Bellingham Cold Storage Company-Orchard Drive - Executive Summary |
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Bellingham Cold Storage Company ("BCS") owns and operates two cold storage facilities in Bellingham, Washington. The Orchard Drive facility, located at 600 Orchard Drive, is a warehouse for storage of frozen food products for various manufacturers as well as a retail seafood freezing operation. The Orchard Drive facility employs approximately 10 people. BCS's Orchard Drive facility uses anhydrous ammonia for refrigeration of the products in storage. Anhydrous ammonia is subject to EPA regulation under 40 CFR 68, Accidental Release Risk Management of Highly Hazardous Chemicals. Pursuant to the RMP regulations (40 CFR 68) and the Process Safety Management (PSM) regulations, BCS has developed a comprehensive PSM written program to protect our employees and the surrounding community from exposure to the hazardous chemicals onsite. BCS completed a process hazards analysis (PHA) for the ammonia system using the Hazard and Operability study methodology. The PHA was completed using technic al and operations staff from the facility as well as experienced facilitators from an outside engineering firm. BCS's implementation of the PSM program includes employee education in the hazards of ammonia and measures that can be used to reduce employee and community exposure to accidental releases of ammonia. The plans include preventive maintenance programs (mechanical integrity) for the ammonia system, as well as a program for both pre-startup safety reviews and management of changes (MOC) to this system. The program also includes specific requirements for safe work practices (such as safe approaches to welding and similar hot work) and safety requirements for contractors who may be hired to work on the system. Lastly, the PSM written program incorporates the BCS emergency response plan and places special emphasis on handling accidental releases of hazardous chemicals and coordination of emergency response with local fire departments and other emergency response organizations. A s part of the RMP requirements, BCS undertook a review of the potential offsite consequences of the accidental releases of the largest vessels in the system. Although such a release is highly unlikely, the regulation requires this review. The following is a description of the results: Ammonia Refrigeration BCS stores and uses anhydrous ammonia on site for refrigeration of products in storage. Ammonia is used for its excellent energy efficiency and flexibility, in addition to benefits to employee safety. Ammonia at the facility is kept entirely within the refrigeration system. The Orchard Drive facility has never experienced a release of ammonia involving consequences that affected residents or the environment. The worst case scenario was assumed to be the release of the entire contents of the 26,143-pound capacity of the low-pressure receiver which is located indoors. The analysis of this release indicates that a potential exposure of an area approximately 1.94 miles in diamete r (distance to endpoint of 0.97 miles) would result. The total population within the potential exposure area is estimated to be 1,706. This worst-case release scenario presents the potential to affect public receptors, including residences, schools, hospitals, parks, and businesses; however, there are no environmental receptors that would be affected. In determining the alternate case scenario for ammonia, BCS analyzed incidents occurring at other refrigeration facilities and the results of the internal process hazards analysis (PHA). The scenario chosen for the ammonia system assumes a =" hole in a liquid return pipe from the outside condensers. Such a release would affect an area of 0.36 miles (0.18 miles to the toxic endpoint) and create the potential to affect approximately 52 persons. Residences and businesses are located within this area. BCS is committed to minimizing accidental releases of ammonia from the refrigeration process at the Orchard Drive facility. Facility mana gement is involved in the design, operation, and maintenance of the system. BCS employees at all levels have been involved in the development of the PSM and RMP programs. Management has committed to working with local agencies to educate the public regarding the hazards of ammonia and to ensure a safe workplace and surrounding community. Specific questions regarding RMP compliance at BCS should be addressed to the Mr. Douglas Thomas, President of Bellingham Cold Storage Company. |