Columbia Colstor-Woodland - Executive Summary |
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This is to inform all interested persons, including employees that Columbia Colstor, Inc. is complying with OSHA's Process Safety Management Standard (called Process Safety Management or PSM), Title 29 Code of Federal Regulations (CFR) 1910.119, and EPA's Risk Management Program regulations (called RM Program), Title 40 CFR Part 68, to deal with the risks involved with the storage, handling, and processing of hazardous chemicals. In this way we promote overall plant, worker, and public safety. These programs enable our facility to prevent the occurrence, and minimize the consequences, of significant releases of toxic substances as well as fires, explosions, and other types of catastrophic accidents. Overall, these programs prevent accidental fatalities, injuries, and illnesses and avoid physical property damage. Our safety programs are applied to any activity involving hazardous chemicals including any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or combination of these activities. Any group of vessels, which are interconnected and separate vessels, which are located, such that a hazardous chemical could be involved in a potential release shall be considered a single process. Our safety programs prevent accidents because they focus on the rules, procedures, and practices, which govern individual processes, activities, or pieces of equipment. These rules are detailed and improved as necessary. They are also communicated to and accepted by all employees at the facility. Columbia Colstor-Woodland maintains approximately 26,200 lbs. of ammonia in a refrigeration process. Most storage is on the south side of the building near the center. It is used for cold storage of food products. The general facility function is cold storage warehousing. The worst case scenario would be failure of the high pressure receiver containing 17,154 lbs. of anhydrous ammonia with the receiver quantity limited to 85% of the vessel capacity by facil ity procedures resulting in a ten minute release. Under worst [case weather conditions, ammonia could travel .6 miles before dispersing enough to no longer pose a hazard to the public. This scenario is unlikely for the following reasons: worst-case weather conditions are uncommon; the vessel is enclosed in a building that would withstand and help to contain such a release; industry standard for the manufacture and quality control of pressure vessels; ammonia is not corrosive in this service; pressure safety valves limit operating pressure in this vessel; the accident prevention program in place at the facility including the mechanical integrity program for regular maintenance, inspection and testing, and replacement of equipment, if necessary; installed ammonia sensors in the system in place to warn operating personnel of process upsets; and the emergency response plan and equipment in place at the facility. The alternative release scenario would be the failure of a relief valve. T his would result in the loss of 594 lbs. of ammonia over a time period of ten minutes. Under common weather conditions, ammonia could travel .1 miles before dispersing enough to no longer pose a hazard to the public. Failure of a relief valve was chosen because it is one of the most common occurrences listed in the plan. This scenario is unlikely for the following reasons; the facility accident prevention program in place at the facility including operating procedures; proper valve sizing; mechanical integrity program at the facility and the emergency response plan and equipment in place at the facility. Columbia Colstor, Inc. complies with the OSHA PSM standard 29 CFR 1910.119, EPA RM program regulations in 40 CFR Part 68, ANS/;IIAR 2-1992 Standard for Equipment, Design, and Installation of Ammonia Mechanical Refrigerating Systems. There were no accidental releases of ammonia in the past five years. There were no onsite or offsite injuries due to ammonia releases. This facility's emergency response program is based on the OSHA requirements for Emergency Action Plans (29 CFR 1910.38 and 1910.119) and HAZWOPER (29 CFR 1910.120). We have trained employees for emergency response and maintain a written emergency response plan. This plan will be coordinated with the Local Emergency Planning Committee (LEPC) and the local fire department. We will conduct annual drills for implementation of the emergency response plan at the facility with the participation of the LEPC and the fire department. Columbia Colstor, Inc. plans to have an in house training program developed in the next year. We are also rewriting our emergency response plans to follow the one plan approach. |