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 processes at our facility. It is our policy to implement appropriate controls to prevent possible releases of regulated substances. 2. The Stationary Source and the Regulated Substances Handled Our facility's primary activities encompass Refrigerated Warehouse for low temperature food storage. We have 1 regulated substance present at our facility. This substance is Anhydrous Ammonia. Ammonia is used as a refrigerant in our system. The maximum inventory of Ammonia (anhydrous) at our facility is approximately 56,000 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 our Program 3 toxic substance involves a catastrophic release from the High Stage Accumulator of the Ammonia Refrigeration System. In this scenario 10243.40 lb. of Ammonia (anhydrous) 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. At Class F atmospheric stability and 1.5 m/s windspeed, the maximum distance of 1.42 miles is obtained corresponding to a toxic endpoint of 200 parts per million (ppm)(0.14 mg/L). On e alternative release scenario for Ammonia (anhydrous) involves a release from a safety relief valve on Condensers #1 & #2 of the Ammonia Refrigeration System. The scenario involves the release of 421.20 lb. of ammonia vapor. Toxic gas is assumed to be released to the atmosphere. The entire release is estimated to have occurred for 10 minutes. The release is also assumed to be controlled by our emergency dump station, emergency shutdown systems, ammonia sensors and emergency response from the haz-mat team. 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 0.06 miles. Another alternative release scenario for Ammonia (anhydrous) involves a release from a safety relief valve on the Thermosyphon of the Ammonia Refrigeration System. The scenario involves the release of 421.20 lb. of ammonia vapor. Toxic gas is assumed to be released to the atmosphere. The entire release is estimated to h ave occurred for 10 minutes. The release is also assumed to be controlled by the emergency dump station, emergency shutdown systems, ammonia sensors and emergency response from the haz-mat team. Under neutral weather conditions, the maximum distance to the toxic endpoint of 200 part per million (ppm)(0.14 mg/L) of Ammonia (anhydrous) is 0.06 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-2-1992 "Equipment, Design, and Installation of Ammonia 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 record of safety information that describes th e chemical hazards, operating parameters and equipment designs associated with our 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 and process operations and are revalidated at a regular interval of at least every five years. Any findings related to the hazard analysis are addressed in a timely manner. The most recent PHA/update was performed on 06/16/1998. 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, temporary operations, emergency shutdown, emergency operations, normal shutdown and s tartup after a turnaround. The information is regularly reviewed and is readily accessible to operators involved in the process. Training Zero Mountain, Inc. has a comprehensive training program in place to ensure that employees who are operating the process are competent in the operating procedures associated with our process. Refresher training is provided at least every three years and more frequently 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; compressors, 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 specialized training as needed. Any equipment deficiencies identified by the mai ntenance 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 the process chemical, technology, equipment and procedures. The most recent review/revision of maintenance procedures was performed on 04/23/1999. 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 our process are conducted as a regular practice at Zero Mountain, Inc.. The most recent review was performed on 05/08/1998. These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. 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 12/31/1997. 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 our regulated substance. 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 prevention 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. Contractors On occasion, our company hires contractors to conduct specialized maintenance and 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 processes. Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance 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, only one accidental release has occurred during this period. There has been only one accidental release of our regulated substance from our facility within the last 5 ye ars. This release took place on 02/14/1998 and involved 6000 lb. of Ammonia (anhydrous). No deaths or injuries occured offsite as a result of this accident. Onsite, there were no deaths or injuries. There was some onsite property damage. 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 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 process that would require a modified emergency response. Benton County LEPC is the Local Emergency Planning Committee (LEPC) with which our emergency plan has bee n 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 an Emergency Dump Sation installed and currently at the ready for operation. |