Claxton Cold Storage, Inc. - Executive Summary |
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RMP Executive Summary: 1.0 Accidental release prevention and emergency response policies at Claxton Cold Storage ('68.155(a) ). Claxton Cold Storage prevents accidental releases through on the job training of refrigeration personnel and ongoing inspection and maintenance of the system. New additions to the refrigeration system are located in areas that are not as likely to become damaged (i.e., pipes placed near ceilings, tanks placed away from forklift and truck traffic). 2.0 Source and regulated substances handled ('68.155(b)). 14,000 lbs. of anhydrous ammonia is contained on site at the Claxton Cold Storage facility. The EPA requires a Risk Management Plan be developed and maintained when the total amount of anhydrous ammonia exceeds the threshold limit of 10,000 lbs. 3.0 Worst Case and Alternate Case Release Scenarios ('68.155(c)). 3.1 Worst Case Scenario (WCS) The receiver/re-circulator tank in the engine room predictably contains the largest quantity of anhydrous a mmonia during at least one day per year. The maximum predicted quantity is assumed to be 100% capacity of the tank filled with anhydrous ammonia from the refrigeration system caused by a site electrical power loss or similar event. This tank typically holds approximately 2,375 lbs. at 33% capacity and can hold 7,187 lbs. at 100% capacity under an internal pressure and temperature of 181 psig and 95 0F respectively. The worst case scenario assumes that the tank's contents are fully released over a 10 minute period. The dispersion model Degadis predicted, with a wind speed of 3 mph and atmospheric stability class F, the release may travel approximately 1.4 miles from the point of release (See: Appendix B). Approximately 690 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 Alter nate Case Scenario (ACS) The Alternate Case Release Scenario for the Claxton Cold Storage facility was selected to involve a Frigid Cool Air unit supply line, on the loading dock, severed by a forklift truck during loading operations. The 3/4 inch pipeline extends approximately 14 feet from the air unit inside the loading dock to the isolation valves located on the roof. Ammonia (at 45 psi and 15 0F) was estimated to have a flow rate of 108 lbs./min from two-phase (gas/liquid) choked flow equations (Tscreen dispersion model). It is estimated that the supply line could be isolated in approximately 10 minutes, with a corresponding total quantity in the supply line released of approximately 1080 lbs. of anhydrous ammonia. Screen3 air dispersion models used, predict, with a wind speed of 5 mph, the ammonia release, under these conditions may travel approximately 0.4 miles. Approximately 60 people reside within the radius to the toxic endpoint (level of concern = 200 ppm, anhydrous am monia). 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)). Claxton Cold Storage standard policy requires daily inspection of the 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)). Emergency Response: During normal workday operation, the facility emergency response plan consists of employee notification (alarm) and evacuation, followed by notification of the Claxton Fire Department. Maintenance and technical personnel have received hazardous material te chnician 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 ammonia release, are noted on the plan. 7.0 Planned changes to improve safety ('68.155(g)). Future plans to improve ammonia refrigeration system safety at Claxton Cold Storage include continuing annual operator refresher training, hazardous materials technician and incident commander training, and facility and refrigeration system process safety management program inspection audit annually. |