Zero Mountain, Inc. - Executive Summary

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General Executive Summary for Chemical, Manufacturing and Oil Refining Facilities 
1.    Accidental Release Prevention and Emergency Response Policies 
We at Zero Mountain, Inc. are strongly committed to employee, public and environmental safety.  This commitment is demonstrated by our comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance, and employee training associated with the process at our facility.  It is our policy to implement appropriate controls to prevent possible releases of the regulated substance. 
2.    The Stationary Source and the Regulated Substances Handled 
Our facility's primary activities encompass refrigerated warehouse storage and Blast (quick) freezing for low temperature food storage and handling.  We have 1 regulated substance present at our facility.  This substance is  Anhydrous Ammonia.  Ammonia is used to remove heat from the Docks, Freezers, Cooler, and Blast cells to maintain an a 
ppropriate level of refrigerated air temperature for food storage.                                        . 
The maximum inventory of Ammonia (anhydrous) at our facility is approximately 40,000 lb.. 
3.    The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario 
To perform the required offsite consequence analysis for our facility, we have used the EPA's RMP Guidance for Ammonia Refrigeration  Reference Tables or Equations.  The following paragraphs provide details of the chosen scenarios. 
The worst case release scenario submitted for Program 3 toxic substances as a class involves a catastrophic release from the Ammonia Refrigeration System.  In this scenario 6413.65 lb. of Anhydrous Ammonia is released.  The toxic liquid released is assumed to form a 1 cm deep pool from which evaporation takes place.  The entire pool is estimated to evaporate over 10 minutes.  A 
t Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 1.48 miles is obtained corresponding to a toxic endpoint of 200 parts per million (ppm)(0.14 mg/L). 
One alternative release scenario for Ammonia (anhydrous) involves a release from the Condenser safety relief valve of the Ammonia Refrigeration System.  The scenario involves the release of 421.20 lb. of Ammonia.  Toxic gas is assumed to be released into the atmosphere over 10 minutes.  The release is also assumed to be controlled by emergency shutdown system(s) and Emergency Response from Maintenance and Haz-Mat personnel.  Under neutral weather conditions, the maximum distance to the toxic endpoint of 200 parts per million (ppm))0.14 mg/L) of Ammonia (anhydrous) is 0.14 miles. 
Another alternative release scenario for Ammonia (anhydrous) involves a release from the Ammoina Pump safety relief valve off the Low-Low Accumulator of the Ammonia Refrigeration System.  The scenario involves the release of 14 lb. o 
f Ammonia.  Toxic gas is assumed to be released into the atmosphere over 0.33 minutes.  The release is also assumed to be controlled by emergency shutdown system(s) and Emergency response by Maintenance and Haz-Mat Team personnel..  Under neutral weather conditions, the maximum distance to the toxic endpoint of 200 parts per million (ppm)(0.14 mg/L) of Ammonia (anhydrous) is 0.14 miles. 
4.    The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps 
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68 of the EPA.  This facility was designed and constructed in accordance with ANSI/IIAR-2-1984 & 1992 "Equipment, Design, and Installation of Ammoina Mechanical Refrigeration Systems".  The following sections briefly describe the elements of the release prevention program that is in place at our facility. 
Process Safety Information 
Zero Mountain, Inc. maintains a detailed re 
cord of safety information that describes the chemical hazards, operating parameters and equipment designs associated with the process. 
Process Hazard Analysis 
Our facility conducts comprehensive studies to ensure that hazards associated with our process are identified and controlled efficiently.  The methodology used to carry out these analyses is the "What if...Methodology.  The studies are undertaken by a team of qualified personnel with expertise in engineering, safety, and process operations and are revalidated at a regular interval of at least every five years or on an as needed basis.  Any findings related to the hazard analysis are addressed in a timely manner.  The most recent PHA/update was performed on 05/03/1999. 
Operating Procedures 
For the purposes of safely conducting activities within our covered process, Zero Mountain, Inc. maintains written operating procedures.  These procedures address various modes of operation such as initial startup, normal operations, temporar 
y operations, emergency shutdown, emergency operations, normal shutdown and startup after a turnaround.  The information is regularly reviewed and is readily accessible to operators involved in the process. 
Zero Mountain, Inc. has a comprehensive training program in place to ensure that employees who are operating processes are competent in the operating procedures associated with these processes.  Refresher training is provided at least every three years and usually every six months or as needed. 
Mechanical Integrity 
Zero Mountain, Inc. carries out highly documented maintenance checks on process equipment to ensure proper operations.  Process equipment examined by these checks includes among others; pressure vessels, storage tanks, piping systems, relief and vent systems, emergency shutdown systems, controls and pumps.  Maintenance operations are carried out by qualified personnel with previous training in maintenance practices.  Furthermore, these personnel are offered spe 
cialized training as needed.  Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. 
Management of Change 
Written procedures are in place at Zero Mountain, Inc. to manage changes in process chemicals, technology, equipment and procedures.  The most recent review/revision of maintenance procedures was performed on 01/29/1999.  Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. 
Pre-startup Reviews 
Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at Zero Mountain, Inc..  The most recent review was performed on 03/12/99.  These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operatio 
Compliance Audits 
Zero Mountain, Inc. conducts audits on a regular basis to determine whether the provisions set out under the RMP rule are being implemented.  The most recent comliance audit was conducted on 12/29/1997.  These audits are carried out at least every 3 years and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. 
Incident Investigation 
Zero Mountain, Inc. promptly investigates any incident that has resulted in, or could reasonably result in a catastrophic release of a Anhydrous Ammonia.  These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring.  All reports are retained for a minimum of 5 years. 
Employee Participation 
Zero Mountain, Inc. truly believes that process safety management and accident prevention is a team effort.  Company employees are strongly encouraged to express their views concerning accident preven 
tion issues and to recommend improvements.  In addition, our employees have access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. 
On occasion, our company hires contractors to conduct specialized maintenance and/or construction activities.  Prior to selecting a contractor, a thorough evaluation of safety performance of the contractor is carried out.  Zero Mountain, Inc. has a strict policy of informing the contractors of known potential hazards related the contractor's work and the process.  Contractors are also informed of all the procedures for emergency response should an accidental release of Anhydrous Ammonia should occur. 
5.    Five-year Accident History 
Zero Mountain, Inc. has had an excellent record of preventing accidental releases over the last 5 years.  Due to our stringent release prevention policies, there has been no reportable accidental release d 
uring this period. 
6.    Emergency Response Plan 
Zero Mountain, Inc. carries a written emergency response plan to deal with accidental releases of hazardous materials.  The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of equipment and/or affected areas. 
To ensure proper functioning, our emergency response equipment is regularly inspected and serviced.  In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. 
Sebastian County OES is the agency with which our emergency plan has been coordinated and verified. 
7.    Planned Changes to Improve Safety 
Several developments and findings have resulted from the implementation of the various elements of our accidental release prevention program.  We have installed an Emergency 
Dump Station to reduce the risk associated with the system in the event a fire occurs in the engine room of the facility.  It is completed and ready for full operation, if needed.
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