Blue Bird, Inc. - Executive Summary

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A.Accidental Release Prevention and Emergency Response Policies 
 
Blue Bird, Inc. (hereafter referred to as Blue Bird) accidental release prevention policy involves a unified approach that integrates technologies, procedures, and management practices.  It is the policy of Blue Bird to adhere to all applicable federal and state safety and environmental regulations. 
 
Blue Bird's emergency response policy involves the preparation of response plans and training of employees in evacuation and the handling of minor ammonia releases. 
 
At Blue Bird anhydrous ammonia is used on-site. Ammonia is considered hazardous by EPA and is listed on the Extremely Hazardous Substance (EHS) list.  Chemical properties of ammonia make it necessary to observe certain safety precautions in handling ammonia in order to: 
7 Prevent unnecessary human exposure 
7 Reduce the threat to our personnel 
7 Reduce the threat to the community 
 
B. Facility and Regulated Substance Handled 
 
Blue Bird is a fruit processing and col 
d storage facility located in the city of Wenatchee, county of Chelan, state of Washington. 
 
The regulated substance used at Blue Bird is anhydrous ammonia (CAS# 7664-41-7). The use of anhydrous ammonia is as a refrigerant. 
 
There is 11,700 pounds of anhydrous ammonia in the refrigeration system. 
 
Blue Bird uses other hazardous substances on-site, however they are not listed in 40 CFR 68.130.  However, Blue Bird believes in the concept set forth in the "General Duty Clause" of the Clean Air Act.  To this effect, Blue Bird has established policies, procedures and training to reduce the risk of an accidental hazardous substance release for the safety of its employees and surrounding areas. 
 
C.Worst-Case and Alternative Release Scenarios 
 
The off-site consequence analysis considers two ammonia release scenarios identified as "worst case" and "alternative" scenarios.  The worst case scenario is defined by the Environmental Protection Agency (EPA), which states that "the owner or operator s 
hall assume that the maximum quantity in the largest vessel is released ".  The alternative scenario is defined as "more likely to occur than the worst case scenario". 
 
Worst-Case Scenario - Failure of the largest vessel would release 6,900 pounds of anhydrous ammonia.  The release would occur inside the compressor room, which is in direct contact with the outside. 
 
The distance to the toxic endpoint of 0.14 mg/L is 1 mile.  The "risk radius" extends past the boundaries of the plant, into public and environmental receptors. Although the receiver is inside a room with direct contact to the outside, no mitigation was used. 
 
Alternative scenario - The distance to the toxic end-point of 0.14 mg/L is 560 yards.  This is based on a release from the drain at the bottom of the receiver under normal operating conditions. Since this release would occur inside a room with direct wall contact to the outside, building mitigation was used.  A 20% reduction in the amount released was applied. It was 
also assumed that process safeties would limit the amount released to the ammonia in the receiver.  This scenario was chosen because it gave the greatest distance to the toxic end-point of the releases modeled.   
 
The chances of either scenario occurring are unlikely with the automatic safeties on the system.  A more realistic release scenario is a pressure relief valve venting to protect from an overpressure situation.  This would produce a distance to the end-point closer to 155 yards. 
 
D.Accidental Release Prevention Program 
 
Blue Bird's accidental release prevent program is based on the following key elements: 
7 Training of personnel 
7 Preventative maintenance program 
7 Use of safety equipment 
7 Use of accurate and effective written operating procedures 
 
Blue Bird complies with:  
7 OSHA's and Washington State's process safety management rule. 
7 Washington State's safety regulations (WAC's 296-24 and 296-62), which are equal to, or more restrictive than OSHA regulations. 
7 IIAR (I 
nternational Institute of Ammonia Refrigeration) standards for good work practices. 
 
The ammonia refrigeration system was installed to codes and good practices at the time of installation.  Piping is elevated to prevent accidental damage to the system from moving vehicles.  Other safety devices Blue Bird utilizes include: 
7 Computerized controls, which can be operated remotely 
7 Suction trap hi-level float 
7 High discharge pressure shut down 
7 Low suction pressure shut down 
7 High discharge temperature shut down 
7 Oil pressure failure shut down 
7 High amperes shut down 
7 Automatic timer to prevent short cycling 
7 Oil filters plugged shut down 
7 250 psi relief valves on high pressure side, to prevent overpressure situations 
7 150 psi relief valves on low pressure side, to prevent overpressure situations 
                                                                                                                                                                            Operating Pr 
ocedures have been prepared by Blue Bird to be used by employees performing operational functions.  The operating procedures are kept in the engine room and the refrigeration engineer's office.  These procedures include:  
7 Pre-start up procedures 
7 Routine operations 
7 Maintenance 
7 Response to minor releases 
7 Emergency action plan 
 
E.Five-Year Accident History 
 
Blue Bird has not had any accidents involving ammonia in the last five years. 
 
F.Emergency Response Program 
 
In addition to the operating procedures, Blue Bird has established Emergency Response Guidelines for releases involving ammonia.  These procedures are part of the ongoing training. 
 
G.Planned Safety Improvements 
 
Blue Bird plans to install ammonia monitors throughout the areas where the system is located.  The engine room ventilation fan will be connected to an ammonia monitor so that the fan will activate upon reaching a threshold less than 40,000 parts per million, which is < of ammonia's lower explosive limit (LEL)  
of 16%, or 160,000 parts per million.  
 
Blue Bird is also working to improve its employee alarm system to provide a more audible system.
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