DOT Foods Inc. (Williamsport) - Executive Summary

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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES 
 
The DOT Foods, Williamsport, facility has an emergency response plan in effect.  The Emergency Response Plan (Plan) is detailed in the Emergency Planning and Response section of the PSM/RMP document.  This Plan was designed to meet the following objectives: 
 
1.)To save lives. 
2.)To minimize and avoid injuries. 
3.)To protect the environment. 
4.)To minimize property damage. 
 
DOT Foods maintains a safety committee whose members are the designated emergency coordinators for the facility.  The Plan provides the response organization and notification procedures, evacuation routes, ammonia health hazards, and mitigation procedures which will be implemented to respond effectively to emergency situations that may arise at the facility.  This Plan is reviewed and updated at least once per year.  This Plan was reviewed and updated to ensure compliance with the PSM and RMP regulations, as well as to incorporate facility changes. 
 
 
STAT 
IONARY SOURCE AND REGULATED SUBSTANCE 
 
The DOT Foods ammonia refrigeration system has been in operation since 1995.  Changes/modifications have taken place since the completion of the facility with an expansion in 1999.  The ammonia refrigeration process was designed and constructed in accordance with all applicable federal, state, and local regulations.  The facility is located at 16301 Elliot Parkway, Williamsport, Maryland 21795. 
 
The ammonia refrigeration system uses 15,000 pounds of ammonia for dock operations, warehouse cold storage, and freezer storage.  The majority of the system is located in the machine room including vessels and compressors.  The condensers are mounted on the machine room roof, the water tank is located in the existing machine room, and all of the evaporators are located in their respective cold storage rooms/areas. 
 
 
ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS 
 
The DOT Foods facility was designed and constructed in accordanc 
e with the Uniform Mechanical Code which specifically outlines requirements for the safe operation of ammonia refrigeration systems.  These safety features include ammonia sensors in the machine room as well as sensors in selected cold storage areas, and automatic shut down systems.  In addition, the majority of the ammonia is maintained inside the machine room or on the machine room roof (condensers). 
 
Ammonia sensors are present in the machine room and cold storage areas.  The system shuts down if a concentration of 10,000 ppm is detected.  Once the renovation is complete in 1999, operators will have the ability to dial into the central computer and read the alarm from a portable computer.   
 
In addition to the Uniform Mechanical Code, the facility will operate in accordance with the International Institute of Ammonia Refrigeration (IIAR) guidelines.  In particular, the IIAR Bulletin 110, "Startup, Inspection, and Maintenance of Ammonia Refrigeration Systems." 
 
 
HAZARD ASSESSMENT SUM 
MARY 
 
Worst Case Release Result Summary 
Scenario Description: Release of the maximum quantity of ammonia that can be stored in the +150 Recirculator - 11,000 pounds - in 10 minutes.  The Recirculator is located within an enclosure, therefore, passive mitigation measures were used.  The most pessimistic meteorological conditions were used: 1.5 m/s and F stability for a rural area.  The EPA's RMP Guidance for Ammonia Refrigeration was used to determine the distance to the toxic endpoint of 200 ppm.  This scenario reaches off-site may affect population receptors.  No environmental receptors were affected by this potential scenario. 
 
Alternative Release Result Summary 
Scenario Description: A 0.25 inch diameter leak of high pressure liquid ammonia for one hour.  The quantity of ammonia released in one hour at a rate of 134 pounds per minute is 8,040 pounds.  The meteorological conditions used were 3 m/s and D stability for a rural area.  The EPA's RMP Guidance for Ammonia Refrigeration was  
used to determine the distance to the toxic endpoint of 200 ppm.  This scenario reaches off-site may affect population receptors.  No environmental receptors were affected by this potential scenario. 
 
 
FIVE YEAR ACCIDENT HISTORY 
 
This facility has been in operation since 1995 and changes/modifications have taken place since the completion.  There is no accident history at this facility. 
 
 
EMERGENCY RESPONSE PROGRAM 
 
If an ammonia release were to occur, the DOT Foods response is to call the fire department's HazMat team to help aid in the shut down of the plant.  Once the renovation is complete in 1999, operators will have the ability to dial into the central computer and read the alarm from a portable computer.  Ammonia sensors are present in the machine room and cold storage areas.  The system shuts down if a concentration of 10,000 ppm is detected.  During off-hours, the alarm is directed to an outside alarm company that calls the on-call operator. 
 
Employees within the building are  
evacuated to a point upwind of the facility or shelter in place.  Evacuation drills are performed annually.  The Emergency Response Plan (Plan) is detailed in the Emergency Planning and Response section of this PSM/RMP document.  This Plan was reviewed and updated to ensure compliance with the PSM and RMP regulations, and is reviewed annually to ensure that the plan is kept current. 
 
 
PLANNED CHANGES TO IMPROVE SAFETY 
 
The Process Hazard Analysis provided the mitigation measures outlined below to improve safety at the DOT Foods facility located at 16301 Elliot Parkway, Williamsport, Maryland and are scheduled to be complete by June 2000. 
 
R01 Verify that a warning alarm is present on the readout on the main computer which shows the ammonia concentration level in the machine room and the set point in which it alarms.  It was suggested that the alarm is consistent with other DOT Foods facility alarms. 
 
R02 Include in the Mechanical Integrity program to periodically test the ammonia detec 
tion system. 
 
R03 Consider flexibility of remotely shutting down the system through the central computer system. 
 
R04 Develop a plan that includes those persons responsible for responding to a leak.  Verify that the proper training and procedures are intact.  Coordinate with the local fire department, HAZMAT Team, responding agency, and/or outside contractor regarding whether they will assist DOT Foods with entering the engine room to shut down a release. 
 
R05 If DOT Foods decides to purchase SCBAs, ensure that the proper training is provided. 
 
R06 Develop a procedure to notify all employees and outside contractors including truck drivers that ammonia is present at the facility and the location of the evacuation assembly areas. 
 
R07 Develop a written emergency plan/evacuation plan. 
 
R08 Schedule relief valve change outs with the DOT East facility. 
 
R09 Include in the Mechanical Integrity program that the manufacturer's recommendations for the safety equipment is included. 
 
R10 Consider 
using RETA and ammonia suppliers for properly training operators on ammonia hazards. 
 
R11 Ensure that all employees know that ammonia is on site and the action taken in case there was an ammonia release. 
 
R12 Include in the Mechanical Integrity program to rebuild seals on pumps. 
 
R13 Include in the Mechanical Integrity  program to manually trip the high level shut offs on the ammonia vessels annually. 
 
R14 Include a written set of procedures for oil draining. 
 
R15 Consider controlling evaporator solenoid valves from the main computer in order to isolate an evaporator. 
 
R16 Verify from design plans that an equipment disconnect is located on the roof so that the operator can perform a lockout-tagout operation. 
 
R17 Ensure that operators notify someone and an estimated time of return is given when performing work on the roof. 
 
R18 Consider installing a wench to haul tools to the roof. 
 
R19 Include in the Mechanical Integrity program to follow the manufacturer's recommendations in checkin 
g the compressor safety cutouts. 
 
R20 Consider using vortex system for a continuous water treatment system instead of chemicals. 
 
R21 Consider having an operator take a portable eyewash with them when working on the roof, or use goggles. 
 
R22 Consider installing a water line to the roof. 
 
R23 Coordinate with the fire department with the use of the Diffusion Box in the case of emergencies. 
 
R24 Ensure that the evacuation assembly areas are not in the path of the sewer line/manholes. 
 
R25 Include in the emergency response plan to call the necessary parties if ammonia is dumped into the sewer system. 
 
R26 Install a warning light in the shop area outside the machine room to warn of an ammonia leak.  Tie the visual light to the ammonia detector inside the machine room. See recommendation R01 concerning the concentration level. 
 
R27 Ensure that ammonia safety placards are installed on all doors to the machine room. 
 
R28 Install an escape mask in the electrical room in case there was an amm 
onia release in the machine room and an operator needed to evacuate.   
 
R29 Evaluate the possibility of evacuating the building or sheltering-in-place and turning off the ventilation system if ammonia was released. 
 
R30 Decide who on the night shift will give the alarm to evacuate in case of an ammonia release.
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