Industrial Cold Storage - Executive Summary |
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RMP Executive Summary 1.0 Accidental release prevention and emergency response policies at Industrial Cold Storage, Inc. ('68.155(a) ). Industrial Cold Storage prevents accidental releases through classroom and on the job training of refrigeration personnel and ongoing inspection and maintenance of the refrigeration system. Refrigeration system components are located in areas that are not as likely to become damaged (i.e., pipes placed on roofs, tanks placed away and protected from forklift and truck traffic). Industrial Cold Storage has a proactive emergency preparedness policy. Key technical and supervisory personnel are properly trained and equipped to respond to on site anhydrous ammonia releases, requiring entry into contaminated zones, rescue, risk assessment and spill and leak control. 2.0 Source and regulated substances handled ('68.155(b)). Approximately 50,000 lbs. of anhydrous ammonia is contained within the refrigeration system on site at Industrial Cold Storage. The EPA requires a Risk Management Plan be developed and maintained when the total amount of anhydrous ammonia exceeds the threshold quantity of 10,000 lbs. No other substances, in quantities subject to EPA RMP certification requirements, are located at the Industrial Cold Storage facility. 3.0 Worst Case and Alternate Case Release Scenarios ('68.155(c)). 3.1 Worst Case Scenario (WCS) The vertical anhydrous ammonia high-pressure receiver located outside and east of the engine room contains the largest quantity of anhydrous ammonia, on site, on a predictable worst case basis. This tank holds approximately 9,952 lbs. of anhydrous ammonia when 50% full under an internal pressure and temperature of approximately 181 psig and 95 0F. The Worst Case Scenario as required by EPA, assumes that the tank's contents are fully released as a gas/vapor over a 10-minute period. The dispersion model, "Screen3", predicted, with a wind speed of 3 mph and atmospheric stability class F, the anhydro us ammonia release may travel 1.1 miles from the point of release (See: Appendix B). Approximately 10,000 people, in the surrounding community, reside within the radius to the toxic endpoint (level of concern = 200 ppm, anhydrous ammonia). A list of schools, churches, parks, etc. that lie within the radius to the toxic endpoint are listed in Appendix C. 3.2 Alternate Case Scenario (ACS) The Alternate Case Release Scenario for Industrial Cold Storage was selected to involve a relief valve failure on the roof above the engine room. Anhydrous ammonia (at approximately 136 psi and 105 0F) was estimated to have a flow rate of approximately 92 lbs./min from two-phase (gas/liquid) choked flow equations. It is estimated that the supply line containing the relief valve could be isolated in approximately 45 minutes by trained operators arriving from offsite, with a corresponding anhydrous ammonia quantity released of approximately 4171 lbs. The Screen3 air dispersion model predicted, wi th a wind speed of 6 mph, that the anhydrous ammonia release may travel approximately 0.11 miles. Approximately 28 people reside within the radius to the toxic endpoint (level of concern = 200 ppm, anhydrous ammonia). A list of schools, churches, parks, etc. that are located within the radius to the toxic endpoint are listed in Appendix C. 4.0 Accidental release prevention program ('68.155(d)). Industrial Cold Storage standard policy requires daily monitoring and inspection of the anhydrous ammonia refrigeration system by trained employees, or contracted services personnel, in accordance with OSHA and IIAR guidelines. Necessary repairs to the refrigeration system are made in a prompt, safe manner. 5.0 5 year accidental history ('68.155(e)). No releases or accidents, involving anhydrous ammonia, that are reportable in accordance with 40 CFR Part 68 (RMP Rule), have occurred at this facility. 6.0 Emergency response program ('68.155(f)). 6.1 During normal workday operation, the facility emergency response plan consists of employee notification (public address system) and evacuation, followed by notification of the Jacksonville Fire and Rescue Department (nearest station to ICS is department # 17, 710 Huron St.). Security Concepts (1279 Scotts Rd., Jacksonville, FL., (904) 730-9191) also monitors the anhydrous ammonia detector alarms on a continuous basis. Maintenance and technical personnel have received hazardous material technician level training in accordance with OSHA 29CFR 1910.120(q)(iii). Supervisory personnel have received incident commander level training in accordance with OSHA 29 CFR 1910.120(q)(v). A facility emergency evacuation plan has been prepared and disseminated to facility personnel. Evacuation routes in case of an anhydrous ammonia release are noted on the plan. 6.2 Red Cross shelter resources in the Jacksonville area consists of pre-arranged service agreements with the local school board and some local churches. Schools that would serve as a Red Cross shelter would provide space and cafeteria food to shelter inhabitants. Schools would be reimbursed for food/supplies by the Red Cross. The nearest Red Cross shelter, to Industrial Cold Storage, is the Robert E. Lee Sr. High School (1200 S. McDuff Ave., (904) 381-3930). In addition, the local Red Cross office is capable of supplying shelter kits consisting of basic first-aid supplies and blankets, with a reserve supply of goods located at Cecil Field. A Fire Department Commander or Police Commander would decide if evacuation and sheltering is required in a given emergency, who would then notify the Duval County Emergency Operations Center (EOC) (Andy Sykes, 515 Julia St., Jacksonville, FL (904) 630-2427), who would run the TASO computer dispersion model to determine where evacuation is needed. The EOM would then direct the Red Cross to activate the designated shelter(s). Reference: Northeast Florida Red Cross Office, Garfield Jones, Assistant Director f or Disaster Services, (904) 358-8091. 7.0 Planned changes to improve safety ('68.155(g)). Future plans to improve anhydrous ammonia refrigeration system safety at Industrial Cold Storage consist of training non-refrigeration supervisory personnel (i.e., loading dock supervisors) on the refrigeration system for 24-hour on site emergency watch. Other plans are continuing annual operator refresher training, hazardous materials technician and incident commander training, and refrigeration system process safety management program inspection audit annually. |