P&C Perishables Distribution Center - Executive Summary |
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P&C Foods (P&C) operates an ammonia refrigeration process at its Perishable Distribution Center in Syracuse, New York. This process is subject to USEPA's Accidental Release Prevention rules, due to the presence of ammonia in excess of the rule threshold quantity of 10,000 pounds. These rules require P&C to initially conduct a hazard assessment of the refrigeration system, including compilation of a five-year history of relevant accidental releases, offsite consequence analysis to determine the area impacted by hypothetical releases, and evaluation of population size and sensitive receptors in the projected impact areas. On this basis, the rules further require P&C to develop programs to prevent accidental releases and to respond to release emergencies, to implement a management system over these programs, and to submit a Risk Management Plan (RMP) to USEPA by June 21, 1999, summarizing all programs in electronic format for public access via the Internet. The status of our Risk Management Program is summarized below. 7 Review of accident history reveals that no incidents involving ammonia releases causing adverse impacts offsite have occurred within the last five years; in fact no such incidents are reported to have ever occurred in the life of the facility to date. 7 Offsite consequence analysis (OCA) predicts that a hypothetical worst-case release of 25,000 pounds of ammonia would adversely affect an estimated population of 1,500, residing in a 10.91 square mile area (excluding plant property) extending 1.87 miles from the plant. Public receptors affected include residences, a school, commer cial/industrial facilities, and a public recreation area. No environmental receptors would be affected. For a continuous leak at a rate of 591 pounds per minute in an ammonia line off the high pressure receiver, OCA predicts that the closest residence approximately 975 feet away would be just within the impact area, affecting 4 individuals. This alternative release would affect no public receptors other than the residences and neighboring commercial/industrial facilities, and no environmental receptors. 7 Because the worst-case OCA predicts offsite consequences and the refrigeration process is subject to the OSHA Process Safety Management (PSM) Standard, the process is subject to full RMP requirements under Program 3 of the rule. To meet these requirements, PC has implemented refrigeration system design, installation, maintenance, and operator training guidance provided by the International Institute for Ammonia Refrigeration (IIAR), coordinated emergency response with the Local Emerg ency Planning Committee and fire department, and has developed a management system to ensure ongoing RMP compliance. |