of the RMPP for maintenance, emergency response Personne~ ~- ~' general and Emerqency Response Procedures: 1. Location for employee use ~6_~,6~ 2. Bullhorn/intercom for notification Re c o rd Ke e~ ~~°~Yes: 1. Per Section 8 of the RMPP~~~M~ M.EMORAN DUM "WE C4 E" .... becember 18, 1991 TO: Capt'ain Welborn, Station 9-B FROM: Barbara Brenner, Hazardous Materials Division SUBJECT:'Lock boxes at Pestritto Foods During the risk management training at Pestritto Foods, we asked the plant staff to add additional keys to the existing lock bOx. A1 Sautner, the plant manager, notified me tha~ the keys have been made. He needs access to the box to place the items inside. Since this facility is in 9-B inspection area, I hope that you can assist Pestritto staff by opening the box. A1 Sautner can be contacted at 837-8461. At the time of the plant tour, several firemen expressed concern regarding 'the possibility that the existing lock box could be within the ammonia plume during a major release. Pestritto is willing to supply the contents if we can provide a secondlock box. The location of the second box should be on the north west, rear corner of the plant or on a light pole in the same'vicinity. ~One of the' two lock boxes would then be readily accessible during'an ammonia release. Please determine if.we can provide a second lock box and direct plant staff regarding the location of it. · PleaSe call me at 326-3979, if you have any problems following up on these items. I appreciate your assistance. cc: Ralph Huey A1 Sautner FIRE DEPARTMENT S. D, JOHNSON FIRE CHIEF CITY of BAKERSFIEL "WE CARE" December 18,. 1991 A1 Sautner Plant Manager Pestritto Foods 6800 McDivitt Dr. Bakersfield, CA 93313 2101 H STREET BAKERSFIELD, 93301 326-3911 - Following is a.list of the items we discussed during the RMPP inspection which will require your attention regarding follow-up. ~dS. The ammonia diffusion control box should be protected from physical damage.(code section provided) . ~ ~.' The hazard placarding on the exterior of the engine room needs · to be larger. (standard. provided) Request that the alarm .company notify 911 emergency dispatchers if they KNOW that plant personnel are responding to emergency. The firemen do not want to waste time trying to locate individuals in route to the plant. .~4f~ Be sure to continue to document all of the" monthly safety meetings, drills, routine periodic maintenance and maintenance training. Page V-5 of the RMPP, Section F indicates that a standard operating procedures manual was supplied by the.refrigeration contractor. This manual is also said to contain the normal start up, emergency shutdown and control system alarm set point instructions. Please investigate whether or not this manual will be made available. I have attached a copy of the memo sent to Captain Welborn regarding your lock box. I will follow uP on items 1-4 during inspections conducted next year. Please let me know by the end of January, what the status of item 5 is. If Tri-Com is not going to supply standard operating procedures, this section of the RMPP will have to be revised. Standard procedures are an important t~i for training maintenance staff and insuring continued safe practice despite turnover of the personnel who received hands on training from the installation contractor. Thank you for alI of your cooperation regarding the plant tOurs'for training of the. emergency responders. Please call me, ~.-".~ .~. '..326-3979, .anytime that I can. provide assistance with ..... ,~- ~,- ~ '-.-~ .~i ~materials planning. -.. ~ ~: .~-/.~ j-..~-¥,~.~.~i!'~ -. '" .... !'?'U'":'": .... : i C ~ Y,':' ' ' ........ ' ' :.-. .... Sneel ', ' : .: .'.>. :?.:.. .... .:HazardoUs Materials :Plan'ning cc:.... Ralph. Huey ~,~. ::~ ~: *-7--.-' .......... ~--' -- . ....... ~:__ ..... . . ' ' . m~ .~. ¢~s.~ . Tri-Com Refrigeration, Inc. · INSTRUCTIONS FOR EMERGENCY:";"., CONTROL' BOX .- INSTRUCTIONS FOR FIRE DEPARTMENT USE step.1 ·Turn ventilation switch on (S-2) & evaluate the problem in the system. If problem is in the low side, do not'push emergency shutdown switch (S-l). If problem is' in the high side of the system, push emergency shutdown switch (S-i). Step 2 Open valve No. 3 & use the gauges to maintain the pressure on the low side of the system below 140 psig. Valve No. 3 - Discharge valve to water diffuser tank (iow pressure side of system) Step 3 Open valve No. 1 & use the' gauges to maintain the pressure on the high side of the system below 200 psig. /Valve No.'l·- Discharge valve to water diffuser tank (high -pressure side of system) Note: oPtion if'desired Notify qualified person before.proceeding with this step. ~ HOME PAGER A1 Sautner (805)833-1397 (805)398-2685 Leo Vadnais (805)836-0995 (805)398-2684 Stan Bryan. (805)393-4725 (805)398-2693 Step 4 Ammonia transfer within system. Open Valve No. 2 to transfer. .' ammonia 'from the high side to the low side of the system. EMERGENCY SWITCHES: " Switch No. i (S-l) "Emergency Refrigeration ShUtdown,, 'switch. Shuts off the entire refrigeration system. . · SwitCh No 2 (S-2) "Emergency Ventilation" switch Turns on the ;',~?, exhaust fan. ';:-Switch No. a (S-3) "Horn/Silence" switch. Silence alarm horn while scrubber system is operating. Switch No. 4. (S-4) "Manual Scrubber System'" .switch. Operates_ the .ammonia scrubber system. "Hand-Off-Auto" switch normally in the AUTO position unless manual operation is needed. 11909 E. Telegraph Road · p.O. Box 3866 · Santa Fe Springs, CA 90670 · (213) 948-3861 / FAX: (213) 949-8249 · Ucense # 461823 B-I, C-38 INDUSTRIAL REFRIGERATION AND COLD STORAGE SPECIALISTS . -,,. LUFT ENVIRONMENTAL CONSULTING 3701 Pegasus· Drive, Suite 121 * Bakersfield, California 93308 · 8 5 Barbara Brenner Hazardous Materials Planning Technician' Bakersfield City Fire Department 2101 "H" Street Bakersfield, CA 93301 Ms. Brenner: RECEtVEO OCl 0 7 1991 HAZ. MAT. DrY, Per your request, enclosed is the change to page V-5 of Section 5 in Pestritto Foods Inc.'s RMPP. The requested change is highlighted in the following sentence: "If the concentration of ammonia reaches 200 ppm, an alarm will sound and an emergency fan will be automatically started to direct air out of the engine room and into an evaporative condenser where the ammonia will be absorbed in the water." If you have any questions concerning the enclosed, please contact me at your convenience. ad W. Luff Principal · Mechanical Engineer Larry Wuethrich - Pestritto Foods, Inc. w/enclosures Al Sautner - Pestritto Foods Inc. - Bakersfield w/enclosures Larry Rolison - Td-Com Refrigeration Inc. w/enclosures LEC-91-0313 PF-01 p tdo o SEPTEMBER 16, 1991 BAKERY DIVISION RECEIVED 1991 Pea~ B~,.b~a Brem~e~: PI~¢ find ¢nc£o~/ ~e Em~tgencq Action PLan, ~ Fou requited. If I can be of amy fuxl:hea a~,tance,plea~e e_a~,Thanlz ~ou. Admin ~ative 6800 McDIVITT DRIVE · BAKERSFIELD CA 93313 PHONE (8.05)' 837-8461· · FAX (805) 836-3559 PESTRITTO FOODS, INC. JAKERSFI~.n, CA. STAFF/EMPLOYEE SAFET~ MRRTING- INSTRUCTOR: AL SAUTNER RECEIVED $EP I 8 1991 HAZ. Maj. DIV. AUGUST 15,]99] FIRST AID PROCEDURE- FIRST AID KIT LOCATED IN Q.C.ROOM, INCLUDES=BANDAIDS,BANDAGES, 0INTMENTS,SPRAYS,ASPIRIN'TYLRNOL...ETC. MUST SIGN FIRST AID DISPENSARY BOOK UPON RECEIVING ANY OF THE ABOVE. LOGGING OF ACCIDENTS-ANYANDALLACCIDENTS MUST BE REPORTED TO MARGE SAUTNER- NON-RECORDABLE INJURIES-LOST TIME INJURIES(OSHA-200) ON THE JOB INJURIES. MUST BE REPORTED IMMEDIATELY! FIRE/EARTHQUAKE/CHEMICAL RELEASE EMERGENCY PROCEDURE-EVERYONE HAS RECEIVED A COPY OF OUR SAFETY PROGRAM-INCLUDED IS OUR EVACTUATION PROCEDURE FOR FIRE OR C~.MICAL ~.RASE EMERGENCY... EARTHQUAKE NOT NOTED ON THIS POLICY,BUT,IN CASE OF AN EARTHQUAKE WE WILL GO TO THE SAME EVACUATION POINT,THIS POINT CAN BE FOUND ON MAP OF BUILDING WHICH EVERYONE HAS RECEIVED A COPY. ?FACUATION PROCEDURE-wHO'S IN CHARGE? IN THE EVENT OF AN EMERGENCY,TRRRE WILL BE THREE SHORT "BR~-DS"OVER THE INTER-COM YOU T~]ZNWILL BE INSTRUCTED OF EVACUATION PROCEDURE...IMMEDIATELY SHUT DOWN A~.~. MACHINERY..TO DO SO,DEPRESS T~E RED EMERGENCY STOP BUTTONS CLEARLY LOCATED ON ~LLMACHINERY..THEN PROCR~RD TO EXIT THE BUILDING IN THE DESCRIBED MANNER W'BAT OUR PLANT ALARM SOUNDS LIKE-THIS WOULD BE OUR INTER-COM SYSTEM OR IN THE CASE OF RL~CTRICAL FAILURE,THE "BULL-HORN" OR NAME OTHER. LOCATION OF M.S~D.S.(RIGHT TO KNOW STATION)-EVERYONE BAS RECEIVED A COPY OF OUR HAZARDS COMMUNICATION PROGRAM..TBEYALSOWERE INFORMED OF LOCATION OF RIGHT TO KNOW STATION (LOCATED ON MAP) POLICY ON DRUG SC~RRNING-EVERYONE HAS BEEN INFORMED OF THE POLICY AND SIGNED THE (~tECK LIST CLRARLY STATING THAT HE/SHE UNDERSTANDS THAT PARTICULAR POLICY.THIS IS FOUND ON THE BACK PAGE OF OUR RULES AND REGULATIONS(HIGHLITED) PF. STRITTO FOODS, INC. 6800 McDIVITT DRIVE BAKERSFIELD,CA. 93313 EVAC. AREA "'~ 'l. 0 ~ ~LRST , , , ~.c DIVITT 'A "PESTRITTO FOODS OF CALIFORNIA" EVACUATION PROCEDURES AND POLICY POLICY: IT IS THE POLICY OF THE COMPANY TO PROVIDE A SAFE EXIT IN THE EVENT OF A FIRE AND/OR AMMONIA LEAK. EMPLOYEES ARE EXPECTED TO COMPLY WITH ALL SAFETY REQUIREMENTS 'WHETHER ESTABLISHED BY MANAGEMENT OR BY FEDERAL, STATE, OR LOCAL LAW. PROCEDURE: EMPLOYEES WILL BE REQUIRED TO ATTEND A SAFETY ORIENTATIION MEETING THAT WILL ADVISE THEM OF THE PROPER PROCEDURES IN THE EVENT OF AN EMERGENCY EXIT. 1. ONE PERSON WiLL BE APPOINTED IN EACH DEPARTMENT TO BE RESPONSIBLE TO OVERSEE THE EVACUATION OF THEIR AREA. 2. UPON REACHING THE DESIGNATED AREA THE APPOINTED PERSON IS RESPONSIBLE FOR TAKING A HEAD COUNT, THUS MAKING SURE ALL EMPLOYEES ARE ACCOUNTED FOR. EACH DEPARTMENT WILL ALSO HAVE A SECOND PERSON APPOINTED, THAT IN THE EVENT THE DEPARTMENT HEAD IS ABSENT, WILL OVERSEE THE SAME EVACUATION PROCEDURES. SAFETY EVACUATION PROCEDURE: IN THE CASE OF A FIRE. AND/OR AMMONIA LEAK AN OFFICIAL WILL BROADCAST OVER THE PUBLIC ADDRESS SYSTEM THAT AN IMMEDIATE EVACUATION IS NECESSARY. IN THE EVENT THAT THE PUBLIC ADDRESS SYSTEM IS NOT WORKING THIS BROADCAST WILL BE BY BULLHORNS THAT ARE LOCATED THRU OUT THE BUILDING. EVERYONE IS REQUIRED TO MEET AT A CENTRALLY LOCATED AREA THAT IS DESIGNATED ON THE ATTACHED MAP. AT THAT TIME THE PLANT MANAGER WILL MEET WITH THE DEPARTMENT HEADS TO GATHER THE HEAD COUNTS OF ALL DEPARTMENTS, MAKING CERTAIN THAT ALL EMPLOYEES ARE ACCOUNTED FOR. TO: FROM: DATE: SUBJECT: ALL ?ESTRITTO FOODS EMPLOYEES AL SAUTNER, PLANT MANAGER JULY 31,1991 PESTRITTO FOODS OF CALIFORNIA SAFETY PROGRAM ENCLOSED YOU WILL FIND YoUR COPY OF PESTRITTO FOODS SAFETY PROGRAM. PLEASE READ IT CAREFULLY. THIS PROGRAM IS DESIGNED FOR THE SAFETY OF ALL PESTRITTO FOODS E~{PLOYEES. PLEASE READ ALL ATTACHED PAPERS AND HELP TO MAKE THIS A SAFE WORK PLACE FOR EVERYONE. REME~BER: READ IT, KNOW IT, LIVE IT. "PESTRITTO FOODS OF CALIFORNIA" SAFETY pROGRAM PROCEDURE POLICY: IT IS THE POLICY OF THE COMPANY TO PROVIDE A WORK ENVIRONMENT AS FREE'-AS'FEASIBLE FROM RECOGNIZED HAZARDS. EMPLOYEES ARE EXPECTED TO COMPLY WITH ALL SAFETY AND HEALTH REQUIREMENTS WHETHER ESTABLISHED BY MANAGEMENT OR BY FEDERAL, STATE, OR LOCAL LAW. E~PLOYEES VIOLATING SAFETY RULES ARE SUBJECT TO '. DISCIPLINE UP TO AND INCLUDING TERMINATION. PROCEDURE: (1) THE PRESIDENT OF THE COMPANY HAS APPOINTED A SAFETY OFFICER WHOSE RESPONSIBILITIES INCLUDE: (a) MONITORING COMPLIANCE WITH COMPANY SAFETY RULES AND REGULATIONS AND THE APPLICABLE SAFETY AND HEALTH STANDARDS ESTABLISHED AS A RESULT OF THE OCCUPATIONAL SAFETY AND HEALTH ACT OF 1970 AND ANY OTHER APPLICABLE FEDERAL, STATE, OR LOCAL EMPLOYEE SAFETY LAWS OR REGULATIONS; (b) INVESTIGATING, dORRECTING, AND ELIMINATING RECOGNIZED UNSAFE WORKING CONDITIONS OR POTENTIAL HAZARDS; (c) CONDUCTING PERIODIC INFORMAL SAFETY INSPECTIONS (d) (e) (f) OF ALL WORK AREAS, MACHINERY, EQUIPMENT, GROUNDS, LIFT TRUCKS, WARE & TEAR, AND ANY OTHER RECOGNIZED POTENTIALLY HAZARDOUS COMPANY FACILITIES; REPRESENTING THE COMPANY DURING INVESTIGATIONS CONDUCTED BY THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA), STATE SAFETY AND HEALTH AND INSURANCE CARRIER PERSONNEL. ORGANIZING THE TRAINING AND RETRAINING OF EMPLOYEES AS REQUIRED BY OSHA. MONITORING COMPLIANCE WITH THE VARIOUS REQUIREMENTS ESTABLISHED BY OSHA, THE STATE, AND THE INSURANCE CARRIER RELATING TO RECORD KEEPING AND THE RETENTION OF RECORDS; (2) (3) (4) (g) POSTING NOTICES AND KEEPING RECORDS AS MAY BE REQUIRED BY OSHA, THE STATE, AND THE INSURANCE CARRIER; (h) ESTABLISHING FIRE PREVENTION AND FIRE FIGHTING PROGRAMS, AND CONDUCTING FIRE DRILLS; (i) DEVELOPING CONTINGENCY DISASTER PREPAREDNESS PLANS; (j) INVESTIGATING' ALL ACCIDENTS AND'FIRES INVOLVING COMPANY EMPLOYEES, OR WHICH OCCUR ON COMPANY PREMISES, AND PREPARING THE REQUIRED REPORTS. EMPLOYEES SHOULD REPORT TO THE SAFETY OFFICER ALL OBSERVED SAFETY AND HEALTH VIOLATIONS AND ANY ACCIDENTS RESULTING IN INJURYS TO EMPLOYEES OR CUSTOMERS. ALL EMPLOYEES ARE ENCOURAGED TO SUBMIT SUGGESTIONS TOiTHE SAFETY OFFICER CONCERNING SAFETY AND HEALTH M3kTTERS. IF SAFETY CLOTHING OR EQUIPMENT IS REQUIRED BY OSHA REGULATIONS.OR COMPANY POLICY, THE COMPANY WILL PROVIDE THE CLOTHING AND EQUIPMENT. THE COMPANY WILL REPLACE. DAMAGED OR BROKEN SAFETY EQUIPMENT OR CLOTHING, PROVIDED THE DAMAGE IS NOT CAUSED BY THE NEGLIGENCE'OF THE EMPLOYEE. SAFETY PROGRAM PROCEDURE: SAFETY INSPECTIONS WILL BE CONDUCTED WEEKLY, BY ALL SHIFTS. THE SHIFT SUPERVISOR AND AN HOURLY REPRESENTIVE, WILL TOUR ALL.AREAS AND DOCUMENT UNSAFE CONDITIONS, MACHINES, PRACTICES, THIS REPORT WILL BE SUBMITTED TO THE SAFETY OFFICER. THE SAFETY REPORT THEN BE GIVEN TO THE DEPARTMENT RESPONSIBLE FOR CORRECTING THE PROBLEM. THE SAFETY REPORTS WILL BE REVIEWED BY THE SAFETY OFFICER AT THE END OF EACH WEEK, AND STATUS NOTED. FIFTEEN MINUTE SAFETY MEETINGS WILL BE HELD EACH MONTH. THIS INCLUDES ALL SHIFTS. (3) MACHINE OPERATOR INSTRUCTIONS 8) 9) 'tO) 1].) ].2) 14) 15) 16) 1) ALL MACHINE OPERATORS SHOULD BE MADE AWARE OF POTENTIAL HAZARDS OF THE MACHINES OPERATIONS & ALL EMERGENCY STOP SWITCHES & LOCK OUT CONTROLS. 2) MACHINE OPERATOR'S SHOULD BE MADE FAMILIAR WITH OPERATION OF ADAMATIC LINES AND PROOFER. 3) SHOULD BE TOLD WHAT ROUNDING DRUM TO USE WITH DIFFERENT DOUGH WEIGHTS ALSO HOW THE DOUGH BALL SHOULD LOOK. 4) SHOULD BE SHOWN HOW TO ADJUST THE WEIGHT OF DOUGH. 5) THEY SHOULD BE SHOWN HOW TO LIFT DOUGH TROUGH AND PUT DOUGH IN HOPPER. NOT TO PUT AN EXCESSIVE AMOUNT OF DOUGH IN THE HOPPER. 6) SHOULD BE MADE AWARE OF THE IMPORTANCE OF CHECKING WEIGHTS OF DOUGH CONSTANTLY. 7) MAKE SURE SAMPLES ARE TAKEN AT HEAD OF MACHINE AND CORRECT DOUGH NUMBERS PUT ON IT. SHOULD BE MADE AWARE OE ADJUSTING THE DUSTING ELOUR. SPRAY OIL ONLY ON HEAD OF ADAMATIC HOPPER NOT ON BELTS. SHOULD CHECK PROOFER AND KEEP PROOFER CLEAN. EMPTY PANS UNDER PROOFER EVERY OTHER DOUGH. IF DOUGHS ARE NOT RUNNING THROUGH MACHINE PROPERLY MAKE FOREMAN AWARE OF PROBLEM. KEEP FLOUR FROM HEAD OF ADAMATIC TO END OF PROOFER CLEAN; KEEP ADAMATIC CLEAN AT ALL TIMES. EMPTY BARRELS FOR USED DUSTING FLOUR. USE ONLY CLEAN RYE FLOUR FOR DUSTING PURPOSES ON KAISER ROLLS-SPLIT TOP. 17) PUT DRUMS BACK ON RACK AFTER USE. 18) IF MACHINE IS NOT RUNNING RIGHT MECHANICALLY TELL THE FOREMAN. 19) NEVER LEAVE YOUR MACHINE UNATTENDED. 20) KEEP HANDS AND FINGERS OUT OF' MACHINE, SHUT OFF TO CLEAN. (4) PRODUCTION SAFETY PROCEDURES MACHINE OPERATORS 1. KNOW WHERE THE STOP AND START SWITCHES ARE ON YOUR MACHINE. DO NOT OPERATE ANY MACHINE WITHOUT INSTRUCTIONS. 2. STOP MACHINE TO REMOVE DOUBLES, CLOGGS. 3. KEEP HANDS AND CLOTHING AWAY FROM ECCENTRIC DRIVES, BELTS, CHAINS. NEVER REACH INTO ADAMATIC HOPPER TO REMOVE DOUGH. 4. uSE CAUTION WHEN CUTTING DOUGH PORTIONS. ~ 5. 'DO NOT CLIMB OR SIT ON CONVEYOR OR PROOFER. 6. REPORT TO YOUR SUPERVISORS ANY BARE WIRES, LOOSE CHAINS, BELTS SPLIT.TING, ETC. 7. DO NOT REACH INTO HOPPER FOR ANY REASON. 8. USE CARE WHEN SPRAYING OIL ON DOUGH. DO NOT GET OIL ON FLOOR. 9. DO NOT LEAVE MACHINE RUNNING UNATTENDED FOR ANY REASON.. 10. KEEP YOUR MACHINE AND WORK AREA CLEAN. 11. ANY EMPLOYEE THROWING DOUGH WILL BE TERMINATED. 12. DO NOT WEAR RINGS, WATCHES, EARRINGS, NECKLACES, OR ANY KIND OF JEWELRY. 3. 4. 5. SAFETY PROCEDURES FOR SHIPPING REPORT ANY EQUIPMENT PROBLEMS SUCH AS: BRAKES, HORN, BARE .WIRING, STEERING. KEEP FREEZER FLOORS CLEAN AND CLUTTER FREE. DO NOT USE BATTERY CHARGER WITHOUT PROPER INSTRUCTIONS. KEEP PRODUCTION SKIDS STACKED AT A SAFE LEVEL. DO NOT USE A PIECE OF EQUIPMENT THAT IS UNSAFE. (6) PACKAGING 3 4 5 6 7 8 KEEP HANDS OUT OF CONVEYOR BELTS. USE CAUTION WHEN IN HOLDING FREEZER, REPORT SLICK FLOORS, KEEP AREA CLEAN. KEEP SKIDS STACKED NEATLY, NEVER LEAVE A SKID STANDING ON END. STACK PRODUCT IN A WELL BALANCED ORDER ON THE. SKID. KEEP YOUR WORK STATION CLEAN. REPORT ANY SAFETY HAZARDS TO YOUR SUPERVISOR. DO NOT STAND ON CASES OR PALLETS OF ANY TYPE. HEARING PROTECTORS ARE MANDATORY. (7) LADDER SAFETY 1. NEVER USE LADDER WITH DAMAGED OR MISSING PARTS. 2. DO NOT EXCEED MAXIMUM WEIGHT. 3. DO NOT USE LADDERS IN FRONT OF UN-LOCKED DOORS. 4. PLACE LADDER FEET ON FIRM LEVEL SURFACES. 5. NEVER PLACE ANYTHING UNDER ON ATTACH ANYTHING TO A LADDER TO GAIN HEIGHT OR TO ADJUST FOR UNEVEN SURFACES. 6. CHECK THAT ALL FOUR FEET OF LADDER FIRMLY SUPPORTED TO PREVENT EXCESSIVE MOVEMENT. 7. ALWAYS FULLY OPEN LADDER AND LOCK SPREADERS BEFORE CLIMBING. 8. NEVER STAND, SET OR CLIMB ON LADDER TOP, PAIL SHELF, BRACES OR BACK SECTION. 9. DO NOT OVER REACH. 10. KEEP METAL LADDERS AWAY FROM ELECTRIAL POWER LINES AND CIRCUITS, METAL CONDUCTS ELECTRICITY. 11. ALWAYS KEEP L~DDERS CLEAN AND FREE OF FOREIGN MATERIALS. PRODUCTION SAFETY PROCEDURES MOLDER SAFETY RULES STRAIGHTNERS 4. 5. 6. STOP MACHINE TO CLEAN OUT DOUGH CLOGGS. DO NOT ATTEMPT TO PULL DOUGH OUT OF A MACHINE WHILE RUNNING. DO NOT TRY TO CHANGE PLATES WITHOUT STOPPING MOLDER KEEP HANDS, AND CLOTHING AWAY FROM DRIVE BELTS, CHAINS. ' KEEP GUARDS IN PLACE. REPORT ANY MECHANICAL PROBLEMS, BELTS, TEARING, SPLITTING. (9) PACKAGING 1. KEEP HANDS OUT OF CONVEYOR BELTS, USE A SCRAPER TO CLEAN CHUTES. 2. USE CAUTION WHEN IN HOLDING FREEZER, REPORT SLICK FLOORS, KEEP AREA CLEAN. 3. KEEP SKIDS STACKED NEATLY, NEVER LEAVE A SKID STANDING ON END. 4. STACK PRODUCT IN A WELL BALANCED ORDER ON THE SKID. 5. KEEP YOUR WORK STATION CLEAN. 6. REPORT ANY SAFETY HAZARDS TOKYOUR SUPERVISOR. 7. DO NOT STAND ON BOWL TO CLEAN CHUTES. 8. HEARING PROTECTORS ARE MSkNDATORY. (lo) SANITATION SAFETY RULES COTTON GLOVES, RUBBER GLOVES OR ANY OTHER MEANS OF HAND PROTECTION ARE NOT TO BE WORN AROUND RUNNING MACHINERY. 2. PERSONS HAVING LONG HAIR ARE REQUIRED TO KEEP IT TIED BACK AND CONFINED IN A HAIR NET. 3. EAR OR EYE PROTECTION,(EAR PLUGS, MUFFS, SAFETY GLASSES OR GOGGLES) MUST BE WORN IN AREAS REQUIRING PROTECTION. 10. 11. 12. 13. WET FLOOR CONES MUST BE ON DISPLAY WHENEVER A SLIPPERY CONDITION EXISTS. WET FLOOR CONES MUST BE DISPLAYED UNTIL'' AREA IS COMPLETELY DRY. NEVER SMOKE IN REFRIGERATED AREAS AS THIS.COULD CAUSE SEVERE DAMAGE TO THE RESPIRATORY SYSTEM. LOOSE CLOTHING SUCH AS SHIRTS, LONG SLEEVES ARE TO BE TUCKED IN, ROLLED UP OR SECURED IN SUCH A MANNER AS NOT TO GET CAUGHT IN MACHINERY BEING USED OR CLEANED· AIR WANDS, DUE TO THEIR ABILITY TO INCREASE AIR VELOCITY MUST BE USED WITH EXTREME CAUTION. NEVER POINT AT ANOTHER PERSON, DO NOT POKE WAND IN AREAS WHERE ELECTRICAL WIRES OR DEVICES EXIST, USE CAUTION WHEN OTHERS ARE PRESENT. NEVER USE AN AIR NOZZLE OR WAND TO BLOW OFF YOUR CLOTHING~ CONDENSATION CREATES RUST IN THE LINES, THIS IN TURN COULD GET BLOWN INTO THE SKIN OR EYES. IN SOME INSTANCES IT HAS BEEN KNOWN TO CAUSE BLOOD POISONING. EYE AND EAR PROTECTION IS REQUIRED WHEN USING AIR TO BLOW DOWN MACHINERY. OBSERVE AND OBEY ALL WARNING SIGNS ON MACHINERY. DO NOT START ANY MACHINERY UNTIL YOU CHECK FOR CO-WORKERS. ADVISE THOSE NEARBY OF YOUR INTENTIONS. IF TWO WORKERS ARE ENGAGED IN CLEANING A MACHINE, ONE WORKER IS TO HAVE CONTROL OVER THE STARTING AND STOPPING OF THE MACHINE. BEFORE ATTEMPTING TO USE ANY ELECTRICAL DEVICE, ALWAYS INSPECT FOR DAMAGED PARTS, CUTS OR BREAKS IN ELECTRICAL CORDS OR DAMAGED PLUGS. IF SUCH ARE FOUND, REPORT IT TO Ill) 14. 15. 16. 17. 18. THE SUPERVISOR. NEVER REMOVE A GROUND PRONG FROM A ELECTRICAL PLUG. DO NOT CLEAN MACHINERY WHILE IT IS RUNNING. YOU COULD BE PULLED INTO THE CHAINS OR ROLLERS. FAMILIARIZE YOURSELF WITH A MACHINES EMERGENCY SHUT OFF DEVICES BEFORE YOU ATTEMPT TO CLEAN. BEFORE STARTING A MACHINE, CHECK ALL AREAS FOR CLEANING EQUIPMENT, MACHINE PARTS, ETC. BROKEN PARTS COULD CAUSE SOMEONE TO GET HURT. REPORT ALL ACCIDENTS TO YOUR SUPERVISOR NO MATTER HOW SMALL. (12) PRACTICAL WORK RULES & SUGGESTIONS IN THE INTEREST OF EFFICIENCY, SAFETY AND FOR THE PROTECTION OF THE INDIVIDUAL, REASONABLE RULES OF CONDUCT ARE POSTED AT VARIOUS LOCATIONS THROUGHOUT THE PLANT FOR THE INFORMATION & COOPERATION OF ALL EMPLOYEES. THESE RULES ARE NECESSARY TO PREVENT ANY UNCOOPERATIVE EMPLOYEE FROM TAKING ADVANTAGE OF THE MAJORITY WHO WANT TO COOPERATE TO DO A GOOD JOB. ALL EMPLOYEES ARE RESPONSIBLE FOR UNDERSTANDING AND OBSERVING THESE RULES AND SHOULD SEE THEIR SUPERVISOR OR PERS0~NEL DIRECTOR IF THEY HAVE QUESTIONS. IN ADDITION, EMPLOYEES ENGAGED IN ANY OF THE FOLLOWING ACTIVITIES MAY BE SUBJECT TO EITHER DISCIPLINARY ACTION OR DISCHARGE. SMOKING IN A'.RESTRICTED AREA. SMOKING MUST BE CONFINED TO RESTROOMS~, BREAK ROOMS. SMOKING ELSEWHERE IN THE BUILDING IS PROHIBITED BY USDA AND FIRE INSURANCE REGULATIONS. A FIRE COULD LEAVE YOU JOBLESS!! o REPORTING TO WORK UNDER THE INFLUENCE OF, USING, CARRYING, OR DISTRIBUTING INTOXICATION BEVERAGES OR DRUGS ON COMPANY PROPERTY, ANYONE ON MEDICATION MUST REPORT IT TO PERSONNEL STATING WHAT IT IS. o USING PROFANE, ABUSIVE, OR THREATENING LANGUAGE; FIGHTING, HORSEPLAY OR THREATENING THE WELL BEING OF ANY FELLOW EMPLOYEE, THIS ILLUSTRATIVE AND NOT EXHAUSTIVE. o INSUBORDINATION, REFUSING TO DO ASSIGNED WORK, OR FAILING TO CARRY OUT ANY REASONABLE INSTRUCTION OF MANAGEMENT. 5. LEAVING THE ASSIGNED WORK STATION WITHOUT THE SUPERVISOR'S PERMISSION. 6. EXCESSIVE TALKING THAT INTERFERES WITH THE WORK PERFORM~%NCE OF ANY INDIVIDUAL. 7. HAVING IN YOUR POSSESSION (OR IN YOUR AUTOMOBILE ON COMPANY PREMISES) FIREARMS, OTHER WEAPONS, OR ARTICLES RESEMBLING WEAPONS, WHILE ON COMPANY PROPERTY. BEING INVOLVED IN ANY FORM OF'GAMBLING UNLESS SPECIFICALLY ORGANIZED BY MANAGEMENT. (13) ., 10. FAILING TO WORK ACCORDING TO THE STANDARDS SET BY MANAGEMENT OR POOR JOB PERFORMANCE. UTILIZING COMPANY SUPPLIES, EQUIPMENT, PERSONNEL, FACILITIES OR PROPERTY, INCLUDING TELEPHONE EQUIPMENT FOR PERSONEL BENEFIT OR CONVENIENCE. VIOLATING SAFETY REGULATIONS OR IN ANY WAY JEOPARDIZING THE HEALTH OR SAFETY OF OTHER EMPLOYEES. FALSIFYING DOCUMENTS, INCLUDING APPLICATION FORMS, EMPLOYMENT RECORDS, TIMEKEEPING RECORDS, OR ANY OTHER COMPANY DOCUMENTS. (14) PESTRITTO FOODS INC. THE MATERIAL SAFETY DATA SHEET (HAZA/~DS COMMIRqICATIONS PROGRAM) THIS MATERIAL SAFETY DATA SHEET IS YOUR GUIDE TO WORKPLACE SAFETY. THIS BASIC HAZARD COMMUNICATION TOOL GIVES. DETAILS ON CHEMICAL AND PHYSICAL DANGERS, SAFETY PROCEDURES, AND EMERGENCY RESPONSE TECHNIQUES. EVERYTHING THAT'S KNOWN ABOUT THE CHEMICAL IS HERE. AND YOUR EMPLOYER MUST HAVE ONE FOR EVERY CHEMICAL IN YOUR WORKPLACE. THE'MATERIAL SAFETY DATA SHEET COVERS: 1. IDENTITY WHO MAKES IT, THEIR ADDRESS, EMERGENCY PHONE NUMBER AND DATE PREPARED. 2. HAZARDOUS INGREDIENTS YOU'LL .FIND THE SUBSTANCE'S HAZARDOUS COMPONENTS, CHEMICAL ID AND COMMON NAMES. WORKER EXPOSURE LIMITS TO THE CHEMICAL, SUCH AS THE OSHA PEL, ACGIH TLV AND OTHER RECOMMENDED LIMITS ARE ALSO INCLUDED. THE ONLY TIME Y0~ WON'T FIND THE IDENTITY OF A CHEMICAL IS WHEN IT'S A TRADE SECRET. BUT THE MATERIAL SAFETY DATE SHEET WILL STILL TELL YOU ABOUT ITS HAZARDS AND THE SAFETY MEASURES THEY REQUIRE. 3. PHYSICAL AND CHEMICAL CHARACTERISTICS 1. BOILING POINT 2. VAPOR PRESSURE 3. VAPOR DENSITY 4. MELTING POINT 5. EVAPORATION RATE 6. WATER SOLUBILITY 7. APPEARANCE AND ODOR UNDER NORMAL CONDITIONS PHYSICAL HAZARDS SUCH AS FIRE AND EXPLOSION AND WAYS TO HANDLE THOSE HAZARDS, SUCH AS FIRE FIGHTING EQUIPMENT AND PROCEDURES. REACTIVITY TELLS YOU WHETHER THE SUBSTANCE IS STABLE. YOU'LL LEARN WHICH SUBSTANCES AND SITUATIONS TO KEEP IT AWAY FROM SO IT WON'T REACT. HEALTH HAZARDS THIS SECTION WILL TELL YOU HOW THE CHEMICAL COULD ENTER THE BODY, FOR INSTANCE: 1. INHALING 2. THROUGH THE SKIN 3. SWALLOWING YOU'LL ALSO LEARN ABOUT ALL THE POSSIBLE HEALTH HAZARDS THAT COULD COME FROM EXPOSURE. IF THE CHEMICAL IS BELIEVED TO BE A CARCINOGEN, THAT WILL ALSO BE LISTED. HEALTH HAZARDS ALSO COVERS SIGNS AND SYMPTOMS OF EXPOSURE SUCH AS: 1. EYE IRRITAION 2. NAUSEA 3. DIZZINESS 4. SKIN RASHES 5. HEADACHE 6. EXISTING MEDICAL CONDITIONS THAT COULD BE AGGRAvATED BY EXPOSURE PLUS EMERGENCY AND FIRST AID PROCEDURES IF AN ACCIDENT HAPPENS. PRECAUTIONS FOR SAFE HANDLING AND USE WHAT TO DO IF THE SUBSTANCE SPILLS OF LEAKS. HOW TO DISPOSE OF THE SUBSTANCE. EQUIPMENT AND PROCEDURES NEEDED FOR CLEANING UP SPILLS AND LEAKS' PLUS HOW TO HANDLE THE SUBSTANCE PROPERLY, HOW TO STORE IT AND ANY OTHER PRECAUTIONS. 8. CONTROL MEASURES TO REDUCE HARMFUL EXPOSURE ARE LISTED IN THIS SECTION. YOU'LL FIND OUT WHAT TYPE OF: 1. RESPIRATOR 2. GLOVES 3. EYE PROTECTION 4. PROTECTIVE CLOTHING 5. VENTILATION TO USE WHEN HANDLING THAT PARTICULAR CHEMICAL. NOTE: MOST PEOPLE IN THE PRODUCTION AREA DO NOT HANDLE CHEMICALS. BUT KEEP IN MIND THAT FLOUR IN CONTAINED AREAS IS EXPLOSIVE AND UNDER THE RIGHT CONDITIONS WILL EXPLODE. FOR THIS REASON THERE CAN BE NO OPEN FLAMES OR ANY TYPE OF SPARKS IN THE PRODUCTION AREAS. ALSO MINERAL OIL HAS A FLASH POINT OF 440°. OUR OIL WILL NOT GET THAT HOT. PLEASE KNOW THIS INFORMATION AND READ ALL MSDS SHEETS THAT ARE PROVIDED. ARCO PRIME OIL 'WHITE MINERAL OIL ZEP FAST GASKET BLUE DYNA 143 AMINE-B (CLEANER) FS 3389 (SANTIZER) SANITARY SPRAY LUBRICANT USP ZEP 45 (PENTRATING OIL) GEORGIA PACIFIC CORPORATION SODIUM HYPOCHLORITE (BLEACH) S.C. JOHNSON & SON HORIZON 100 GLASS CLEANER CREW TOILET BOWL CLEANER HILTI HEA (VINYL ESTER RESIN SYSTEM PACKED IN.GLASS TUBES) CLEANING AGENT FOR CB 120 FILLER FOAM HIT-Cl00 DOWELLING POLYURETHANE FOAM CB 120-R1 (CLEANING AGENT FOR CB 120 FILLER FOAM) DUBOIS CHEMICAL INC. GCO 10 WITH VISIGARD (COOLING TOWER TREATMENT COMPOUND) NATIONAL LABORATORIES INSTITUTIONAL D-CON JET STREAM ANT.& ROACH KILLER SPRAY LOCTITE CORPORATION SUPERBONDER 414 INSTANT ADHESIVE SARA TITLE III SUPERBONDER 414 INSTANT ADHESIVE 10 ML PERMANENT TL 262 (ANAEROBIC) CROWN SAFETY SOLVENT. MOBIL 0IL CORPORATION LUBE 0IL SHC 629 SHC 600 SYNTHETIC LUBRICANTS FISKE BROTHERS REFINING COMPANY LUBRICATING GREASE RHONE-POULENC SAFE GRIP ANTI-SLIP ABSORBENT OLIN 0LIN 2121 COOLING WATER TREATMENT HARCOS CHEMICALS SILICONE ANTIFOAM 10 FG 3M HIGH TACK ADHESIVE DAP INC. WELDWOOD 200.0 NONFLAMMABLE CONTACT CEMENT PHILLIPS 66 MIXTURE KEROSENE ~ PHILUBE SMP GEAR OIL, SAE 80, 90 AND 140 PHILLIPS 66 HDS OIL DIESEL FUEL SUPER HD BOWMAN'DIST. GALV-COAT LUBRIPL~TE (FISK BROS.) FMO 350 HYDRAULIC OIL APG-75 CHAIN & CABLE FLUID LUBRIPLATE N0.1200-2 FLG-0 FLG-1 FLG-2 LOCTITE EXTEND (R) RUST TREATMENT BERNZOMATIC PROPANE TELEDYNE BIG BEAM/EMERGENCY LIGHT SAB NIFE ST-NT PRIMARY BATTERY SERIES · NICKEL CADMIUM POCKET PLATE STORAGE BATTERY ALCAD POTASSIUM HYDROXIDE SULFURIC ACID POWER BATTERY CO. LEAD ACID BATTERY NATIONAL SANITARY STINGER SANI-TUFF E-2 RATED CLEANSER NBC CONCENTRATE HILL BROS.Cr~ICAL CO. ANHYDROUS AMMONIA VAN WATERS & ROGERS PROPY~.RNE GLYCOL S~r.F. CLAvus (R) OIL 68 FU~.r. RR-O ' BRIEN SOLVENT BASED .ARCHITECTURAL COATINGS PRIMERS,SEAr.~S AND TOPCOATS MIRA-PLATE FU~.F?~PLAST CATALYST METAL ETCH PRIMER CATALYST,FAST THINNER LACQUER, PLASTISYN ,STAIN TRAFFIC PAINT CITY of BAKERSFIELD' Far~ and Agriculture r] Standard Business J'] HAZARDOUS MAT ERIALS INVENTORY TO BE COMPLETED NON--TRADE SECRETS AT LATER DATE Paq~ ..... Tl~It'~ N NAHE H J. Heinz · .,,. NAM _0F THIS FACILITY: Bakersfield,CA BUSINESS NAHE: PE.C, TI~TTTn. W~C'ltr'lq ' - ' cL?¢ATIOH: 68UU MCD.1.V].£c-Dr: ..... ~[D~SS; ~..L), Box §/ ,.,. ,,.-,--,n . ST^~UARD ]ND. CLASS CODE.= '~r:'.'-]~.-'.' '~'--' IY. ZiP: _Bake.r~.LP-.~LgL.,_.CA '-J3304 CITY. ZiP: ~-~_L~uu£.~, ,-,~, ..... DUN AND BRADSTREET NUHBER ......... PHONE ,: --~Ub-U.50-.L:)~o '-- /~-[-I~'L~ "~O-~~N~ROP~---R CODES --- - ? ] 4 5 ~ 8 9 I0 II 12 IHns !yqe ~ax Average Annual Heasure I ~ont ~ont ~ont ~e Location Vhece u,, Stored In Facility S~e Instruct~o~ code A,~ Ant c~ ' Units ~ _/ype tress leap Physical and Health XHard C.A.a. Hu,ber 7664417 Co,ponent II Xa,e I C.A.S. Humber IChec~ ali that applyJ . Co,ponen[ Hane C,A.S, Humber ~ire ~azard ~ Reactivit~ ~ Delayed ~ Sudden Release ~l,~ediate Health et Pressure Health Coeponent 13 Haee ~ C.A.S. Nueber [hsical and Health ~azard C,A.S. Hueber -- Coaponent II Haee I C.A.a. Huaber I~hec[ al/ that applyJ ~ ) Comp:esso: O~[ , Component 12 Naee & C.A.S. Humber Fire ~azard O Reactivity ~ Delayed ~ Sudden Release ~ ie~i~ 1) ~nr R~ Oil Health o~ Pressure Coeponent la Haee S C.A.S. ~ueber ~PhlSiCal and ~elith Hazard C.A.S. Humber ,. Co~ponent II Ha~e i C.A.S. Humber ICheck all that applyl Coeponent I~ Ha,e ~ C.A.S. Hunber __ Health · of Pressure CoepOnent 13 Xa~e i C.A.S. Humber [ ~h~sicll Ind Health ~alatd C.A.a. Hueber. Co,ponent II Hane I C.A.S. Humber IChec~ ali that applyl Conponent m2 Nane i C.A.S. ~ueber Fire,azard ~ Reactivity ~'Oelayed ~ Sudden Release ~ Health o~ Pressure Conponent 13 Hsne I ¢.A.S. Hunber A1 Sautner Plant M~---- ~C~F~N---- 1t2 Leo Vadnais EH£RGENCY CONTACTS 111R11~ Ire'lie Title ] g ,91~ c fens ~~~-~ :.,rtili;,ti0, (Read and_$fgn aftpr' cOmpTet:,ffa,iliar,lt~l~e~n[o[e~ttpnaubeltte~ In this.lndall . cert,fy.u,der oenalt, o,,a, thqt , ,aYe peEsonaj,y, exaHnqqaqo la ~h t~ <uached docueeflt, 'hi tMt eased on ay inquiry 9t.tnose inDiviDuals respons~ble.~for obtaining cna /nforAat~on. ] believe a '-~tted l~for~l IS true. accurate, aha coep/eLe. :: ..... NON ROUTINE TASKS THE CLEANING OF THE SILO REQUIRES THE EMPLOYEE TO COME.INTO CONTACT WITH THE CHEMICAL : SODIUM R'YPOCR'LORITE OR BLEACH. HAZARDS OF SODIUM R'YPOCR'LORITE (BLEACH) ARE: 1~. WILL CAUSE IRRITATION TO EYES AND SKIN IF , OVEREXPOSED. BEFORE USING THIS CHEMICAL ON SILO'S PLEASE REFER TO THE MSDS SHEET, AND FAMILIARIZE YOURSELF WITH THE PROVIDED INFORMATION. NOTE: THIS BOOK WILL BE UP-DA~ED AS NEEDEDD EXTERNAL REPORTING CHART PAGER 398-2695- PAGER.398-2684- PAGER 398-2693- BAKERSFIRLH FIRE HAZARD MATERIAL DIVISION 805-326-3979 CALIFORNIA OFFICE OF ]~IERGENCY'RESPONSE 800--852--7550 9]6--427--434] 805-861-3682 NATIONAL RESPONSE CENTER 800-852-7550 WORKER SPILL AL SAUTNER-OFFICE-837-8461 HOME -833-1397 LEO VADNAIS-HOME -836-0995 STAN BRYAN -HOME -393-4725 PAGER-398-2694 AS NEEDED <DEPENDING ON TYPE OF SPIIJ. OR FIRE / RESCUE 911 805-324-4542 BAKERSFIF_.LD POLICE 805-327-7111 CALIF.HWY.PATROL 805-3255822 VACUUM TRUCK SERVICE M. P. VACUUM 805-393-1151 805-589-5220 HAZARDOUS MATERIAL DISPOSAL CO. K.E.S '805-589-5220 CFIRMICALWASTE MGT. 800-222-2964 WASTE CONTROL SERVICE 805-399-4620 PESTRITTO FOODS, IN¢. ,~ BAKERSFI~.n, CA. EMERGENCY RESPONSE PROCEDURES WHEN PLACING CALL TO EMERGENCY RESPONSE AGENCY,THE FOLLOWING INFORMATION WILL BE PROVIDED: · NAME OF PERSON MAKING THE CALL · NAME OF THE COMPANY · ADDRESS AND PHONE NUMBER OF T~E FACILITY · REASON FOR THE CALL (i.e. WHET~ER A NOTIFICATION IS BEING MADE OR EMERGENCY RESPONSE IS BEING REQUESTED) · IF EMERGENCY RESPONSE IS BEIN~G REQUESTED,A BRIEF DESCRIPTION OF THE EMERGENCY (e.g. FIRE,EXPLOSION,ABM ~.RASE) AND ~ EMERGENCY MEDICAL RESPONSE IS REQUIRED. · W~RRE PESTRITTO FOODS,INC.~ERSONNEL WILL MR. RT THE RESPONDING AGENCY MEDICAL ASSISTANCE PROCEDURE THE FOLLOWING LOCAL EMERGENCY ~ICAL FACILITY WILL BE USED IN THE EVENT OF AN EMERGENCY: · MERCY HOSPITAL 22]5 TRUXTON AVE. BAKERSFIELD,CA. 9330] (805) 328-5223 THE FOLLOWING LOCAL AMBULANCE SERVICE WILL BE USED IN THE EVENT OF AN ~ERGENCY: · ~ALLAMBULANCE SERVICE PARAMEDIC SERVICE (805) 327-4111 PERSONNEL CHECKLIST NAM~ PRESENT. AT HOME. MISSING OFFICE AL SAUTNER-PLANT MANAGER MARGE SAUTNER-ADMIN.ASST. MONICA GU I ~.~.RN-RECEPT IONIST LEO VADNAIS-MAINTENANCE SUPERVISOR STANLEY BRYAN THOMAS NORD PRODUCTION JOHN L OPEZ-MIXER DANNY 0 ' NEAL-MIXER LARRY CRIDDLE-MACHINE OPERATOR KATHY TYMN-BELT INSPECTOR MIKE SOLOR IA-FLOATER PACKAGING (MEZZANINE ) MARIA PEREZ-BOXER DEBBIE HUNSUCKER-PACKER EMILY EDIAMISTON-PACKER TINA MARTINEZ-PACKER FREEZER DAVE WELCH-SKIDDER BEN PATTERSON-SHIPPER ROGER ~ P~STRITTO I~D$~INC. II~O~I~ COI~.~$POND~NC~ INQUIRY (MEDICAL EMERGENCY) SHOULD AN INJURY OCCUR AT PESTRITTO FOODS INC. THE FOLLOWING STEPS SHOULD BE OBSERVED BY ALL PERSONNEL: 1)PREVENT LOSS OF BLOOD 2 ) MAINTAIN BREATHING 3)PREVENT INDIVIDUAL FROM FURTheR INJURY 4)PREVENT SHOCK 5)NOTIFY YOUR IMMEDIATE SUPERVISOR SUPERVISOR WILL BE RESPONSIBLE FOR THE TRANSPORT OF INJURED INDMDUALS TO A MEDICAL FACILITY. THE FOLLOWING LOCAL EMERGENCY MEDICAL FACILITY WILL BE USED IN THE EVENT OF AN EMERGENCY: · MERCY HOSPITAL 2215 TRUXTON AVE. (805) 328-5223 TItE FOLLOWING LOCAL AMBULANCE SERVICE WILL BE USED IN THE EVENT OF AN EMERGENCY: · HALL AMBULANCE SERVICE' PARAMEDIC SERVICE (805) 327-4111 PESTRITTO FOODS INC. INTEROFFICE CORRESPONDENCE PERSONNEL QUALIFIED TO USE EMERGENCY EQUIPMENT(BAKERSFI~.~ DMSION) BUSINESS PLAN THE. PERSONNEL BELOW HAVE BRRN QUALIFIED AND TRAINED TO USE EMERGENCY EQUIPMENT: AIR PURIFYING , SCBA CPR : EQUIP. (MASK) CERTIFIED CERTIFI~ AL SAUTNER X X LEO V'ADNAI S X X sTANLEy BRYAN X X THOMAS NORD X X MARY McARTHUR X ADDITIONAL QUALIFIED PERSONNEL WILL BE TRAINED. Internal Reporting Responsibilities Personel Worker Area Supervisor Utilities Foreman (Maintenance Engineer) Resident Engineer (Environmental Coordinator) Safety Manager Plant Manager Environmental Staff · ~-,,. '.. - . Res ponsibil ity Report incidents immediately; "no doubts, always report" Decide if incident involves priority substance and report; report to main- tenance engineer if in doubt; initiate prescribed contingency plans Inspect, assess, take actio~,"repo~t; seek confirmation on action if in doubt; initiate safety and health procedures or other contingency plan ~Decide if incident rep?table to agencies; if in doubt, consult corporate staff; inform Plant Manager and corporate staff of decision; confirm action taken Confirms action taken: decides if'local outside emergency units should be involved; assists Resident Engineer if incident is reportable and demands immediate outside agency assistance Coordinate all activities involving incident; inform appropriate managers; prepares PR agent and controls information flow and actions taken Confirms decision to report to agencies; advises on corrective action; prepares PR agent; liason with Legal Staff PESTRITTO FOODS, INC. BAKERSFI~.~, CA. HAZARDOUS SUBSTANCE COMMUNICATION PROGRAM INVENTORY An inventory has been taken and a complete list of all hazardous substance has been compiled. Material Safety Data Sheets (MSDS) have been received from the manufacture or from vendors distributing these substances. All shipments of hazardous substances must include the Material Safety Data Sheet with the delivery.: If the Material Safety Data Sheet is not included the shipment should not be accepted. The master inventory should contain the following information for each substance listed: 1) .Identification of the product Location of the Material Safety Data Sheet 3) Maximum amount handled/stored at any one time. The master inventory of hazardous substances will be-kept current and maintained by: MARGE SAUTNER ADMINISTRATIVE ASSISTANT .Each workplace where substances are stored, handled or utilized must be posted with a list of those, substances. Workplace postings will be located at the plan~ office and each supervisor has these as part of their Business Plan and Environmental Incident Plan. Any product received without the appropriate Material Safety Data Sheet requires follow up with the distributor. If the distribu- tor has working days from the date of. request the local Occupational Safety and Health Administration Office must be notified. These follow up procedures will be the responsibility of the supervisor responsible for the product. MATERIAL SAFETY DATA SHEETS Material Safety Data Sheets will be obtained'~and kept on file for all hazardous substances purchased, stored, used or handled by the PESTRITTOFOODS,INC. PLANT (BAKERSFI~.D,CA.) ...... Material Safety Data Sheets will be kept on file wit~ each indi- vidual supervisor. EMPLOYEE TRAINING Employee training will be provided to each employee on all hazar- dous substance he or she may come in contact with or be exposed to while working for PESTRI~COFOODS,INC. Current employees have received appropriate training as a 'group. Each group will consist of employees utilizing or having possible exposure to the same or similar hazardous substances. This group training will enable the training to be as specific as possible. The training program will -be on-going ~with additional training presented as new substances are introduced into our operations or if information on current Material Safety Data Sheets significa- tly changes. A significant change entails new information indi- cating an increased risk in the use of the substance and/or changes in the measures necessary ~%o protect the employees from exposure. In addition to employees being updated on significant changes and new products, training will be conducted as follows; 1) Initial training 2) Annual re-training 3) Newly hired employees will receive training immediately upon starting work. 4) Specific training for all non-routine tasks. 5) Vendors/contractors will receive training on hazardous substances they could be exposed to while on company premise. All training and re-training will be thoroughly documented as to the trainers, course outline, and those in attendance. Training, re-tFaining programs and all documentation of training programs will be conducted'under the direction of each individual .supervi- sor with plant wide coordination from ALSAUTN~R/PLANTMANAGER Employee hazardous substance training shall include the follo- wing: An. explanation of what a Material Safety Data Sheet is, its intended purpose and how to read and interpret the informa- ti:on provided on the Material Safety Data Sheet. An, explanation of the information provided on the Material Safety Data Sheet: --the health hazards associated with the use and/or exposure .to exposure to the substance --proper handling for safety to reduce the exposure --personal protective equipment which is necessary or.recom- mended during handling or use of the substance. --Emergency procedures for spills, fires, first aid and dis- posal --other safety precautions necessary to prevent or minimize exposure to the subshance. C. An explanation of the information on the container labels. An explanation of the right of the employee to obtain a copy of any Material Safety Da~ta Sheet by following the procedures explained in the "Material Safety Data Sheet" section of this policy. An explanation of the right for a collective bargaining agent or a treating physician to obtain a copy of any Material Safety Data Sheet upon following the proper procedures explained in the "Material Safety Data Sheet" section of this policy. Fo An explanation of the employee ' s protection from termination, discrimination for retaliation by the company for exercising rights under the General Industry Safety Orders. LABELS All containers, to include secondary containers, holding hazar- dous substance will be labeled with at least the following .information. --A complete identity of the product. --All appropriate hazard warnings and safety precautions. It is the responsibility of each employee to be certain that all containers have proper label with the appropriate information and that ail labels are securely attached to the containers. Sub- stances which do not have the proper label and/or cannot be identified are not to be used, handled or stored. If containers are'found without proper' labels notify MARGE SAUTNER~ Shipping and.reCeiving will not ac- cept shipments of materials that are not properl~ labeled. DISCIPLINARY PROCEDURES Employees will comply with all safety rules and regulations implemented by Gist-brocades Food Ingredients Incorporated for the purchasing, storing, handling and/or using hazardous substan- ce. Disciplinary action taken will be within the guidelines as defined in the company employee handbook. PESTRITTO FOODS, INC. BAKERSFIF. LD, CA. FIRE ACTION PLAN WHEN THE FIRE ALARM SYSTEM IS ACTIVATED BY EIT~RR SMOKE OR ~3%T A SIGNAL IS SENT TO "SECURE". "SECURE" WILL ~ DISPATCH THE FI_RE DEPARTMENT. ONCE THE ALARM SOUNDS IT BECOMES THE RESPONSIBILITY OF ALL SUPERVISORS TO CHECK THEIR RESPECTIVE DEPARTMENTS FOR FIRE LOCATIONS.T~RN,ANNOUNCE THE FIRE LOCATIONS OVER THE PUBLIC ADDRESS SYSTEM (TELEPHONE ADDRESS SYSTEM) AND DETERMINE IF EVACUATION OF T~E PLANT IS NECCESSARY. IF NECCESSARY, ACTIVATE THE EVACUATION HORN. PESTRITTO FOODS,INC. PERSSONEL WILL ATTEMPT TO FIGHT FIRES OF A NATURE ONLY,i.e., TRASH CANS,RAGS,ETC. A MAP SHOWING THE EVACUATION AREA IS POSTED THROUGHOUT THE PLANT WITE ARROWS SHOWING THE PRIMARY ESCAPE ROUTES. SHOULD EVACUATION BE NECCESSARY,ALL PERSONNEL SHOULD EXIT THROUGH THE RESPECTIVE EXIT ASSIGNED TO EACH SECTION OF THE PLANT,AND REPORT TO THEIR IMMEDIATE SUPERVISOR. EACH SUPERVISOR WILL BE RESPONSIBLE FOR ASSURING T~AT THEIR PERSONNEL EVACUATE THE BUILDING AND ARE ACCOUNTED FOR. AFTER A ~]~3%D COUNT, EACH SUPERVISOR WILL REPORT MISSING PERSONS TO THE PLANT MANAGER. IN AN EVACUATION FOLLOW T~E "EVACUATION PLAN".WHEN EVACUATING T~E BUILDING FOLLOW THE RULES BELOW: 1 ) LRAVE ALL PERSONAL BELONGINGS 2) WALK,DO NOT RUN,TO EXITS 3) IF AN AREA IS COVERED WITH DENSE SMOKE, CRAWL TO AN EXIT 4) STAY IN THE ASSEMBLY AREA UNTIL TOLD TO LEAVE BY THE ACTING PLANT MANAGEMENT 5) DO NOT RE-ENTER T~E BUILDING UNLESS AUTHORIZED FIRE DEPARTMENT S.D. JOHNSON FIRE CHIEF CITY of BAKERSFIELD "WE CARE" September 6, .1991 2101 H STREET BAKERSFIELD, 93301 326-3911 A1 Sautner Plant Manager Pestritto Foods, Inc. 6800 McDivitt Dr. Bakersfield, CA 93304 Mr. Sautner: In their letter to Bakersfield Fire on 8-6-91, Luft Environmental indicated that the safety, evacuation, and emergency procedures.addressed in Pestritto's Risk Management and Prevention Plan (RMPP) are a part of or by-product of Pestritto's Emergency Action Plan. I requested a copy of this plan from Luft because it was used as a basis for the Risk Management Plan. Luft sent only the evacuation section of the Emergency Action Planl Bakersfield Fire is requesting that you supply us with a full copy of the Emergency Action Plan because it was used as a reference and basis for' several sections of the RMPP. Please send the Emergency Action Plan to me at: Bakersfield Fire Department 2130 G St. Bakersfield, CA 93301 Thank you for your cooperation and I look forward to 'working with you in the future. Sincerely, Barbara Brenner Hazardous Materials Planning Technician cc: Ralph Huey LUFT ENVIRONMENTAL,CONSULTING 3701 Pegasus Drive, Suite 121 Bakersfield, California 93308 · (805) 399-5838 ' '~ ':~- ' ' 'AugUst 26, 1991" Barbara Brenner Hazardous Materials Planning Technician Bakersfield City Fire Department 2101 "H" Street Bakersfield, CA 93301 Ms. Brenner: Enclosed'are.,t~he.~reSpOnses to your August 12, 1991' letter regarding the RMPP for Pestritto Foods Inc. If you have. any questions concerning the enclosed, please contact me at your convenience. .. Principal Mechanical Engineer cc: Larry Wuethrich - Pestritto Foods, Inc. w/enclosures Larry Rolisdn - Tri-Com Refrigeration Inc. w/enclosures LEC-91-0286 PF-01 Responses to Bakersfield City Fire Department's Comments on Pestritto Foods Inc.'s Risk Management and Prevention Program BCFD comment regarding 25534 (d) (1): 25534 (d) (1) The scope of a Risk Management Plan is not limited to equipment failure in systems which normally handle an acutely hazardous material. The existence of the emergency ammonia ventilation system was documented in Section V of the RMPP and described in the haz-op as able to mitigate an ammonia release. However, this equipment had not been evaluated in regard to it's operability and potential hazards. Risk Management and Prevention Programs are designed to address situations that are not normal. Response: The. scope of the RMPP, according to Section 25532, inCludes all administrative and operational programs of a business which are designed to prevent acutely hazardous materials accident risks. An acutely hazardous materials accident risk is defined as the potential for the release, of an acutely hazardous material into the environment which could produce a significant likelihood that persons exposed may suffer acute health effects resulting in significant injury or death. Although there is no language that expressly limits the RMPP to systems that handle acutely hazardous materials, it is very apparent that the RMPPs are to address the systems that present an acutely hazardous material accident risk. Generally, the only way for a system 'to present an acutely hazardous material accident 'risk is to handle an acutely hazardoUs material. Pestritto Foods Inc.'s emergency ventilation system does not pose an acutely. hazardous material accident risk. The installation of this system does not change the probability of occurrence, or the severity of an acutely hazardous material accident, The emergency ventilation system is only a mitigation measure that was installed pursuant to the Bakersfield City Fire Department's interpretation of the 1988 Uniform Fire Code, Article 80. The Offsite Consequence Analysis performed for this facility was based on an unlikely Page 1 failure of a 3 inch liquid ammonia line Outside of the engine room. The location of the failure was purposely set outside of the engine room where the emergency ventilation system would not help mitigate the release. Even under adverse weather conditions, the air dispersion modeling showed that there would probably not be any significant health effects to sensitive receptors from this unlikely, worst credible release. Therefore, it appears that the health and safety of the sensitive receptors (from this unlikely release event) would not be significantly impacted, whether or not the emergency ventilation system operates. Additionally, as stated in Section 25534 (d) (1), the RMPP shall consider "[t]he results of a hazard and operability study which identifies the hazards associated with the handling of an acutely hazardous material due to operating error, equipment failure, and external events, which may present an acutely hazardous materials accident risk." Since the emergency ventilation system does not handle acutely hazardous materials, does not present an acutely hazardous materials accident risk, and is not required to protect the health of sensitive receptors from the worst case release, the system does not need to be included in the HazOp Study. BCFD comment regarding 25534.5: 25534.5 There had been no response to the requests for additional information made by Bakersfield Fire in the letters to Luft Environmental dated July 8 and July 12, 1991. The information necessary for the Administering Agency to determine the sufficiency of the RMPP was incomplete~ Response: The BCFD letter of July 8 was based on a draft HazOp matrix submitted June 28, 1991. On July 10, 1991 the draft HazOp Study and'modeling results were hand delivered. BCFD's July '12, 1991 letter indicated that several of the questions from the July 8 letter were adequately addressed in the draft HazOp Study and the modeling results. BCFD's July 12, 1991 letter also contained three questions concerning the drafts that were hand delivered on July 10, 1991. All three questions in the July 12, 1991 letter were addressed in either the RMPP, HazOp Study, or the Offsite COnsequence Analysis. Final responses to all questions were provided on August 6, 1991 when the signed' RMPP was delivered to the BCFD. We felt that we were being responsive to the BCFD letters with our submittals. However, based on the July 26 and August 12 letters from Page 2 the BCFD, it is apparent that the BCFD did not believe that these responses were adequate; We regret this apparent misunderstanding. BCFD comment #1: Describe the potential failures modes and abnormal operating conditions possible in the emergency ammonia ventilation and absorption system which are mentioned in the second paragraph, page 2 of Luft's correspondence dated August 6, 1991. Include a discussion of the hazards resulting from operational deviations. Response: The BCFD comment was based on the following paragraph: "Since the water tank is a passive scrubber design, there are very few potential failures that could occur in the system under normal operation. However, potential failures could occur in the emergency ventilation system. If the ambient ammonia sensor fails, the system can still be activated via the manual switch S2. There is even a separate emergency electrical power circuit designed into the system." Potential failures for emergency ventilation system include: 1. Solid state ammonia sensor failure. 2. Emergency fan motor failure. 3. Solenoid failure. 4. Water pump failure. 5. Motor control center failure, or fan or water pump failure. In regards to "abnormal operating conditions", the system either works, or fails, according to the above listed potential failures. Since the absorption system is .passive, the only failure could be loss of water due tooperator error or tank failure. There are no additional hazards associated with the failure of the emergen(~y ~ventilation system or the passive scrubber system~~ The offsite consequence analysis showed that thers, would not be a serious health threat to sensitive receptors as a result of the worst credible release. This analysis was performed without the benefit of these emergency systems. The potential exPosures to plant personnel from an ammonia release in the engine room will occur whether or not the emergency systems operate. This is one of the reasons that Pestritto personnel will be trained in the use of self contained breathing apparatus and emergency response procedures. Page 3 .Both of these emergency systems do not alter the acutely hazardous materials accident risk. Both systems are mitigation requirements pursuant to the BCFD interpretation of Article 80 of the Uniform Fire Code, 1988 edition, and not a result of the offsite consequence analysis. Both of these systems will, however, reduce the duration of exposure to sensitive populations, including plant personnel. BCFD comment #2: The excess flow requirement is based upon the plans for the Pestritto plant which the City of Bakersfield Building and Fire Departments approved. That Kern County Building Department approved this system has no bearing due to the facility's location withing the City of Bakersfield. The fact that this system is designed to meet other existing codes does not change the requirement for excess flow control on anhydrous ammonia piping pressurized above 15 psig. Response: Tri-Com Refrigeration will be responding directly to this comment. BCFD comment #3: Submit a copy of Pestritto Food's Emergency Action Plan which is being used as a reference for the RMPP. Response: Enclosed is a copy of the evacuation portion of the Pestritto Food's Emergency Action Plan. Page 4 PESTRITTO FOODS, INC. BAKERSFI~-?.n, CA. AUGUST 8,1991 INTEROFFICE CORRESPONDANCE I HAVE BRRN INSTRUCTED BY SUPERVISOR ON THE FOLLOWING: 1)FIRSTAID PROCEDURE/LOG~LL ACCIDENTS 2)FIRE/EARTHQUAKE/~ICAL RFr.~ASE EMERGENCY PROCedURE 3)EVACUATION PROCEDURES-WHO'S IN CHARGE,WHERE TO GO...ETC. 4)WHAT OUR PLANT ALARM SOUNDS LIKE. 5)LOCATION OF M.S.D.S. ("RIGHT TO KNOW" STATION. 6)POLICY ON 'DRUG SCRR~NING W~RNACCIDENTS OCCUR. *IN THE EVENT OF AN EMERGENCY YOUWILL HEAR THREE (3) SHORT "B~RPS" OVERT HE INTER-COM... YOU WILL BE INSTRUCTED OF EVACUATION PROCEDURE,IMMEDIATLY SHUT DOWN~F~.MACHINERY,TO DO SO,DEPRESS THE RED EMERGENCY STOP BUTTONS Twin PROC~ TO EXIT THE BUILDING IN THE DESCRIBED MANNER. I UNDERSTAND ANDAG~R. TO ABIDE BY THEABOVEMENTIONED pROCEDuRES. SIGNED DATE JU~ 31,1991 PESTRITTO FOODSw INC 6800 McDIVITT DRIVE BAKERSFIEI~D, CA o 933 EVAC. AREA _ , _M.c~VITT 'A "PESTRITTO FOODS OF CALIFORNIA" EVACUATION FROCEDURES AND POLICY POLICY: IT IS THE POLICY OF THE COMPANY TO PROVIDE A SAFE EXIT IN THE EVENT OF A FIRE AND/OR AMMONIA LEAK. EMPLOYEES ARE EXPECTED TO COMPLY WITH ALL SAFETY REQUIREMENTS WHETHER ESTABLISHED BY MANAGEMENT OR BY FEDERAL, STATE, OR LOCAL LAW. PROCEDURE: EMPLOYEES WILL BE REQUIRED TO ATTEND A SAFETY ORIENTATIION MEETING THAT WILL ADVISE THEM OF THE PROPER PROCEDURES IN THE EVENT OF AN EMERGENCY EXIT. 1. ONE PERSON WiLL BE APPOINTED IN EACH DEPARTMENT TO BE RESPONSIBLE TO OVERSEE THE EVACUATION OF THEIR AREA. o UPON REACHING THE DESIGNATED AREA THE APPOINTED PERSON IS RESPONSIBLE FOR TAKING A HEAD COUNT, THUS MAKING SURE ALL EMPLOYEES ARE ACCOUNTED FOR. o EACH DEPARTMENT WILL ALSO HAVE A SECOND PERSON APPOINTED, THAT IN THE EVENT THE DEPARTMENT HEAD IS ABSENT, WILL OVERSEE THE SAME EVACUATION PROCEDURES. SAFETY EVACUATION PROCEDURE: IN THE CASE OF A FIRE AND/OR AMMONIA LEAK AN OFFICIAL WILL BROADCAST OVER THE PUBLIC ADDRESS SYSTEM THAT AN IMMEDIATE EVACUATION IS NECESSARY. IN THE EVENT THAT THE PUBLIC ADDRESS SYSTEM IS NOT WORKING THIS BROADCAST WILL BE BY BULLHORNS THAT ARE LOCATED THRU OUT THE BUILDING. EVERYONE IS REQUIRED TO MEET AT A CENTRALLY LOCATED AREA THAT IS DESIGNATED ON THE ATTACHED MAP. AT THAT TIME THE PLANT MANAGER WILL MEET WITH THE DEPARTMENT HEADS TO GATHER THE HEAD COUNTS OF ALL DEPARTMENTS, MAKING CERTAIN THAT ALL EMPLOYEES ARE ACCOUNTED FOR. PESTRITTO FOODS, INC. BAKERSFIELD, CA. FIRE ACTION PLAN Wff~N THE FIRE ALARM SYSTEM IS ACTIVATED BY EIT~RR SMOKE OR ~3~T A SIGNAL IS SENT TO "SECURE". 'SECURE' WILL THEN DISPATCH THE FIRE DEPARTMENT. ONCE THE ALARM SOUNDS I~ BECOMES THE RESPONSIBILITY OF ALL SUPERVISORS TO CHECK T~EIR RESPECTIVE DEPARTMENTS FOR FIRE LOCATIONS.T~N,ANNOUNCE THE FIRE LOCATIONS OVER THE PUBLIC ADDRESS SYSTEM (TELEPHONE ADDRESS SYSTT~) AND DETERMINE IF EVACUATION OF THE PLANT IS NECCESSARY. IF NECCESSARY, ACTIVATE THE EVACUATION HORN. PESTRITTO FOODS,INC. PERSSONEL WILL ATTEMPT TO FIGHT FIRES OF A SMA]'.]'. NATURE ONLY,i.e., TRASH CANS,RAGS,ETC. A MAP SHOWING THE EVACUATION AREA IS POSTED THROUGHOUT THE PLANT WITH ARROWS SHOWING THE PRIMARY ESCAPE ROUTES. SHOULD EVACUATION BE NECCESSARY,~LL PERSONNEL SHOULD EXIT THROUGH THE RESPECTIVE EXIT ASSIGNED TO EACH SECTION OF THE PLANT,AND REPORT TO THEIR IMMEDIATE SUPERVISOR. EACH SUPERVISOR WILL BE RESPONSIBLE FOR ASSURING T~AT THEIR PERSONNEL EVACUATE THE BUILDING AND ARE ACCOUNTED FOR. AFTER A mAD COUNT, EACH SUPERVISOR WILL REPORT MISSING PERSONS TO THE PLANT MANAGER. IN AN EVACUATION FOLLOW THE "EVACUATION PLAN".WHEN EVACUATING THE BUILDING FOLLOW THE RULES BELOW: 1) LEAVE ALL PERSONAL BELONGINGS 2 ) WALK,DO NOT' RUN,TO EXITS 3) IF ~ AREA IS COVERED WITH D~SE S~KE, CRAM TO ~ EXIT 4) STAY IN THE ASSEMBLY AREA UNTIL TOLD TO LEAVE BY THE ACTING PLANT MANAGEMENT 5) DO NOT RE-ENTER THE BUILDING UNLESS AUTHORIZED PRSTRITTO FOODS, INC. BAKERSFIELD,CA. EMERGENCY RESPONSE PROCEDURES WHEN PLACING CALL TO EMERGENCY RESPONSE AGENCY,THE FOLLOWING INFORMATION WILL BE PROVIDED: · NAME OF PERSON. MAKING T~E CALL · NAME OF THE COMPANY · ADDRESS AND PHONE NUMBER OF THE FACILITY · REASON FOR THE CALL (i.e. WHET~RR A NOTIFICATION IS BEING MADE OR EMERGENCY RESPONSE IS BEING REQUESTED) · IF EMERGENCY RESPONSE IS BEIN~G REQUESTED,A'BRIEF DESCRIPTION OF THE EMERGENCY (e.g. FIRE,EXPLOSION,A~M ~RLRASE) AND WHE'I~RR EMERGENCY MEDICAL RESPONSE IS REQUIRED. · WK~RE PESTRITTO FOODS,INC.~ERSONNEL WILL ~RRT T~E RESPONDING AGENCY MEDICAL ASSISTANCE PROCEDURE THE FOLLOWING LOCAL EMERGENCY MEDICAL FACILITY WILL BE USED IN THE EVENT OF AN EMERGENCY: · MERCY HOSPITAL 2215 TRUXTON AVE. BAKERSFIELD,CA. 93301 (805) 328-5223 THE FOLLOWING LOCAL AMBULANCE SERVICE WILL BE USED IN THE EVENT OF AN EMERGENCY: · HALL AMBULANCE SERVICE PARAMEDIC SERVICE (805) 327-4111 EXTERNAL REPORTING C~ART PAGER 398-2695- PAGER 398-2684- PAGER 398-2693- SPILL AL SAUTNER-OFFICE-837-8461 HOME -833-1397 LEO VADNAIS-HOME -836-0995 STAN BRYAN -HOME -393-4725 PAGER-398-2694 BAKERSFIRT.n FIRE BAZARD MATERIAL DIVISION 805-326'3979 CALIFORNIA OFFICE OF EMERGENCY RESPONSE 800-852-7550 916-427-4341 K.C.A.P.C.D. 805-861-3682 NATIONAL RESPONSE CENTER 800-852-7550 EIT~RR TYPE OF SPILL OR FIRE / RESCUE 911 805-324-4542 B~KERSFIELD POLICE 805-327-7111 CALIF.HWY.PATROL 805-3255822 VACUUM TRUCK SERVICE M.P .VACUUM 805-393-1151 KERN VACUUM SERVICE 805-589-5220 HAZARDOUS MATERIAL DISPOSAL CO. K.E.S 805-589-5220 C~EMICALWASTEMGT. 800-222-2964 WASTE CONTROL SERVICE 805-399-4620 PESTRITTO FOODS INC. INT~OFFIC~ CORRESPONDENCE PERSONNEL QUALIFIED TO USE EMERGENCY EQUIPMENT(BAKERSFIELD DMSION) BUSINESS PLAN THE PERSONNEL BELOW HAVE B~N QUALIFIED AND TRAINED TO USE EMERGENCY EQUIPMENT: AIR PURIFYING SCBA CPR EQUIP. (MASK} CERTIFIED CERTIFIEI AL SAUTNER X X LEO VADNAIS X X STANLEY BRYAN X X THOMAS NORD X X MARY McARTHUR ~ ADDITIONAL QUALIFIED PERSONNEL WILL BE TRAINED. PERSONNEL CHECKLIST NAM~ PRESENT AT HOME. MISSING OFFICE AL SAUTNER-PLANT MANAGER MARGE SAUTNER-ADMIN.ASST. MONICA GUILL~N-RECEPTIONIST LEO VADNAIS-MAINTENANCE SUPERVISOR STANLEY BRYAN THOMAS NORD PRODUCTION JOHN LOPEZ-MIXER DANNY 0 ' NEAL-MIXER LARRY CRIDDLE-MACHINE OPERATOR KATHY TYMN-BELT INSPECTOR MIKE SOLOR IA-FLOATER PACKAGING ( MEZZANINE ) MARIA PEREZ-BOXER DEBBIE HUNSUCKER-PACKER EMILY EDIAMISTON-PACKER TINA MARTINEZ-PACKER ~ FREEZER DAVE WELCH-SKIDDER BEN PATTERSON-SHIPPER PLANT IMPROVEMENT DANIEL RIVAS JAMES TAYLOR 08/22/91 10:13 FAX 949 8249 TRI CO.~ EFR ~002/003 ~¢So ~a~bara Brenner Bak~rsfi~ld City Fire Department HaZardou~ %~aterial Div. 2130 G Street Bakersfield, CA 93301 Subject: Pestritto Foods Ammonia Refrigeration System Response to letter 8/12/91. Dear M$o Brenner: P~r our phone conversation we would like to clarify the control system used on the liquid line referenced in your. letter ~ated 8/12/910 E~c~ss flow control on piping above 15 p~ig will be p~ovi~ by valves that are part of the control system an~ ~ill automatically close if the pressure drops too iow indicating a loss of refrigerant. ~:~% Thl~ is accomplished by monitoring the Pressure in that part of-th~ ~ystemo On-a sudden d~op in-pressure the solenoids ~.r~ dener~ized (closed) stopping additional .~--~ refrigerant from going to the system.. Per your request we reviewed the possibility of installina an excess flow device in the liquld line and found severai problems. ~ 1o Co~Rtruction of most of these devices use threaded :,~"~,~Z. fittings which in 3 inch pipe size is not used on ammonia due to leakage problems. 'c~-' - 2. At or near design flow rates the pressure drop on these devises are excessive (approaches 10 Psi). The ~,~ normal flow coefficient (Cv) for a three inch ~>~' control valv~ i~ 115. The fl0w coefficient for the / ~x~ess flow ~evlce is 41. . . This pressur~ drop will cause Part of the liquid ~a~sing thru the device to flash into a gas and cause ~perational problems with the control valves and affect th~ system op~ration~ Thmse devioem also have a design problem in that at or near design flow they can create pulsations in the flow (chattering) which can cause damage to control ,.:~;s2raph Road n P.O ?a;: 'J'?/- -': Santa Fe Springs, CA _9067D n (21.3) 948-3861 / FAX: (213) c2z~'-.7-8249 o License ¢ 461823 B-l, C-38 ..... ~.. ~- - [ .... ~c.,U.~T~IAL REF[~IGEI~ATION AND COLD S'I"C)RAGI~ SPECIALISTS 0~/22/91 10;14 FAX 2~949 8249 TRI COK REFR: 003/003 d~vices down stream creating the very situation that is trying to be prevented. We hop~ this explains to your satisfaction our system and is acceptable to your Department. Pleasm call me if you have any questions or need any additional information. Sincerely Trl~C~m Re.~-rl~ration FIRE DEPARTMENT SD. JOHNSON FIRE CHIEF CITY of BAKERSFIELD "WE CARE" August 12, 1991 2101H STREET BAKERSFIELD, 9330~ 326-3911 Larry Rolison Tri-Com Refrigeration, Inc. P.O. Box 3866 Santa Fe Springs, CA 90670 Mr. Rolison: The excess flow requirement on anhydrous ammonia piping pressurized above 15 psig at the Pestritto Foods Plant in Bakersfield is based upon the plans approVed by the Bakersfield Fire Department on March 1, 1991. The Risk Management and Prevention Plan submitted for the Pestritto plant does not describe a system which conforms with item #2, regarding UFC Article 80 compliance, in the Tri-Com letter of 2-11-91. .This letter outlining the methods to be used for compliance with the Fire Code is a part of the approved plan. System shut down upon triggering of the engine room ambient ammonia sensor does not provide excess flow control for liquid ammonia lines outside the engine room. Please submit a plan to Bakersfield Fire detailing the method which you intend to use to provide excess flow control for the high pressure· side of the Pestritto Foods anhydrous ammonia System. Sincerely, Barbara Brenner Hazardous Materials Planning Technician cc: Ralph Huey CITY of BAKERSFIELD "WE CARE" FIRE DEPARTMENT SD. JOHNSON FIRE CHIEF August 12, 1991 2101H STREET BAKERSFIELD, 93301 326-3911 Karl Luft Luft Environmental Consulting 3701 Pegasus Drive, Suite 121 Bakersfield, CA 93308 Mr. Luft: The following sections of the California Health and Safety Code (Division 20, Chapter 6.95, Article 2) are the basis for our return of the Pestritto Foods RMPP to you as incomplete. 25534(d)(1) The scope of a Risk Management Plan is not limited to equipment failure in systems which normally handle an acutely hazardous material. The existence of the emergency ammonia ventilation system was documented in Section V of the RMPP and described in the haz-op summary as able to 'mitigate an ammonia release. However, this equipment had not been evaluated in regard to it's operability and potential hazards. Risk Management and Prevention Programs are designed to address situations that are not normal. 25534.5 There had been no response to the requests for additional information made by Bakersfield Fire in the letters to Luft Environmental dated July 8 and July 12, 1991. The information necessary~for the Administering Agency to determine the sufficiency of the RMPP was incomplete. Having reviewed your responses to our questions regarding the Pestritto Hazard and Operability Study and RMPP, I will outline the remaining requirements for completion of this project. Describe the potential failures modes and abnormal operating conditions possible in the emergency ammonia ventilation and absorption systemwhich are mentioned in the second paragraph, page 2 of Luft's correspondence dated August 6, 1991. Include a discussion of the hazards· resulting from operational deviations. .m The excess flow requirement is based upon the plans for the Pestritto plant which the City of Bakersfield Building and Fire Departments approved. That. Kern County Building Department approved this system has no bearing due' to the facility's location within the City of Bakersfield. The fact that this system is designed to meet other existing codes does not change the requirement for excess flow control on anhydrous ammonia piping pressurized above 15 psig. Submit a copy of the Pestritto Food's Emergency Action Plan Which is being' used as a reference for the RMPP. Luft.Environmental's practice of. submitting~the finished RMPP prior to responding to Bakersfield Fire's requests for additional infOrmation regarding hazard, risk and consequence analyses is not satisfactory. We do not wish to impose additional financial burden on your clients~by requiring RMPP modifications. However, there ts no alternative when all of the responses to our concerns· are presented after preparation of the RMPP. In .the future, Bakersfield Fire will not review a RMPP until all outstanding questions'and issues regarding hazard and risk analysis have been resolved. Following my reevaluation of S~ction 25534.5, we have decided that the practice of returning confidential documents to Risk Management Plan preparers will be discontinued. In the future, Bakersfield Fire will retain possession of all such documents. If there is a public request for this information we will notify the appropriate parties pursuant to Division 20, Chapter 6.95, Article 1, Section 25511 of the California Health and Safety Code. I will contact Tri-Comm Refrigeration directly regarding the resolution of item #2 above. Your responses to our other questions are adequate. nf~~cere ly, Barbara Brenner Hazardous Materials Planning Technician cc: Ralph Huey LUFT ENVIRONMENTAL CONSULTING 3701 Pegasus Drive, Suite 121 · Bakersfield, California 93308 · (805) 399-5838 August.6, 1991 Barbara Brenner Hazardous Materials Planning Technician Bakersfield City Fire Department 2101 "H" Street ~ , Bakersfield, CA 93301 Ms. Brenner: Enclosed are the responses to your July 26, 1991 letter, a signed copy of the RMPP Supporting Document, the Hazard and Operability Study, and the Offsite Consequence Analysis for Pestdtto Foods Inc. " In your July 26, 1991 letter, you stated that the above listed documents were being returned "because they are incomplete at this time." Please cite which Sections of Article 2, Chapter 6.95, Division 20, California Health and Safety Code have not been addressed. -,., If you have any questions concerning the enclosed, please contact me at your '~convenience. Karl W. Luff Principal Mechanical Engineer cc: Larry Wuethrich - Pestdtto Foods, Inc. w/o enclosures Larry Rolison - Tri-Com Refrigeration Inc. w/o enclosures LEC-91-0270 PF-01 Responses to Bakersfield City Fire Department's Comments on Pestritto Foods Inc.'s Risk Management and Prevention Program ~/~BCFD comment #1: Define the term "public consequence" as used in the haz-op matrix. include plant employees? Does this Response: This statement does include plant employees.' Whenever "no public consequence" appears in the HazOp matrix, it means that there would not be a public consequence associated with the deviation from design intent. The deviation from design intent, where "no public consequence" appears, does not result in a release of ammonia to the atmOsphere. BCFD comment #2: The ammonia scrubber and absorption system should be included in the Haz-Op Study. Define the system's capacity, limits and any hazards which may be caused by potential failures. Response: The ammonia scrubber and absorption system does not n~ormally~ handle the acutely hazardous material, and therefore was not included in the HazOp study. This system was designed and installed to meet the intent of Article 80 of the Uniform Fire Code pursuant to the Bakersfield City Fire Department's request. Since the ammonia'/TM scrubber and absorption systems were reviewed and approved by the City of Bakersfield and construction permits were issued, it was not addressed in detail in the.,.) RMPP. As far as system capacity, the passive scrubber tank is a 41,600 gallon water tank that will. contain 30,000 gallons of water (approximately 250,000 pounds of water). Since the initial ammonia charge will be 5,000 poUnds, a two percent solution of ammonium hydroxide would be formed if all of the ammonia refrigerant were to be absorbed into the water in the tank. ~'~ Page1 ''~ ~0~\~ :'~ 0~-' ~''~ ~0~ The emergency ventilation system consists of a high flow rate fan (19,150 cubic feet per minute) that discharges into the evaporative condenser. The evaporative condenser sump contains approximately 600 gallons of water that is circulated at a rate of 1030 gallons per minute. Once the system is activated (either automatically or manually), the fan will pull air out of the engine room and blow it into the evaporative condenser. Air is drawn through the evaporative condenser via separate fans at a rate of 102,500 cubic.feet per minute. ~-~- c~z- -~1~-~- ..~a',\J ~ Since the water tank is a passive scrubber design, there are very few potential failures th__at could occur in the system under normal operation. However, potential failures could occur in the emergency ventilation system. If the ambient ammonia sensor fails, · the system can still be activated via the manual switch S2. There is even a separate emergency electrical power circuit deSigned into the system. BCFD comment #3: ~YProvide doc-mentation to support the conclusion that the ammonia delivery hose would fail prior to the damage occurring to the back check valve or the line into the receiver. Is the ammonia delivery line adequately braced? Response: We are not able to provide documentation to support this conclusion since the components subject to this request are normally rated for pressure, not pull apart strength. However, due to the serpentine routing to get the delivery hose to the controlled pressure receiver, it is extremely unlikely that there could be a direct pull on the back check valve or the receiver pipeline during the initial delivery of ammonia. Due to the fact that the routing of the hose will be around several pieces of equipment and that trained personnel, including Tri-Com Refrigeration, will witness the charging of the system, the ammonia line appears to be adequately braced for its intended purpose. After the initial delivery of ammonia, any recharge of the system is likely to be accomplished through the use of compressed gas cylinders. When cylinders are used for the refrigerant recharge, the cylinders will be brought onsite to charge the system and will be removed upon completion of the recharge. Ammonia cylinders will not typically be stored at the plant. Page 2 BCFD comment #4: Will isolation of the liquid ammonia lines be accomplished automatically if a liquid line breaks? ~ System shut down' upon triggering of the engine room ambient o_mmonia sensor does not fulfill, the requirement for excess flow control sensors on pressurized piping above 15 psig. A break in a liquid line outside the engine room must also actuate system shutdown. Please state how this requirement will be provided for pursuant to the method outlined by Tri-Com Refrigeration in the attached correspondence regarding Uniform Fire Code compliance. Response: Isolation of the liquid ammonia line will be accomplished automatically if an ammonia line breaks in the control room and triggers the emergency ventilation system. If the ambient ammonia sensor in the emergency ventilation system detects 200 ppm of ammonia, all solenoid valves will be de-energized (closed) and all compressors will be shut down. All solenoid ~alves can be closed and the compressors shut down manually by operating the emergency shut down switch, S1, outside of the engine room. The current emergency shut down system safely isolates the appropriate segments in the refrigeration system. The requirement for excess flow control would make the control system for the refrigeration system extremely complicated, expensive, and relatively unreliable in comparison with the current system. The flow of ammonia through the refrigeration system, including the. flow to and from the vessels, evaporators, and heat exchangers, is controlled with solenoid valves. Since these solenoid valves are essentially instant on and instant off, there is a surge of fluid each time a solenoid valve opens to establish liquid ammonia flow. It is unlikely that any reasOnable combination of excess flow valves, solenoid valves, and flow meters could cover the range of normal operation without excessive cost and reduced reliability of the refrigeration system. _~'~.~ Although this system was approved by the Kern County~BUi~lding Departm~_~ent in .~ ~;~'~'~'~'-') conjunction with the Bakersfield City Fire Department, Tri-Com Refrigeration is j0~/x~,§5 ~ investigating the use of an excess flow valve on the liquid ammonia line from the ~'~,~;~/ controlled pressure receiver. However, an excess flow valve in this application may ~(~'/~,~0t be suitable due to the operating pressures and flow rates within the system. The Bakersfield City Fire Department requests that "Iai break in the liquid line outside Page 3 the engine room must also actuate system shutdown". 'This request appears to be unfounded. Members of the HazOp team concluded that a failure of this pipeline was not a likely event. It is credible that the building could collapse during a monumental earthquake, or that an airplane could fall out of the sky and hit the building. But these events are not likely. Ammonia sensors on the roof would not be of any use if such a catastrophic event were to take place. Additionally, ammonia sensors are affected by ambient moisture. During foggy conditions and rain, it is very likely that the ammonia sensors would false alarm and shut down the refrigeration system. Such false alarms have the potential to ruin portions of the production run. Release events associated with the failure of an ammonia pipeline were presented in the RMPP and supporting documents to provide a worst case release scenario for the benefit of the emergency responders for planning' purposes. As stated in the Offsite Consequence Analysis, "It]he pipeline failures were not considered as likely events since the lines were designed and installed per ASME codes. However, air dispersion modeling was performed for these release events to provide emergency responders with a representation of a worst case, 'unlikely event." '~ /-'Tri-Com Refrigeration has designed and constructed the facility to American Society of Mechanical Engineers (ASME) piping code B-31.5, the Uniform Bu!lding Code (UBC) and the Uniform Mechanical Code (UMC). These codes were developed by the respective professional organizations to ensure public safety. The ASME, UBC, and UMC ~r~ the standards by which engineering designs are evaluated. Since all of the facility has been designed according to the applicable ASME, UBC, UMC (among other) codes, there is more than adequate documentation that public safety has been X-ensured. These codes are the basis for which building permits are issued, inspections are performed by a third party, and compliance documented. BCFD gomment #5: How will operators be alerted to a water solenoid valve failure in the ~mmonia purger? ~&~ ~~ ~v%c~ ~C¼q~ % ./t~,-rv~r~,"~' ~ ~ Response: The water level in the air purger bubbler is visible. Authorized personnel will be making daily routine inspections of the equipment. During these inspections, the operator will be able to see a change in water level if the water solenoid valve fails. Page 4 BCFD comment #6: Are the adverse weather conditions (stability class C) used for modeling the ammonia releases from the receiver lines worst case? Would a release at night impact a larger area? Response:~ Modeling parameters for both th~and average meteorological conditions were derived from data obtained from the National Weather Service at Meadows Field Airport in Bakersfield. The adverse weather conditions were generated by starting with the lowest monthly average wind speed, which is 5.0 miles per hour in the month of December. This wind speed was coupled with high humidity, high cloud cover (Iow solar radiation), and cold temperature. All 'of these parameters must be within the modeling guidelines., or the model will not run. ~-~), ' <3~ Since the.credible release events were generated during shifts when maintenance was being performed on the ammonia refrigeration system, these release events were modeled during daylight hours. While these release events do not have a high probability of occurrence, they were determined by the HazOp team to be the most likely release events that could reach sensitive populations. ~;~is stated in the Offsite Consequence releases Analysis, "[m]odelJng with these dverse weather conditions would present an offsite consequence that would otentially have the greatest affect on sensitive populations." It may be conceded that .here could be a larqer impact area if a large number ~ modeling runs Were~ / ~o..mpl_~_ed. S'everal of the parameters could be altered until a "wors~ase'' mo~el run (~, was achieved. However, due to the inherent in accuracy of air dispersion models, this~ exercise would be a waste of time and money. The draft of Section XI states that, "action items were created for study nodes with de~_ati~o.s~ likely to occur or with high consequences". Are items 1-6 of Section XI the likely or high consequence study nodes? If so, does this indicate that the other release scenarios identified in the HazOp such as gauge failures and evaporator leaks are expected to have lesser probability and/or consequences? Will the "action items" be discussed in the RMPP? Page 5 Response: With the exception of item 3, items 1-6 in Section XI represent the deviations from the design intent with significant offsite consequences if they were to occur. As stated in Section XII "[t]he HazOp study generated release events for the ammonia 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 occurrence or a significant offsite consequence if the release were to occur. The releases associated With a high likelihood of occurrence were very Iow release rates and originated within the engine room which is equipped with the emergency ventilation system. There would be little or no offsite consequences associated with these release events." There were several release events reviewed during the HazOp study that would have a higher probability of occurrence, but very little consequence to sensitive populations and employees of Pestritto Foods Inc., if they did occur. Item 3 in Section XI states "[t]he available leak flow area for all valves and threaded fittings on the ammonia system would be less than the area of the other failure modes that were reviewed. Although a valve packing is one of the most likely release events, the smaller flow area would result in a release well below the other events described in this section." Additionally, the HazOp team reviewed the start up procedures for the ammonia refrigeration system. After review of the written testing, evacuation, and charging procedures outlined by Tri,Com Refrigeration, it was determined that start up leaks would be essentially nonexistent. Since most of the HazOp action items focused on the need for additional information on the design and/or the equipment in the refrigeration system, the action items were not directly discussed in the RMPP. However, the appropriate deviations from design intent were discussed in the RMPP. BCFD comment #8: A pipeline failure in a liquid ammonia line is identified on page 5 of the HazOp matrix as the worst credible release. Page eight of the Offsite Consequence Analysis states that due to the unlikelihood of a liquid line break this scenario was not considered credible. Failure of a liquid ommonia pipe represents a large volume ammonia release into Page 6 a freezer room or the outside environment. Due to the potential for high consequences and the lack of dom~mentation to prove that this event is not credible, please include the liquid line break in the discussion of consequences in the RMPP. Response= ~:_.~ ~c~Cc_~ ~u~ ~¢5.5..~_~ ~C~,~. ,~OD~ As stated in the response to BCFD comment #4, all of the pipelines associated with the refrigeration system have been designed and installed per the applicable code. This alone should provide documentation that the system was designed to ensure public safety. The risk of this line failing is equivalent to the risk of having one of the receiver vessels fail. While it is an extremely unlikely event, it is credible that a catastrophic failure of the building could break these pipelines during a monumental earthquake. As such, these liquid ammonia pipeline failures were addressed in the RMPP in Section Xl as item #2 for the thermosyphon receiver line and item #5 for the controlled pressure receiver. Air dispersion modeling was performed for these release events in the Offsite Consequence Analysis. Section 25534 (d)(2) states that "[t]he RMPP shall consider... [flor the hazards identified in the hazard and operability studies, an offsite consequence analysis which, for the most likely hazards, assumes pessimistic air dispersion and other adverse environmental conditions." Air dispersion modeling for the liquid line failures was performed, for planning purposes for the emergency responders. ~'~acility evacuation planning and drills have not been addressed in the RMPP. espons,: ~.~L~.~(' ~0~. ~uJ,~d A~ ~, The RMPP addresses safety, evacuation, and emergency procedures in several sections. Section VIII addresses the safety and training records that will be kept at the plant. Section IX.D of the RMPP addresses the general training for the employees, including emergency equipment and emergency procedures, detection and monitoring systems, safety and personnel protective equipment, spill containment and control, emergency response and notification, and fire protection and control. Section IX.E addresses general traini.ng including SCBA training for emergency responders, safety training, and hazardous materials and emergency plan training. Section X of, 0the RMPP addresses internal notification procedures in the event of an emergency. This section describes how the evacuation plan would be put into effect. Section X y_.. Page 7 also states that "[a]ll employees are trained in. evacuation procedures for fire and ammonia release emergencies." All of the above items are part of, or a by-product of Pestritto Foods Inc.'s Emergency Action Plan, as required by Title 8, Section 3220 of the California Code of Regulations. As prudent operators, Pestritto Foods Inc. will implement the Emergency Action Plan prior to commercial operation. Page 8 FIRE DEPARTMENT S. D. JOHNSON FIRE CHIEF CITY of BAKERSFIELD · 'wE CARE" July 29, 1991 2101 H STREET · BAKERSFIELD, 93301 326-3911 Mr. Larry Wuethrich Pestritto Foods, Inc. P.O. Box 328 Blackwood, NJ 08012 Mr. Wuethrich: Please find enclosed copies of my recent correspondence with Luft Environmental Consulting regarding the Risk Management and Prevention Plan which is in progress for the Bakersfield Pestritto 'Foods plant. I understand your concern toward getting the RMPP finished in order to maintain your start up schedule. Therefore, I want to make sure that you-are aware of the nature of the questions and problems Which need resolution. Please call me at (805) 326-3979 if I can clarify any of the points outlined in the correspondence. Sincerely, Barbara Brenner Hazardous Materials 'Planning Technician cc: Ralph Huey CITY of BAKERSFIELD "WE CARE" FIRE DEPARTMENT S.D. JOHNSON FIRE CHIEF ,July 26, 1991 2101H STREET BAKERSFIELD, 93301 326-3911 Karl Luft Luft Environmental Consulting 3701 Pegasus Dr., Suite 121 Bakersfield, CA 93308 Mr. Luft: ~ I have ~ompleted review of the Hazard and Operability Study, the Off Site Consequence Analysis and the Risk Management and Prevention Program submitted on 7-25-91 on behalf of Pestritto Foods' Inc. I am returning these documents because they are ~ incomplete at this time. Most of the questions requiring resolution were posed in my letters of July 8 and July 12, 1991. The points which must still be addressed are restated below and copies'of the original letters, are attached. 1. Define the term "public consequences" as used in the haz-op matrix. Does this include plant employees? 2. The ammonia scrubber and absorption System should be included in the Haz-Op Study. Define the system's capacity, limits and any hazards which may be caused by potential failures. Provide documentation to support the conclusion that the ammonia delivery hose would fail prior to damage occurring to the back check valve or the line into the receiver. Is the ammonia delivery line adequately braced? (Haz~Op item 1, more flow) Will isolation of the liquid ammonia lines be accomplished automatically if a liquid line breaks? System shut down upon triggering of the engine room ambient ammonia sensor does not fulfill the requirement for excess flow control sensors on Pressurized piping above 15 psig~ A break in a liquid line outside the engine room must also actuate system shutdown. Please state how this requirement will be provided for pursuant to the method outlined by Tri- Comm Refrigeration in the attached correspondence regarding Uniform Fire Code compliance. How will opera~tors be alerted ..to a water solenoid valve failure in the ammonia'purger? (Haz-Op item 7, less flow) Are the adverse weather conditions (stability class C) used for modeling the ammonia releases from the receiver lines worst case? ' Would a release at night impact a larger area? The draft of Section .XI states that, "action items were created~for study.nodes with deviations likely to occur or with high consequences". Are items 1~6 of Section XI the likely or high consequence study nodes? If so, does this indicate'that the other release scenarios identified in the Haz-Op such a gauge failures and evaporator leaks ar expected to have'lesser probability and/or consequences?. Will the "action. items" be discussed in the RMPP? The four items in my original letters which have reiterated above have been adequately addressed. additional items also' need further attention. not been Several A pipe failure in a liqgid ammonia line is identified on page 5 of the Haz-Op matrix as the worst credible release. Page eight of the Offsite Consequence Analysis states that due to the unlikelihood of a liquid line break this scenario was not considered credible. FailUre of a' liquid ammonia pipe represents a large volume ammonia release into a freezer 'room or the outside environment. Due to the potential for high conseguences and the lack Of documentation to prove that this event is not credible, please include the liquid line break in the discussion of consequences in the RMPP. 9. have not been Facility evacuation planning and "drills addressed in the RMPP. Upon receipt of the responses to these items, I will review them immediately in order to maintain Pestritto's planned start up schedule. The final RMPP should reflect Portions ~of the information provided in the responses'to these questions. We will need to discuss which information should be integrated into the RMPP document and .the most efficient means of doing So. I am available to discuss these issues at anytime. Please call if I can provide assistance~ Sincerely, Barbara Brenner Hazardous Materials Planning Technician cc: Ralph Huey Larry Wuethrich FIRE DEPARTMENT S. D. JOHNSON FIRE CHIEF CITY of BAKERSFIELD "WE CARE" July 8, 1991 , 2101 H STREET BAKERSFIELD, 93301 326-3911 Karl Luft Luft Environmental Consulting 3701 Pegasus Dr., Suite 121 Bakersfield, CA 93308 Mr. Luft: I have reviewed the draft Hazard and Operability matrix submitted on behalf of Pestritto Foods. The following list contains questions regarding the study and notes areas which warrant further consideration. Please define the term "public consequences" as it is used in the comment section of the matrix. Does the public include plant employees ? The ammonia scrubber and. absorption system should be included in the Hazard and operability study. Define the system's capacity, limits and any hazards which may be caused by potential failures. -' Is piping at the point of ammonia delivery braced adequately to support the conclusion that the ammonia delivery hose would fail prior to damage, occurring at the back check valve or the line into the receiver. (Item 1, more flow deviation) Please address the failures anticipated in the event of an earthquake. Physical hazards to piping and Vessels from in plant traffic and operations should also be evaluated. Item 3, liquid ammonia lines - more flow, indicates that a leak in pipelines would result in the discharge of ammonia until the leak is iSolated. Will isolation be accomplished automatically, triggered by a drop in system pressure ? See attached correspondence from.Tri-Com Refrigeration regarding compliance with the Uniform Fire Code. Are the emergency shut downs (item #9) and the system pressure equalization referred to throughout the.document automatic or must they be actuated by plant personnel? Why 'would a rupture Of a liquid ammonia line ~release the contents of the line only into the engine room? Could the liquid line fail elsewhere in the plant? (item 3, more pressure) How will operators be alerted to a water solenoid valve failure in the ammonia purger? (item 7, less flow) Please address these questions and areas of concern as a follow-up to the Ha~-Op Review Summary previously submitted. PleaSe call me at .326-3979 if any of these items.~equire clarification. · Sincerely, Barbara Brenner Hazardous Materials Planning Technician cc: Ralph~Huey FIRE 'DEP,~RTMENT D. S. ,NEEDH>XM FIRE CHIEF CITY of BAKERSFIELD "WE CARE" July 12, 1991 Karl. Luft Luft Environmental Consulting 3701 Pegasus Dr., Suite 121 Bakersfield, .CA 93308.· I have reviewed the Haz-OP Results and vapor ·dispersion modeling for Pestrittio Foods The draft of RMPP Section XI adequately addres.s the failures anticipated in the event of an earthquake and the item regarding liquid ammonia pipeline failures outside the engine room which I questioned in my letter of 7·-8-91. Following are my questions and comments regarding the modeling and Section XI. , Are the adverse weather conditions (stability class C) used for modeling the ammonia releases from the controlled pressure .receiver and the thermosyphon, receiver worst case? Would a release at night impact a larger area? In the RMPP, please inClude .some discussion of the refrigeration control system Which enables pressure equalization and emergency shutdown. The, draft of Section XI states that, "Action items were - created for study nodes with deviations likely to occur or with high consequences". Are items 1-6 of Section XI the · likely or high consequence study nodes? If so, does this indicate that the other ~elease scenarios identified in the Haz-Op such as gauge failures and evaporator leaks· are expected to have lesser probability and/or consequences? will the "action items" be discussed in the RMPP? Please call me if any of·these points require clarification. Sincerely, Barbara Brenner ,, Hazardous Materials Planning·Technician cc: Ralph Huey 'Fire Department 21'01 "H"'Street Bakersfield, .CA 93301 Date: Fax Phone No. (805) 395-1349 Office (805) 326-3941 ,'19 PLEASE ROUTE AS SOON AS 'POSSIBLE TO: Company/Organization: Lo t---'i- ' ~.r~ ufco,-','~°--r~ 'Fax No, Sending Message to: FROM: Name: Contact Person: Number of Pages (including cover sheet): Description of Materials Sent: 'Special Instructions: FIRE DEPARTMENT S. D JOHNSON FIRE CHIEF CITY of BAKERSFIELD "WE CARE" July 26, 1991 2101 H STREET · ., BAKERSFIELD, 933~)1 326-3911 Karl'Luft Luft Environmental Consulting 3701 Pegasus Dr., Suite 121 Bakersfield, CA 93308 Mr.. Luft: I have completed review of the Hazard and operability Study, the Off Site Consequence Analysis and the Risk Management and 'Prevention Program submitted on 7-25-91 on behalf of Pestritto Foods Inc. I am r~turning these documents because they are incomplete at' this time.. Most of the questions requiring resolution were posed in my letters of July 8 and July 12, 1991. The points which must still be addressed are restated below and copies of the original letters are attached. Define the term-"public, consequences" as used in the haz-op matrix. Does this include plant employees? The ammonia scrubber and absorption system should be included in the Haz-Op Study. Define the system's capacity, limits and any hazards which may be caused by potential failures. Provide documentation to support the conclusion 'that the ammonia delivery hose would fail prior to damage occurring to the back check valve or the line into the. receiver. Is the ammonia delivery line adequately braced? (Haz-Op item 1, more flow) Will isolation of the liquid ammonia lines be accomplished automatically if a liquid line breaks? System shut down upon triggering of the engine room ambient ammonia sensor does not fulfill the requirement for excess flow control sensors on pressurized piping;above 15 psig. A break in a liquid line outside the engine room must also actuate system shutdown. Please state how this requirement will be provided for pursuant to the method outlined by Tri- Comm Refrigeration in the attached correspOndence regarding Uniform Fire Code compliance. How will' operators be alerted to a water- solenoid valve failure in the ammonia purger? (Haz-Op item 7, less flow) Are the adverse weather conditions (stability class C) used for modeling the ammonia releases from the receiver lines worst case? Would a release at night impact a.larger area? The draft of Section XI states that, "action items were. created for'study nodes with deviations likely to occur or with high consequences". Are items 1-6 of Section XI' the likely or high consequence study nodes? If so, does this indicate that the other release scenarios identified in the Haz-Op such a gauge failures and evaporator leaks ar expected to have lesser probability and/or consequences? Will the "action items" be discussed in the RMPP? The four items in my original 'letters which have reiterated above have been adequately addressed. additional items also need further attention. not been Several A pipe failure in a liquid ammonia line is identified on page 5 of the Haz-Op matrix as the worst credible release. Page eight of the Offsite Consequence Analysis states that due to the unlikelihood of a liquid line break this scenario was not considered credible. Failure of a liquid ammonia pipe represents a large volume ammonia release into a freezer room or the outside environment. Due to the potential for high.consequences and the lack of documentation to prpve that this event is not credible, please include the liquid line break in the discussion of consequences in the RMPP. Facility evacuation planning and '..drills addressed in the RMPP. have not been Upon receipt of the responses to these items, I will review them immediately in order to,maintain Pestritto's.planned start up schedule. The final RMPP should reflect portions, of the information provided in the responses to.these questions. We will need to discuss which information should be integrated into the RMPP document and the most efficient means of doing so. I am available to discuss these issues at anytime. Pleasecall if I can provide assistance. Sincerely, Barbara Brenner Hazardous Materials Planning Technician cc: Ralph Huey Larry Wuethrich LUFT ENVIRONMENTAL CONSULTING 3701 Pegasus Drive, Suite 121 Bakersfield, California 93308 · (805) 399-5838 July 25, 1991 Barbara Brenner Hazardous Materials Planning Technician Bakersfield City Fire Department 2101 "H" Street Bakersfield, CA 93301 Ms. Brenner: Enclosed for your review is the Hazard and Operability Study, Offsite Consequence Analysis, and the RMPP Supporting Document for Pestritto Foods Inc. We are initially submitting an unsigned copy of the RMPP in order to maintain the start up schedule for the plant. The RMPP will be signed by me and the Pestritto Foods Inc.'s Plant Manager upon his return to Bakersfield on July 29, 1991. If you have any questions concerning the enclosed, please contact me at your convenience. Karl W. Luff Principal Mechanical Engineer cc: Larry Wuethrich - Pestritto Foods, Inc. w/o enclosures Larry Rolison - Tri-Com Refrigeration Inc. w/enclosures LEC-91-0248 PF-01 FIRE DEPARTMENT D. S. NEEDHAM FIRE CHIEF CITY of BAKERSFIELD "WE CARE" July 12, 1991 2107 H STREET BAKERSFIELD, 93301 326-391'i Karl Luft Luft Environmental-Consulting 3701 Pegasus Dr.,'Suite 121 Bakersfield, CA 93308 I' have reviewed the Haz,OP' .Results and vapor.dispersion .modeling for' Pestrittio Foods. .The draft of RMPP Section XI adequately 'addres.s the failures _anticipated in the event of an earthquake and the item regarding liquid ammonia.pipeline failures outside the engine room which I questionedin my letter of 7-8-91. Following are my questions and comments regarding the modeling and Section XI. Are the adverse weather conditions (stability class C) used for modeling the ammonia releases from the ·contr°lled pressure receiver and the thermosyphon receiver worst case? Would a release at night impact a larger area? In .~the RMPP, please include- some discussion of the refrigeration, control syStem which enables pressure equalization and emergency Shutdown. The draft of Section XI states that, "Action items were created for study nodes with deviations likely to occur or with high consequences". Are items 1-6 of Section XI the likely or high consequence study nOdes? If so, does this indicate that the other release scenarios identified in the Haz/Op such as gauge failures and evaporator leaks, are expected to have lesser probability and/or consequences? Will'the "action'items" be discussed in the RMPP? Please call me if any of these points require clarification. Sincerely, Barbara Brenner Hazardous Materials Planning Technician cc: Ralph Huey CITY of BAKERSFIELD "WE CARE" FIRE DEPARTMENT D. S. NEEDHAM FIRE CHIEF July 10, 1991 2101H STREET BAKERSFIELD, 93301 326-3971 Mr. Larry Wuethrich Pestritto Foods,.Inc. P..O. Box '328 Blackwood, NJ 08012 Mr. Wuethrich:' As of.'July 1, 1991, the City of Bakersfield has instituted a fee of $45.00 per hour for the review of Risk Management and Prevention Programs. Time spent conducting site inspections, reviewing hazard, risk and' consequence analyses and meeting with company officials or consultants will also be billed at this rate. Upon completion of your Risk Management and Prevention Program, You will be billed for the time that Bakersfield Fire Department personnel have spent reviewing the project. If you have any questions regarding this policy, please call me at (805) 326-' 3979. SincerelY, Barbara Brenner Hazardous Materials Planning Technician cc: Ralph Huey FIRE DEPARTMENT D. S. NEEDHAM FIRE CHIEF CITY of BAKERSFIELD "WE CARE" July 8, 1991 210i H STREET BAKERSFIELD, 93301 326-3911 Karl' Luft Luft Environmental Consulting 3701 Pegasus Dr., Suite 121 Bakersfield, CA 93308 Mr. Luft: I have~ reviewed the draft Hazard and Operability matrix submitted on behalf of Pestritto Foods. The following list contains questions regarding the study and notes areas which warrant further consideration. Please define the term "public consequences" as it is used in the comment section of the matrix. Does the public include plant employees ? The amm6nia scrubber and absorption system shOuld be included in' the Hazard and Operability study. Define the system's capacitY,' limits and any hazards which may be caused by potential failures. Is piping at the point of ammonia delivery braced adequately to support the conclusion that the ammonia delivery hose would fail prior to damage occurring at the back check valve, or the line into the receiver. (Item 1, more flow deviation) Please address the failures anticipated in the event of an earthquake. PhySical hazards to piping and vessels from in plant traffic and operations should also be evaluated. Item 3, liquid ammonia lines - more flow, indicates that a leak in pipelines would result in the discharge of ammonia un{il the leak is isolated. Will isolation be accomplished automatically, triggered by a drop in system pressure ? See attached correspondence from Tri,Com Refrigeration regarding compliance with the Uniform Fire Code. Are the emergency, shut downs (item #9) and the system pressure equalization referred to throughout the document automatic or ~ust they be actuated by plant personnel? Why would a rupture of a ~iquid ammonia line release the contents of the line only into the engine room? Could the liquid line fail elsewhere in the plant? (item ~3, more pressure) How Will operators be alerted to a water solenoid valve failure in the ammonia purger? (item 7, less flow) Please .address these questions and areas of concern as a follow-up to the Haz-Op Review Summary previously submitted. Please call me at 326-3979 if any of these items require clarification.- sincerely, Barbara Brenner Hazardous Materials Planning Technician cc: Ralph Hue¥ P. ~32 Hs.. Sarhara Sr=_n~ner ~aza~ou~ Mata~al Div. 213'0' G s~met B~er~field, ~ 933OI S~bJec-.: pest.-it~.o Foods. Ammonia Refriqera=ion System. ' · .. cc~ec~io~ p~ lea%ar 2/8/91. Dear Ms. Brm~er: ~er cur Dhone conversation on Friday ~roceed~a wi~ ~e fo!!~in~ ~anges no. confo~ wi~ your let=er da{ad 2/8/91. A~icle 53 1. The diffuser control box in fac: will have a back as i= is free .stand!hq. 21 The to9 of ~he diffuser control box will not ~caed f~et from ~he ~jo~inq ~o~ level' 3. .~e diffuser controI ~ox will car~f ~he folluwinq !~e!. FIRE DEP.%R~;T ~".~RG~C"I P~-~R. iGEPJu%Tf CONTROL ~OX ~icle S0 1. ~e a~oni, a vaDor tr~a~nen~ system wil~ ' ~=e_of_ ~ower ~euarata ~r~=he __~_i~ave a s~an~y ue ~ns~alled ~er 2~0 o~ ~ ....... q~'=m=~f source and ~ -=~ ~=~u=7~ ~.5 an~ per 230-94 pa~.of t~e co~t. ol svs.~e~ ~--. ~nd will automa=ica!ly close, if' ~%e . ~ow indicating a 10~ of ref-igeran'=]. , .. The plans ara be~q zcdifled to raf!e~ the. above DRAFT Xl, DESCRIPTION AND RESULTS OF THE HAZARD AND OPERABILITY STUDY This section addresses the requirement that the RMPP be based upon an assessment of the processes; operationsl and procedures of the business, and shall consider the "results of a hazard and operability study which identifies the hazards assoCiated with the handling of an acutely hazardous material due to operating error, equipment failure, and external .events,. which may.present an acutely hazardous materials accident risk." [§ 25534 (d)] Additionally, Section'25532 (g)~sPecifies that the RMPP include programs which include risk assessment for unit operations or operating alternatives. In acCordance with these requirements, a Hazard and Operability '(HazOp) study was conducted. The study session was.held on June 3, 1991 at Luff Envir°nmental Consulting's office. This section summarizes the results of the study. The refrigeration system at the'PFI facility utilizes anhydrous ammonia, an acutely hazardous material, as.the refrigerant. The anhydrous ammonia refrigeration system provides cooling for process water and cold storage facilities associated with the manufacturing of.frozen bread dough. · This system was reviewed during the HazOp study'. A. HAZOP TECHNIQUE The Hazard and Operability Study (HazOp) technique that was used .is the "guide word" approach. The. guide word HazOp was chosen since it allows a systematic and thorough review.of every part of the facility that handles acutely hazardous materials (AHMs). This approach is described in' the AICHE GUidelines for Hazard Evaluation Procedures1, which is referenced in Section 25534 Chapter 6.95, Division 20, California Health and ,Safety Code. Other publications further describe this technique, including A Guide to Hazard And Operability Studies2. A multidisciPlinary team was formed.to work 'together (brainstorm) to identify. hazards and oPerability problems by searching for deviations from design intents. Prior to the HazOp study, each HazOp member reviewed piping 'and 1 Guidelines for Hazard Evaluation Procedures, American Institute of Chemical Engineers, New York, 1985. .2A Guide to Hazard and Operability Studies, Chemical Industry Safety and Health Council of the Chemical Industries Association, London, 1985. Pestritto Foods, Inc. RMPP Page Xl-1 June, 1991 ~ Luff Environmental Consulting DRAFT instrumentation diagrams (P&IDs) pertaining to the ammonia refrigeration. The HazOp team also conducted an onsite review (during construction) of the refrigeration syStemsand equipment covered in the HazOp study. The team leader systematically guided the team thrOugh the plant design using a fixed set of Words, called ".guide words". These guide words were applied at :specific points or ',study nodes" in the 'plant'design (using the P&IDs) to identify potential deviations Of the plant process parameters at those nodes. A report of the findings of the HazOp review was prepared in the form of a matrix. For each Study node, this table includes the guide words, causes of deviations, consequences of deviations in terms of potential AHM release, and safeguards and/or suggested 'actions that mitigate the deviations. A summary of the HazOp is included .below. ', HAzOp TEAM MEMBERS The HazOP team was selected based upon knowledge of the design and, operation of the facility, expertise in their respective fields and experience in the type of system and equipment being reviewed For the PFI facility, the HazOp team consisted of the following personnel. Team Leader . Luft Em/ironmental Consulting Study ReCorder Luff Environmental Consulting Operations Manager PFI Refrioeration Eng!D_eering Tri-Com Refrigeration, Inc. C. HAZOP REVIEW FOR.PFI The HazOp review consisted of a brainstorming session of approximately four hour duratioh with follow up telephone calls with the team members. These Pestdtto Foods June, 1991 : Inc. RMPP Page Xl-2 Luff Environmental Consulting DRAFT review sessiOns are described below. In 'order to direct the review team, a copy of the Process and Instrumentation Diagram (P & ID) for ,the ammonia system was posted. The system Was 'divided into eleven areaS of review, 'as follows. Item #1: Item #2: Item #3: Item #4: Item #5 Item #6 Item #7 Item #8 Item #9 Item #10 Item #11 Tank Filling System Thermosyphon Receiver · Liquid Ammonia Distribution Header Shell and Tube Heat Exchanger (Glycol System) Plate Heat Exchanger (ProcesS Water) ~. Controlled Pressure Receiver Ammonia Purger ~lntercooler Low Suction Accumulator Evaporators Compressors and Evaporative Condensers Each item (study node)' was addressed systematically. The guide words· (more,' less,, no; other) were applied at each node. Deviations from normal design for each guide word, the possible causeS of the. deviation, the likelihood of the deviation occurring, and the consequen_~cesof occurrence_ were evaluated. Acti~on items were created for stu~dy_n.ode_s with deviations likely_to occur or with high c. ons.___equences of occurrence. This information was recorded during the seSSion in matrix form.' ' .. After the initial meeting, a summary of'the.results, comments, and action items was assembled in a matrix form and provided to each team member for review. Follow-up meetings/conference calls were held after the action items were addreSsed to determine whether any further changes to the HazOp matrix were required. Pestritto FoOds,' Inc.'RMPP June, 1991 RESULTS-OF HAZOP FOR PFI FACILITY The ammonia system at the PFI facility has been designed in accordance with all applicable laws, ordinances, regulations and standards which should minimize the risk of accidents involving AHMs. However, in order'to meet the requirements · of the statute, an analysis of the hazards assOciated with the handling of the' anhydrous ammonia due to operating error, ~equipment failure, and external events was perfOrmed. This analysis identified the ,potential releaSes that may Page XI-3 Luft Environmental Consulting DRAFT have.an offsite consequence to the surrounding community. In accordance with the guidelines published by the Bakersfield City Fire Department, an offsite 'consequence analysis of the worst credible release was conducted. The potential hazardous'events determined by the HazOp review, are described briefly below. As previously stated, these events coUld be caused by operating error, eqUipment failure or external events (including earthquakes). A discussion of the offsite consequence analysis based on the most likely worst Case release event is provided in Section XII. It is very important to note that the following release events take into account the ambient ammonia monitoring system and. the emergency ventilation system located in the engine mom. The ammonia monitoring system has an ambient ammonia sensor strategically located in the engine room. This Sensor will be set at 200 ppm and will activate an alarm on the ammonia refrigeration control panel. In addition to initiating an alarm, the ambient ammonia monitoring system will also 'start the emergency ventilation system. The emergency ventilation System consists of a fan that will discharge the ammonia laden air from the engine room into the evaporative condenser where the ammonia will be absorbed into the condenser water. When the emergency ventilation system is activated, the blowdown water from the evaporative condenser is redirected from the sewer to a scrubber'tank filled with water located outside of the engine room. A Water circulation pump on the scrubber tank will also start when the emergency ventilation system is activated. This pump circulates water from the scrubber tank to the evaporative condenser. 1. Filling The Refrigeration System In additiOn to the initial fill of the .refrigeration system with anhydrous ammonia, the system will periodically require a "recharge" of ammonia .due to the operation of the air purger and. minute leaks in fittings such as valve packings. During a typical recharge of the refrigeration system, ammonia is added to the system to bring the system capacity up to the initial fill inventoryl The method of adding ammonia to the refrigeration system is the same for the initial fill and the system recharges. Ammonia will be transferred as a liquid from the vendor tanker to the controlled pressure receiver via a liquid ammonia.pump. The hoses that are Pestritto Foods, 'Inc. RMPP.' June, 1991 Page XI-4 LUft Environmental Consulting. DRAFT used to transfer the ammonia mUst comply with the requirements of CAL- 'OSHA. The CAL-OSHA requirements include pressure testing the hoses and incorporating safety factors in the pressure ratings of the hoses; The vendor's tanker is equipped with excess flow valves that will shUt off immediately if the normal filling rate is exceeded. These excess flow valves are designed to automatically 'operate in the 'event of a catastrophic hose or pipe fitting failure. Ammonia tankers are also equipped with cable actu~.ted, spring loaded emergency shut down valves. The cable that operates the emergency shut down valves is accessible frOm both sides of the tanker as well as from the front of the vehicle. The combination of excess flow valve and emergency shut down valves alOng with the standard valves allows for quick.response by the tanker operator in the event of an emergency As an added safety precaution, PFI will also install a back check valve on the fill line', to the-controlled pressure receiver during ammonia deliveries. This back check valve will prevent the reverse flow of ammonia in the event of a hose rupture. A release Could occur during the tank filling operation if the delivery hose were to rupture.' Two types of hose failUre were investigated; a complete failure of a hose and a partial failure of a hose. If a complete hose failure occurred, the excess flow valve on the tanker would close immediately and only the contents of the loading hose would be released. The contents of the controlled pressure receiver would not be released since the back check installed on the controlled pressure receiver would prevent the reverse flow of the ammonia. A more .significant release Could ocCur, under certain circumstances, if there was a partial failure of the hose. If the partial failure of the hose resulted in a release below the ·set' point of the excess flow 'valve, the excess flow valve would not operate. In this release event, the operator (either. the tanker bperat°r or PFI personnel)would need tO pull the cable on the emergency shut down valve to control the release. ~ Assuming that the operator would take up to 10 seconds to respond, the net release would be 25.4 pounds (2.54 pounds per second times~ 10 seconds) of .vapor ammonia and 97.1 pounds (9.71 pounds per second times 10 seconds) of. liquid ammonia. The 25.4 pounds of ammonia vapor represents and instantaneous release to the atmosphere while the 97.1 pounds of Pestritto Foods, Inc. RMPP June, 199i Page XI-5 Luft Environmental Consulting · ? DRAFT. liquid ammonia 'must evaporate. A failure of this type could occur in the engine room where there is an emergency ventilation system, or outside near the delivery truck. In order to help mitigate this type· of release, a PFI employee that is familiar with the. ammonia delivery truck will be required to overSee any tank filling operation. If the this type of releaSe were to take place in the engine room, the emergency.ventilation system would start up automatically or could be initiated manually. Additionally, ~elf contained breathing apparatuses (SCBA's) are on site for emergency response purposes. The rate of release f(~r this event is lower than rate'described in event #5 below. Dispersion modeling was preformed for this 10 second release event, along with a release at the same rate lasting one minute. 2. Thermosyphon Receiver Tank Line Failure The thermosyphon receiver tank supplies various parts of the refrigerati°n system with liquid ammonia via a 3 inch high pressure liquid line. This line,' along with the balance of the ammonia, system, has been installed in accordance with the ANSI/ASME B31.5 refrigeration piping code. Although unlikely, a worst case release event for the ammonia system within the engine room would be a complete pipe failure near the thermosyphon receiver tank. Assuming that the thermosyPhon receiver would'be operating- at approximately .half full'prior to the failure, the 3 inch high pressure liquid line would discharge the contents of the receiver (approximately '486 pounds) in less than a second and a half. Approximately 114 pounds of ammonia would ~vaporize instantly while 372 pounds of liquid ammonia would form a pool and ~have to evaporate to the atmosphere. As a means to help mitigate this type of release, the building is equipped with the emergency ventilation system that is activated by an ambient sensor set at 200 ppm, or may ·be activated manually. Self contained breathing apparatuses (SCBA's) are on site in strategic locatiOns for emergency .response purposes. . " 3. Fitting· Leak · The available leak 'flow area for all valves and threaded fittings on the Pestritto Foods, Inc. RMPP June, 1991 -" Page Xl-6 Luff ·Environmental Consulting DRAFT ammonia system would be less than the area of the other failure modes that were reviewed. Although a valve packing is one of the most likely release events, the smaller flOw area woUld result in a release well belowthe Other events described in this section. In the event of a leak from valves.or'fittings, Sulphur sticks or soap bubble solution will I~e utilized to locate the leak for repair purposes. If a larger leak occurs, the' engine room is equipped with the emergency Ventilation system to mitigate the release. Additionally, SCBAs are on site to provide emergency responders access to the leak' in an ammonia laden environment. 4. Pressure. Relief Valve Release Each vessel in the ammonia refrigeration system is equipped with a pressure relief valve. The pressure relief valves vent into a four inch diameter pressure relief header pipe that discharges into a scrubber tank. This pressure relief header pipe extends down into the scrubber tank which is filled with water. The relief header pipe has perforation~ below the water level which allow the ammonia vapors to bubble out into the water. The ammonia will be absorbed into'the water in the scrubber tank. Although there are very few combustible materials in the engine reom, a fire in the engine room could theoretically cause the system pressure to rise far enough to open the pressure×relief valves. ~ In this unlikely event, the maximum, release rate of ammonia vapors from the refrigeration system. vessels would be approXimately 1.6 pounds per second. Controlled PresSure ReCeiver Tank Line Release The controlled pressure receiver, which operates at 30 psig, ·supplies liquid ammonia to the blast freezer and the holding freezer evaporators via a 3 inch pipeline. This pipeline, built to AN$1/ASME B31.5 piping code, extends from the controlled pressure receiver to the blast freezer located north of the production area in a separate building. Although very unlikely, a worst case release event for the ammonia refrigeration system would be a complete failure of this pipeline (due to an external event, such as an earthquake). A break in this 3 inch line could release liquid ammonia into'the engine room, the blast freezer building,~ or outside depending on the location of the Pestritto FoOds, Inc. RMPP. Page XI-7 June, 1991 Luft Environmental Consulting DRAFT pipeline failure. If this line catastrophically fails, all of the liquid ammonia in the controlled pressure receiver' would be tdischarged .within about 30' seconds. Approximately 361 ~pounds of ammonia would flash into the air during "this discharge. The balance of the liquid, ammonia, approximately 4100 pounds, would form a liquid pool that would evaporate over time. Since the engine room is equipped with an ambient ammonia sensor and emergency ventilation system that discharges into a scrubbing system, a release in the engine room would notbe the worst credible release. If the pipeline were to fail in the blast freezer building, there would not be an immediate release to the atmosphere. The ammonia, in both {he liquid and vapor phases, would be .contained in the blast freezer building. Over time, the ammonia would diffuse through the conveyor belt Openings into the main Production area of the complex. Ammonia vapOrs would also diffuse through the blast freezer building and into ~the atmosphere. ~,~A direCt release to the atmosphere could develop if the pipeline failure occurred outside of the engine room and outside of'the blast freezer building.. In this unlikely event, approximately 361 pounds of ammonia would flash into the atmosphere. The remaining 4100 pounds of ammonia would form an evaporation pool between the blast freezer building and the engine room'. Air dispersion 'modeling, for the worst Credible release event, -was Performed on this release event. A 1 inch liquid ammonia line serves'the ammonia evaporators in.the holding freezer. If this 1 inch line were to fail, the release event would be very similar to the blast freezer release, except ,that the release rate would be approximately 11 percent of the blast freezer release rate. Since the flow rate for.this 1 inch line is much less than the 3 inch line described above, no dispersion modeling was performed. Pestritto Foods, Inc. RMPP June, 1991 Oil Pot Oil drain pots were incorporated into ·the design~of the refrigeration system to remove compressor Oil that will accumulate in the Iow suction accumulator during normal operation, In order to remove the oil from the System, the mixture of 0il and liqUid ammonia is 'drained from the Iow suction accUmulator to the oil pot through a closed piping system. Maintenance Page XI-8 Luft Environmental Consulting DRAFT personnel will' then activate an' eJectric heater to vaporize the liquid ammonia that is in the oil/ammOnia mixture. The vaporized ammonia flows out of the Oil pot and into the refrigeration suction line. After the ammonia has been boiled out of the oil pot, the refrigeration suction line is closed. The oil Pot is then pressurized with the hot discharge gas off of the compressors. Once the Oil pot is pressurized, the operator can open the oil drain valve and bleed the compressor oil into a container. If the service person were to. become incapacitated while draining the oil, ammonia gas could be released into the engine room at a rate of 2.57 pounds per second. The ambient ammonia 'sensor in the engine' room would start the emergency ventilation system if the ambient concentration of 'ammonia reaChed 200 ppm. Since this release would be in the engine room where the emergency ventilation syStem is installed, and the actual release rate to the environment Would be less than event #5 aboVe, this release event was not modelled. ~However, the release ~rate for the oil pOt 'release event (2.57 pounds per second) is very close to the'vapor release rate in.the hose rupture event (2.54 pounds per second). Therefore, the vapor release portion of the hose rupture event (the one minute duration 'case) Provides a qualitative representation of the worst case release without the benefit of the emergency.ventilatiOn system. . Pestritto Foods, Inc. RMpP June. 1.99i Page Xl-9 Luft Environmental Consulting - IV. DRAFT PROJECT DESCRIPTION Section 25534 (c)(1) requi'res a description of past accidents. Since the PFI Facility is a new .facility; this requirement does not applY. .~ In accordance with SeCtion 25534 (c)(2), the RMPP must include "[a] report specifying th'e nature, age, and condition of the eqUipment Used to handle, acutely hazardous materials at the business or facility and any schedules for testing and maintenance?' This SeCtion provides a description of thefacility and equiPment which handles AHMs. ' A. GENERAL DESCRIPTION OF PROJECT The new PFI refrigeration system will 'utilize a vapor compression cycle with flooded type evaporators to' provide cooling for the holding freezer, process water cooler, glycol chiller, and the blast freezer. The chilled glycol (glycol and water) circulation .system is used for refrigerating the dough mixer, yeast cooler dock area, and production area. ~ .B. DESCRIPTION OF AHM PROCESS AND EQUIPMENT The major comPonents of the PFI refrigeration system are: .compressors, evaporative condenser, emergency ventilation system with an emergency refrigeration control box, ammonia receivers, a shell 'and tube heat exchanger with suction trap for the glycol system, a plate and frame heat exchanger for the process water cooling system, flooded evaporators, intercooler, Iow suction accumulator with dump traps, an. air-purger, and an oil· pot. In addition to the refrigeration hardware, there is-also an emergency ventilation system and a pressure relief header system with a water tank. A description of the major pieces of refrigeration equipment that handle ammonia is provided below. .Compressors, There are two levels of compression at this facility. The two booster compressors receive ammonia vapors at approximately 8.7 inches of mercury and increase the pressure to' approximately 23.8 pounds per square inch gauge (psig). The ammonia is discharged through an intercooler and then sent to the high stage compressors. The two high stage compressors increase the pressure of the ammonia vapor to approximately 180 psig before the vapor flows into the Pestritto Foods, InC. RMPP · June, 1991 Page IV-1 Luft. Environmental Consulti DRAFT evaporative condenser. Each compressor .is'equipped with the ,respective manUfacturer's recommended control package. The comPressor equipment control functions include monitoring Of the ammonia discharge temperature and pressure and the compressor oil temperature and pressure. Evaporative Condenser PFI has One evaporative condenser located od the roof of 'the faCility. The evaporative condenser removes heat associated with compressing, the ammonia gas. After sufficient heat is transferred out of the ammonia gas, the gaseous ammonia condenSeS to the liquid state. The'liquid ammonia then gravity flows~ into the 'thermosyphon receiver tank. The evaporative condenser has a secondary function in that it also serves as an ammonia scrubbing system for ammonia leaks that occur within the machine room. Emergency VentilatiOn System The engine room is equipped with an ambient ammonia sensor. If the ambient ammonia concentration in the engine room reaches 200 parts per million (ppm), the ammonia sensor will automatically start up the emergency ventilation fan. The emergencY ventilation fan will discharge 'the ammonia laden air from the engine room into the evaporative condenser where the ammonia will be absorbed into the water. At the same time the emergency fan is activated, a three way valve will direct the blow down water from the evaporative condenser to a scrubber tank filled with water. ^ circulation pump on the scrubber tank will also start and Circulate water from the tank to the evaporative condenser. The emergency ventilation system can also be activated manually from outside the engine room. A compressor shut down switch, fan switch, and scrubber pump switch are located next to the emergency refrigeration control box. In the emergency control box, lines from all of the major ammonia veSsels are Connected to each other. In the event of an overpressure situation in One of the vessels, the emergency control box valves can be operated to relieve the pressure from the overpressured system and distribute it to one or more of the other sYstems. This balancing of the pressures can be done without releasing ammonia to the atmosphere: Under an extreme overpressure situation, such as a major fire, there is also an emergency dUmp valve that can be manually, opened Pestritto Foods, 'Inc. RMPP June, 1991 Page IV-2 Luft Environmental Consulting " DRAFT to discharge the ammonia vapors to the scrubber tank. Ammonia Receiver Tanks The refrigeration system 'is equipped with two ammonia receiver tanks. The thermosyphon receiver tank receives liquid ammonia from the evaporative condenser at approximately 1-80 psig. The thermosyphon receiver supplies liquid 'ammonia to the glycol cOoling system, the process water cooling system, and the controlled pressure receiver. The controlled pressure .receiver' reCeives-liquid ammonia from the thermosyphon 'receiver at approximately 30 psig via a pressure reducing valve. The controlled pressure receiVer supplies liquid ammonia, through a piping distribution system, to the flooded evaporators in the blast freezer and the holding freezer. Shell .and Tube Heat Exchanger (GlycOl)· The shell' and tube heat exchanger consists of a Series of thin:walled tubes encapsulated by an outer shell. As the glycol passes through the inside of the tubes, liquid ammonia is allowed to flow around the outside of the tubes. Heat is' transferred out of the glycol and into the liquid ammonia. The heat transfer into the ammonia, causes it to boil to a vapor, state: The cold glycol is then, pUmped to the dock area, yeast cooler, dough mixer, and production area to absorb more heat, while the ammonia is sent to the suction trap on its way to the intercoOler. The suction trap, located above the shell and tube heat liquid ammonia that is entrained in the ammonia Vapor as it and tube heat exchanger. The suction trap and shell and exchanger, removes returns from the shell tube hem exchanger · assembly is 'equipped with a high and low liquid level control system that. maintains .the proper amount of liquid ammonia in the heat exchanger. This system utilizes a solenoid valve that is opened bY.a Iow.liquid level switch and is closed by a high liquid-level switch. Glycol is cirCulated, at a temperature of approximately 25°F, to the production area via centrifugal pumps. The cold glycol absorbs heat (utilizing evaporator coils) from the dock area, yeast cooler, dough mixer, and production area. The glycol is returned to the shell and tube heat exchanger to reject the heat it had absorbed. Pestdtto Foods, InC. RMPP June, 1991 Page IV-3 Luft Environmental Consulting DRAFT Plate and Frame Heat Exchanger (Process Water), Process'water entering the'production area is cOoled in a plate and frame heat exChanger before entering into the dough mixer.. The process water boils the liquid 'ammonia in the' plate and frame heat exchanger, in a similar manner to'the shell and tube heat exchanger. The ammonia vapors from the pirate and frame heat exchanger are combined with the ammonia from the shell and tube heat exchanger prior to entering the intercooler. Flooded Evaporators Flooded evaporators operate on the principle that liquid ammonia has a higher heat transfer rate than ammonia vapOr. The liquid ammonia is allowed to fill .the evaporator to absorb the heat from the circulated air in the cold Storage room. The cold storage~ air is circulated along the exterior of the evaporator by electrically driven fans. As the liquid ammonia absorbs the heat from the cold storage room air, the liquid ammonia boils to a vapor phase. This ammOnia vapor is returned to the Iow suction accumulator to remove any ammonia liquid entrained in the vapor stream. Intercooler The intercooler has two primary functions. First, it removes the heat of compression from the ammonia being discharged from the booster compressors. This is accomplished by bubbling the hot gas through a bath of liquid ammonia. As the liquid ammonia absorbs-the heat from the gas, the liquid ammonia flashes' to a vapor. The. intercooler also functions as a suction scrubber for the high stage compressors by removing the entrained ammonia liquid from several gas streams. The intercooler removes entrained liquids from the saturated gas streams from the booster compressor discharge. (including the gas from the boiling of the intercooler liquid ammonia), the process water cooler, glycol chiller, and the controlled pressure receiver. Depending on the plant's refrigeration requirements, liquid .~ia may accumulate in the intercooler. ~This fluid is discharged' to the Iov,~ ~on accumulator. Pestritto Foods, Inc. RMPP June, 1991' Page IV-4 · Luft Environmental Consulting Low ~Suction Accumulator DRAFT The Iow suction accumulator serves two purposes. First, it removes liquid ammonia entrained in the vapor line returning to the compressors from the evaporators. Ammonia vapors are returned to the compressor from the top of the accumulator. Second, it acts.as a reservoir for liquid ammonia returning i~n the vapor stream from the evaporators in the blast freezer and the holding freezer. The Iow suction accumulator also receives liquid from the intercooler. As the liquid ammonia accumulates in the vessel, it gravity flows through a check valve and into the dump trap. Dump Trap The dump trap collects liquid ammonia that settles i~ the bottom of the Iow suction accumulator, once the liquid in the dumP trap reaci...~,:$ a preset level, a solenoid valve opens and allows high pressure ammonia ga~ to push the liquid ammonia out of the dump trap and into the controlled pressure receiver. When the level in the dump trap drops Iow enough to reset the float switch, the solenoid valve closes and stops the flow of .high pressure gas. Air-Purger Minute leaks in the valve packing located in the Iow pressure ammonia lines (compressor;suction lines) allow air to be drawn into thesystem. The air, along with other non-condensible gases, degrades the performance of the system. To remove non-condensible gases from the ammonia system, the ammonia is fed · 'from the thermosyphon receiver into an air-pur, ger. The air-purger removes air from the ammonia by cooling the ammonia/air· mixture until the ammonia condenses. The air that remains is fed into a water bubbler where the small amount of residual ammonia is absorbed. This slightly ammonia laden water is then discharged into the sewer. Oil Pot .' The °il pot provides a method for removing.compressor oil from the ammonia refrigeration system. When the compressor oil is to be drained, liquid ammonia with the compressor oil 'will be drained from the Iow suction accumulator into the oil pot. An electric heater is then activated to boil the ammonia out of the ammonia/oil mixture. The ammonia vapors then flow to the Iow suction accumulator. After the ammonia is boiled off, the oil is drained manually from the oil pot. -. Pestritto Foods, Inc. RMPP Page IV-5 Luft Environmental Consulting june, 1991. .... PF-01 BOOSTER. ~;OMPRESSORI I' HIGHSTAGE I J COMP,RESSORI I I ! I .I · - I I ILINGTOWER I THERMO-SYPHON I RECEIVER AIR . pROCESS WATER PURGER HEAT EXCHANGER I SPIRAL FREEZER FREEZER CONTROLLED PRESSURE RECEIVER "i~ I I I I I I I LOW ~ DUMP ' ' ': SUCTION TRAP : ACCUMULATOR : I REFRIGERATION SYSTEM LIQUID AMMONIA GASEOUS AMMONIA' SPECIAL OPERATION 'LEC JUNE 1991~ TABLE 1 PESTRITFO FOODS, INC. 3'! L' ~ ~.- PLUME DISPERSION RESULTS . (~O~l-- · ~ VAPOR RELEASE OF 361 LBS OF AMMONIA LIQUID RELEASE OF 4001 LBS OF AMMONIA ATMOSPHERIC MODELING (~ONDITIONS ATMOSPHERIC MODELING RESULTS CONDITION AVERAGE ADVERSE PLUME DISTANCE OF PLUME TRAVEL CONCENTRAT,ON VAPOR RELEASE L,QU,D RELEASE (PPM) GAUSSIAN I HEAVY GAS GAUSSIAN I HEAVY GAS TEMPERATURE 95°F 40°F' MODELI MODEL MODELI ·MODEL HUMIDITY 25% 50% AVERAGE CONDITIONS CLOUD COVER 10% 70% 50 0.28 miles 0.71 miles 0.18 miles 0.43 miles ~ WIND SPEED 6.4 M PH 5.0 M PH 500 163 yards 357 yards 103 yards 216 yards WIND DIRECTION NW ENE ADVERSE CONDITIONS RELEASE DATE Summer Winter '. 50 0.39 miles 0.99 miles 0.25 miles 0.52 miles RELEASE TIME 4:00 P.M. 4:00 P.M. 500 239 yards 446 yards 137 yards 229 yards STABILITY CLASS B-Unstable C-Unstab/Neut PF-01 6-91 PESTRrR'O FOODS, INC. ~ PLUME DISPERSION RESULTS. ~ ~ ~ ~" ~'~ '~' vAPOR RELEASE OF 113.7 LBS OF AMMONIA LIQUID RELEASE OF 372.2 LBS OF AMMONIA ATMOSPHERIC MODELING CONDITIONS ATMOSPHERIC MODELING RESULTS CONDITION AVERAGE ADVERSE PLUME DISTANCE OF PLUME TRAVEL CONCENTRATION VAPOR RELEASE LIQUID ,,RELEASE (PPM) GAUSSIAN [ HEAVYGAS GAUSSIAN I HEAVYGAS TEMPERATURE 95°F 40°F MODEL, MODEL MODEL MODEL HUMIDITY 25% 50% AVERAGE CONDITIONS CLOUD COVER· 10% 70% - 50 283 yards 682 yards 105 yards ' 197 yards WIND SPEED 6.4'MPH 5.0 MPH 500 92 yards. 206 yards 33 yards 56 yards 'WIND DIRECTION NW ENE ADVERSE CONDITIONS · RELEASE DATE summer ~ 'Winter , · 50 .24 miles .51 miles 141 yards ~-~241 yards RELEASE TIME 4:00 P.M. 4:00 P.M. 500 134 yards 183 yards 44yards · 67 yards STABILITY CLASS B-Unstable C-Unstab/Neut LEC PF-01 6-91 PESTRI TO FOODS, PLUME DISPERSION.. RESULTS VAPOR RELEASE OF 2.54 LBS/SEC OF AMMONIA-FOR 10 sECONDS LIQUID RELEASE OF 9.71 LBS/SEC OF AMMONIA-FOR 10 SECONDS ~- ATMOSPHERIC MODELING CONDITIONS 'ATMOSPHERIC MODELING RESULTS "CONDITION AVERAGE' ADVERSE PLUME DISTANCE OF PLUME TRAVEL CONCENTRATION VAPOR RELEASE LIQUID RELEASE (PPM) GAUSSIAN I HEAVY GAS GAUSSIAN. HEAVY GAS TEMPERATURE 95°F 40°F MODELI MODEL .. MODEL MODEL HUMIDITY 25% 50% AVERAGE CONDITIONS. · CLOUD COVER 10% 70% 50 137 yards 281 yards 106 yards 201 yards WIND SPEED 6.4 MPH 5.0 MPH 500 44 yards 5~ yards 34 yards · 57 yards WIND DIRECTION NW ENE ADVERSE CONDITIONS RELEASE DATE Summer Winter 50 ~201 yards · 401 yards 141 yards 243 yards RELEASE TIME 4:00 P.M. 4:00 P.M. 500 63 yards 90 yards ,44 yards · 67 yards STABILITY CLASS B-Unstable C-Unstab/Neut PF-01 6~91 PLUME DISPERSION RESULTS VAPOR RELEASE OF 2.54 LBS/SEC OF AMMONIA-FOR 1 MINUTE LIQUID RELEASE OF 9.71 LBS/SEC OF AMMONIA-FOR 1 MINUTE CONDITION AVERAGE ADVERSE PLUME DISTANCE OF PLUME TRAVEL CONCENTRATION VAPOR . REL~SE LIQUID RELEASE TEMPERATURE 95°F 40°F MODELI MODEL MODELI MODEL HUMIDI~ 25% 50% AVERAGE CONDITIONS CLOUD COVER 10% 70% ~' 50 0.18 miles 0.45 miles 104 yards 196yards WIND SPEED 6.4 MPH 5.0 MPH ~. 500 106 yards 241 yards 33 yards 56 yards WIND DIRECTION NW' ' ENE ADVERSE CONDITIONS RELEASE DATE Summer Wi~er · ~ 0.27 miles 0.61 miles 140 yards ' 241 yards REL~SE TIME 4:00 P.M. .4:00 P.M. .. 500 -~ 155 yards 227 yards ~ yards 67 yards STABILI'~ C~SS ' B-Unstable C-Unstab/Neut . LEc PF-01 · 6-91 / ACUTELY ARDOUS MATERIALS RE STRAIl QU ,ANTITIES GREATER THAN 500 POUNDS, 55 GALLONS OR 200 C~ STP. I THIS FORM SHALL BE COMPLETED AND SUBMITYED TO Y~ ADMINISTERING AGENCY. (§25533 & 25536 Health & Safety Code) Note Instructions on revers~ Business Name Pestritto Foods Inc. Business Site Address 6800 McDivitt Bakersfield, CA 1991 BusLness Mailing Address Of. different) Business Phone 6fl~ ~R n6~ P.O. Box 328, Blackwood, N.J. 08012 Business Plan Submission Date2 3 -1-91 Process Designation3 ACUTELY HAZARDOUS MATERIALS I:IANDLED4 -USE ADDITIONAL PAGES IF NECESSARY- CHEMICAL NAME NH3 (Anhydro]]~ Ammonia) 7000 GENERAL DESCRIPTION OF PROCESSES AND PRINCIPAL EQUIPMENT The description of the MECHANICAL REFRIGERATION SYSTEM (MRS) is as follows The MRS is confined to three areas of the plant: Spiral, Freezer, Storage Freezer, and Equipment Room. The NH3 is circulated from the Equipment Room to Fan Coil Units located in the Spiral Freezer and the Storaqe Freezer in a insulated sealed steel piping network. Principal equipment is as follows: Spiral Freezer: One floor mounted fan coil unJ. t. Storaqe Freezer: Three ceiling mounted fan coil units.Equipment Room: Four motor driven compressors, Four ASME vessels, One roof mounted Continued on.next paqe..~ , SIGNATURE ~ /, / PRINTED NAME · ~.~ /- TITLE California Office of Emergency Services FORM HM 3777 (1-15-88) evaporative condenser. One propylene glycol chiller. One water plate chiller. One automatic relief system per 1988 IJMC and UFC codes. One sewer connected manual water NH3 diffusion system per 1988 UFC code,.located on exterior northwest cornor of equipment room. FIRE DEPARTMENT D. S. NEEDHAM FIRE CHIEF · CITY of BAKERSFIELD "WE CARE" 2101 H STREET BAKERSFIELD, 93301 326-3911: December 20, 1990 Dear Mr. Wuethrich, Your business Pestritto Foods Inc., to be looated at 6800 McDivitt Drive, has been identified as a future handler of an acutely hazardous material. It has been determined that your operation may present an acutely hazardous materials accident risk. Therefore, pursuant to section 25534 of the California Health and Safety Code? you will be required to submit a Risk Management and Prevention Program <RMPP) for the use and h~ndling of ANHYDROUS AM_MONiA. The RMPP shall be based upon a risk assessment which shall consider all of the following: THE RESULTS OF A HAZARD ANALYSIS WHICH IDENTIFIES THE HAZARDS ASSOCIATED WITH THE HANDLING OF AN ACUTELY HAZARDOUS MATERIAL DUE TO OPERATING ERROR, EQUIPMENT FAILURE AND EXTERNAL EVENTS WHICH MAY PRESENT AN ACUTELY HAZARDOUS MATERIALS ACCIDENT RISK. FOR THE HAZARDS iDENTiFIED IN THE HAZARD ANALYSIS, AN OFFSiTE CONSEQUENCE ANALYSIS WHICH ASSUMES PESSIMISTIC AIR DISPERSION AND OTHER ADVERSE ENVIRONMENTAL CONDITIONS. The RMPP shall include the following elements: A REPORT .SPECIFYING THE NATURE, AGE AND CONDITION OF THE EQUIPMENT USED TO HANDLE ACUTELY HAZARDOUS MATERIALS AT THE FACILITY. INCLUDE SCHEDULES FOR TESTING AND MAINTENANCE OF THIS EQUIPMENT. DESIGN, OPERATING AND MAINTENANCE CONTROLS WHICH MINIMIZE THE RISK OF AN ACCIDENT INVOLVING ACUTELY HAZARDOUS MATERIALS. DETECTION, MONITORING OR AUTOMATIC CONTROL SYSTEMS WHICH MINIMIZE THE 'POTENTIAL RISKS POSED BY ACUTELY HAZARDOUS. MATERIALS ACCIDENTS. IN RESPONSE TO THE FINDINGS OF THE RISK ANALYSIS, ADDITIONAL STEPS TO BE TAKEN BY THE BUSINESS IN ORDER TO REDUCE THE RISK OF AN ACCIDENT INVOLVING ACUTELY HAZkRDOUS MATERIALS. THESE ACTIONS MAY INCLUDE ANY OF THE FOLLOWING: .... INSTALLATION OF ALARM, DETECTION, MONITORING OR -AUTOMATIC CONTROL DEVICES. EQUIPMENT MODIFICATIONS, REPAIRS OR ADDITIONS. CHANGES IN THE OPERATIONS, PROCEDURES, MAINTENANCE SCHEDULES OR FACILITY DESIGN. -~ THE RISK MANAGEMENT AND PREVENTION PROGRAM SHALL IDENTIFY, BY TITLE, ALL PERSONNEL AT THE BUSINESS WHO ARE RESPONSIBLE FOR' CARRYING OUT THE SPECIFIC ELEMENTS .OF THE RMPP. AND A DESCRIPTION OF THEIR RESPECTIVE RESPONSIBILITIES. THE RMPP SHALL INCLUDE A DETAILED TRAINING PROGRAM TO INSURE THAT THOSE PERSONS ARE ABLE TO iMPLEMENT THE RMPP. AUDITING AND INSPECTION PROGRAMS DESIGNED TO ALLOW THE HANDLER TO CONFIRM THAT THE RISK MANAGEMENT AND PREVENTION PROGRAM IS EFFECTIVELY CARRIED OUT. RECORD KEEPING PROCEDURES FOR THE RISK-MANAGEMENT AND PREVENTiON'PROGRAM. THE ACUTELY HAZARDOUS MATERIALS HANDLER SHALL REVIEW THE RISK MANAGEMENT AND PREVENTION PROGRAM AND SHALL MAKE NECESSARY REVISIONS TO THE RMpp AT LEAST EVERY THREE YEARS. REVISIONS SHALL BE MADE WITHIN 60 DAYS FOLLOWING' A MODIFICATION WHICH WOULD MATERIALLY AFFECT THE HANDLING OF AN ACUTELY HAZARDOUS MATERIAL. Pur~uant~ t.o 25535(d) of the CA Health and Safety Code, "T~e owner or operator of a business shall implement all programs and activities in the RMPP before operations commence! in the case of a new facility, or before and new activiti%s involving acutely hazardous materials are taken in the case of a modified facility". The Risk Management and PreventiOn Program, and any revisions to it, shall be certified as complete by a qualified person and the facility operatorI A Risk Management and Prevention Program must be completed prior to occupancy of the new Pestritto'Foods plant zn Bakersfzetd. It usually takes a business several months to locate a qualified company or individual to carry out the hazard analysis, to have the plan's various elements reviewed by this ~dministering Agency knd to complet~ the RMPP. I suggest 6hat you begin work on this Risk Management Plan as soon as posszble'in order' to avoid delays in the. opening of the plan~. . The attached questionnaire, regarding the qualifications of the RMPP preparer, must,.be submitted to this.Agency prior to start of work on the RMPP. Upon approval of the preparer, we will.~gree..to.a-schedule f~r_the'completion.of the. hazard..,._ analysis and RMPP. The finished RMPP will be due prior to., occupancy of the facility at 6800 McDivitt Dr. All submittals shall be made to: The Bakersfield Fire Department 213'0 G Street Ba,kersfield, CA 93301 If I can be of any assistance .pleas'e feel free to call. I can be reached at 326-3979. ncerely, Barbara Brenner Hazardous Materials Planning Technician December 20~ 1990 To: Mr. Mike Quon Building Department Frcm~ Barbara Brenner Fire Department, Hazardous Materials The Hazardous Materi~ls Division is requiring that a Risk M~nagement ahd Prevention Plan be completed for the Pestritto Foods plant at 6800 McDivitt Rd. This plan will have to be submitted prior to occupancy of' the facility. We had mistakenly repo~ted that all hazardous materials reporting requirements were complete. As this is not the case~ please note this change in the file. Thank you H,.Z~Z 5RDOU S H !';~i TE R _T, A L r T f2 NSME OF DISK FiLE Ou,"'a¢i. On of disch¢~r'ge 22898 24848. 27598 See Chapter5 Z; and 12 o~ f, he .DU~d~ for4 .de~a:,i'~5. .boLir'ce r~eit~h'~; specif.i, ed "J'OX'!'C tq'~POR O ~SPFRS'r'Ohi ANALYSIS i~'d~. ~ c for e,z,.~:.ump~;ioqs usuc, irt !.8 18,8 r--,: ?, 2 ":;;", :5 .~ 2 1 J :5 9. ! PH¥S ;i] .OE:HEM i OF~L' F::!:";:OF'ERT i EE~ OF: ,%'~']'EF~ '[ F~L . ~"40RM,qL.. p' Ti T~,I,:: pr~'~'~,c? '' = .-2''4 p,"~ ~:r,~ii ,,'~c;, I,,,J!i::ICd--iT = .17 ~= '!29 = :.;.~ .,r:.; 7 ? __. TEM© OF ("i'"~\l'r~'[~x~'-'-rR F'nMTr-:~',ci''c: .... d ,':¢ g r" ,_=, d s F' psie. ...... ,._,. .......... .;(~l',!~... F;OENT hF'f%R COMPUTATION NCcNE O{~SERUED