Central Storage and Warehouse Company, Inc. - Executive Summary |
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PARTt I General Information Central Storage & Warehouse Co., Inc. (CSW) is complying with OSHA's Process Safety Management Standard (PSM), Title 29 Code of Federal Regulations (CFR) 1910.119 and EPA's Risk Management Program (RMP), Title 40 CFR 68 to control and eliminate the risks involved with the storage, handling, and processing of hazardous chemicals, specifically anhydrous ammonia. CSW intends to communicate this information to all interested individuals (including it's employees) and/or organizations that request or by law require knowledge on the company's efforts in dealing with the risks involved with its storage, handling and processing of anhydrous ammonia. Through these means the company will promote overall plant, worker and public safety. The policies, procedures and programs listed as references enable CSW to prevent incidents from happening and/or minimize the consequences of a large release of ammonia, as well as a fire/explosion, violent weather and other catastrophic accidents or occurrences. The common goal of these programs is to prevent injuries, illnesses, fataliities and to protect the facility from damage. CSW's safety programs cover a broad range of activity in the facility. The maintenance personnel are trained in the use and handling of aammonia, and all the equipment (compressors, vessels, piping, etc.) that are used in the cooling/freezing needs of the plant. They have received and continually receive training in hazardous chemical handling, emergency response to leaks/spills, in the proper use of the refrigeration equipment and to various safety programs that deal with the dangers of handling ammonia. The Plant Engineer is, in addition to the before mentioned, a Class A certified technician through the Refrigeraiton Engineers and Technicians Association (RETA) and has attended the IIAR refrigeration school. The remainder of the warehouse staff has been trained in a claaassroom type setting through the use of lecture, quiestion and answer sessions, film, written tests, and then on the job training. Much of this training deals with the various components of the OSHA Hazard Communication Standard 1910:1200, as it pertains tto chemicals on premises, the explanation of each chemical through use of Material Safety Data Sheets (MSDS), the location of this information, to whom requests for addditional information can be obtained, and the hazards of each chemiical. The majority of this training is concentrated on ammonia and is repeated annuallly. Addiitional staff training in material handling equipment, first aid, LockOut/TagOut and evacuation procedures, (although not ammonia speciifiic), make references to locations and what procedures are to be used to avoid locations where contact is possible. Truck drivers, customers and other individuals that visit the plant are made aware of the hazardous chemicals presence by signs or verbal communication and of any safety hazards they may encounter prior to their entry. Contractors are shown the areas in which they will work, hazards that they may encounter, preventative measures they must make prior to work and are requested to supply thier safety records. These safety programs prevent accidents since they focus on rules, procedures and practices that must be adhered to in the handling of ammonia, the equipment that contains it and the activities of those that work with it. These programs are communicated to all employees. Programs used to identify control, contain, maintain and report on hazardous chemicals on site: 1. 29CFR 1910.119 Process Safety Management, all it's elements 2. 29CFR 1910.151, Medical Services & First Aid 3. 29CFR 1910.1030 Bloodborne Pathogens 4. 29CFR 1910.138 Employee Emergency Plans and Fire Prevention Plans 5. 29 CFR 1910.120 Emergency Response 6. 29CFR 1910.146 Permit Requiired Confined spaces 7. 29 CFR 1910.1200 Hazard Communication Standard 8. 29CFR 19 10.147 The Control of Hazardous Energy, LockOut/TagOut 9. 29CFR Parts of 1910, 1915, 1917 & 1918 Powered Industrial Truck Operator Training 10. 1988 Drug Free Workplace Act 11. 29CFR 1910.132, 133, 134, 135, 136, 137 , 138 Personal Protection Equipment 12. Wisconsin Statute 166.20 & Section 312 of SARA Title III 13. CERCLA & SARA Title III Right to Know Laws 14. ASHRAE and ANSI Guidelines for good engineering practicies Part II Equiipment CSW's refrigeration system is charged with 18,900#s of ammonia and is comprised of (7) compressors, (1) high pressure ammonia receiver, (1) control pressure receiver, (2) intermediate pressure accumulators, (2) low pressure accumulators and piping that carries the ammonia too (39) evaporators located in (8) different storage areas that total 141,435 square feet or 3,021,065cubic feet. One storage area has (4) blast cells. (6) of the (7) compressors are located in a centrally located engine room. There are (2) high sta ge machines rated at 450HP & 400HP. There are (3) booster/low stage machines of which (1) is 150HP, and (2) are 100HP. One 325HP compressor is held in reserve. The (7)th compressor, a 150HP high stage is located in a different room approximately 20' west of the main engine room. Under normal circumstances either a 450HP or 400HP high stage copressor and a 150HP booster are running and if needed a 100HP low stage compressor is automatically turned on. On approximately October 1st of each year CSW receives upwards of 15,000,000#s of ambient temperature cranberries. At this time all equipment is used, except for the reserve unit, for a period of (60) days until the load returns to normal. The (4) blast cells require additional equipment be turned on, however, in varying degrees dependent on how much product is received at one time, the frequency of deliveries, the type of product and the hours required to reach the temperature objectiive. The 450HP and 400HP HIgh Stage mac hines plus the 150HP booster are liiquiid injection compressors with 300 PSIG dual safety relief valves. The 150HP High Stage and (1) of the 100HP units are liquid injection units with dual 250PSIG safety relief valves. The remaiing compressors are water cooled. The high pressure receiver, both intermediate pressure accumulators, and (1) of the low pressure accumulators have dual 250PSIG safety relief vaalves. The remainder of the system valves are 150PSIG. The refrigeration system has an audible alarm for ammonia leaks when they reach 200PPM during business hours. During off hours this alarm plus a system shut down is monitored by ADT. There are (4) people on a call list, one of which is notified of the problem and is responsible to take corrective action. Two sotrage areas are computer monitored. The product stored in the refrigerated areas is primariy food related. In the freezers, generally held at 0 degrees F. or below, the majority of the product consists of cr anberries, fruit concentrates, certain cheeses, bulk or print butter, boxed meat products, boxed vegetables, food service goods, chicken and bread products. The SuperChill, temeprature +28 degrees F. to +31degrees F. is used for dairy and meat products that must be held under +32degrees F. but above their freeze point. Temperature controlled space, temperature +/-5 degrees F., is held at +55 degrees F., and at a 50% humidity. Area is used to temper butter and to store candies that require low humidity and storage under +75 degrees F. Cooler space, +35 degrees F. to 42 degrees F., is used to store tempered butter, tempered concentrates, cheese, food coloring pastes and is a staging area for in and outbound loads. Part III Worst Case Scenario The worst case scenario is a 1" leak on the bottom of the #2 Low Temp Accumulator. Under maximum operating conditions this vessel is 75% full or stores 9,170#s of anhydrous ammonia. The vessel would empty within (10) minutes at an average of 917#s per minute. Using EPA's Table 4-2 Worst Case Scenario Predicted Distances to Toxic Endpoint for Anhydrous Ammonia an Atmospheric Stability Class F with Windspeed 1.5 m/s is 1.21 miles. The worst case scenario is unlikely for the following reasons: 1. Worst case weather conditions are uncommon. 2. The vessel is located in the engine room away from all truck and forklift activity. 3. Buiilt to industry standards for the manufacture and quality control of pressure vessels. 4. Ammoniia is not corrosive in this process. 5. There are dual 250PSIG pressure safety valves which limit the operating pressure of the vessel. 6. An in-house accident prevention procedure. 7. A mechanical integrity/check program for reguar maintenance, inspection and testing. 8. An emergency response program in place. 9. A RETA and IIAR trained engineer. 10. PSM Program current. Part IV Alternate Scenario The allternate release scenario is most likely to occur on t he west dock of the facility if a forklift mast would rupture or break a ceiling mounted ammonia pipe 1 1/2" in diiameter that feeds two freezer compartments. This would result in a vapor release of 3,849#s of ammonia over a period of 6.08 minutes. Using the RMP reference table 4-3, an incident of this type would pose a very minimal health hazard to the general public since the majority would be contained within the bulding while the rest will dissipate within 0.21 miles of the building. This scenario is unlikely since the majority of the piping is located out of the main travel patterns on the dock and is at ceiling height level, equipment operators have been trained to keep the tall masted equipment out of these areas, the employees have been trained in the Hazaard Communication Standard 29CFR 1910.200 of the PSM program, the mechanical integrity program for regular maintenance, inspection, testing and the replacement of equipment when necessary. If necessary the emer gency response plan and equipment are in place. PART V ACCIDENT RELEASE PROGRAM The programs CSW uses to prevent an accidental release of anhydrous ammonia are OSHA PSM 29 CFR 1910.119, the EPA RM Program 40CFR Part 68 and ANSI/IIAR Standard for equipment, design, and installation of ammonia refrigeration systems. Written operating procedures and a maintenance check list of all equipment requiring inspections and their frequency are used for preventive maintenance and/or replacement. In addition, the Plant Engineer, who is a RETA Certified Class A Technician, continues to attend RETA meetings, receives his (8) hours HAZWOPPER Refresher course annually and attends various other refrigeration related seminars. The non-maintenance staff is schooled annually on OSHA 1910.147 LockOut/TagOut, 29 CFR 1910.1200 Hazard Communication Standard, 29 CFR 1910, 1915, 1917, & 1918 Fork Lift Training and Evacuation procedures. The training focuses on ammonia and the refrigeration equipment insuri ng the company that all are aware of the serious consequences an ammonia incident can have. PART VI INCIDENT HISTORY During the last five years there have been no qualifying accidents, in fact there have been no quailifying incidents related to equipment failure or breakdown in this period. PART VII FACILITY RESPONSE PROGRAM CSW's Emergecy Response Program is based on OSHA's Emergency Action Plans 29 CFR 1910.38 and 1910.119 plus HAZWOPPER 1910.120. The Plant Engineer is fully trained to respond to emergencies. Other selected employees are assigned specific tasks related to the incident and only if the area in which they will work is unaffected from all incident consequences. The Company has a written emergency plan that deals with ammonia spills, fire and severe weather. The Madison Fire Department's closest station is located within 1,000 feet of the facility and has resident HAZ-MAT personnel on site. The station personnel visit our plant and the fire department conducts a m inimum of two complete annual safety inspections. The Dane County Department of Emergency Management (LEPC) produces a OFF-SITE PLAN specifically for CSW. This plan was developed with the company's imput and is reviewed frequently by both parties. Lists of names and telephone numbers of the Madison Fire Department, the Madison Police Department and in case of a chemical spill or potential of same the Dane County Emergency Government, The Wisconsin Emergency Response Commission and the EPA Hotline are posted throughout the facility. The Plants' Safety Co-ordinator will then contact the appropriate management personnel. PART VIII PLANNED CHANGES Immediate plans include the OSHA updates on forklift operations & Personal Protective Equipment (PPE) use. We are currently developing an extended plan to increase our computer control of the refrigeration system and remote control of same. An item specific maintenance list of all equipment is being compiled and will be used for preventati ve maintenance and equipment analysis. Inspection frequencies , regulations governing the specific equipment and corrective action are components of the list. |