Bar-S Foods - Altus, OK Facility - Executive Summary |
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RMP Executive Summary 1.0 Accidental release prevention and emergency response policies at Bar-S Foods Co. - Altus, OK ('68.155(a) ). Bar-S Foods Co. prevents accidental releases through training of refrigeration / maintenance personnel, ongoing inspection and maintenance of the refrigeration system, and following an established PSM program. Refrigeration system components are located in areas that are not as likely to become damaged (i.e., tanks and pipe runs are placed away and protected from forklift and truck traffic). 2.0 Source and regulated substances handled ('68.155(b)). Approximately 30,000 lbs. of anhydrous ammonia is contained within the refrigeration system on site at Bar-S Foods Altus, OK. The EPA requires a Risk Management Plan be developed and maintained when the total amount of anhydrous ammonia exceeds the threshold quantity of 10,000 lbs. No other substances, in quantities subject to EPA RMP certification requirements, are located at the Bar-S Foods Altus, OK facility. 3.0 Worst Case and Alternate Case Release Scenarios ('68.155(c)). 3.1 Worst Case Scenario (WCS) The low temperature recirculator, located inside the Engine Room, contains the largest quantity of anhydrous ammonia, on site, on a predictable worst case basis. This vessel is typically maintained at less than 40% full and is equipped with a high level alarm and cutout at 60% level (maximium level). This tank holds approximately 8,700 lbs. of anhydrous ammonia when 60% full, under an internal pressure and temperature of approximately 9 psig and -10 0F. The Worst Case Scenario as required by EPA, assumes that the tank's contents are fully released as a gas/vapor over a 10-minute period. The EPA Ammonia Offsite Consequence Analysis (OCA) Endpoint Tables predicted, with a wind speed of 1.5 m/s and atmospheric stability class F, the anhydrous ammonia release may travel 1.7 miles from the point of release (Rural Topography). Approximately 4500 people, as determined by Land view Census data, in the surrounding community, reside within the radius to the toxic endpoint (level of concern = 200 ppm, anhydrous ammonia). A number of schools, recreation areas, and a hospital fall within the radius to the toxic endpoint. Altus Air Force Base also resides within the radius to the toxic endpoint. There are no environmental receptors, as reportable by EPA RMP criteria, within the radius to the toxic endpoint. 3.2 Alternate Case Scenario (ACS) The Alternate Case, more likely, Release Scenario for Bar-S Foods Altus, OK facility was selected to involve a relief valve release on a condenser. The relief valve discharges on top of the Engine Room roof. Anhydrous ammonia (at approximately 250 psi and 113 0F) was estimated to have a flow rate from the relief valve (inner orifice diameter: 0.75 inches) of approximately 92 lbs./min., determined from an ammonia gas release table. It is estimated that the relief valve could be isolated, or the overpressure condition c orrected, in approximately 10 minutes by trained operators onsite, with a corresponding anhydrous ammonia quantity released of approximately 920 lbs. The EPA OCA Endpoint Tables predicted, with a wind speed of 3 m/s and atmospheric stability class D, that the anhydrous ammonia release may travel approximately 0.2 miles. There are no residences, based on a site visist, within the release radius (level of concern = 200 ppm, anhydrous ammonia) of the facility. There are no other public or environmental receptors within the radius to the toxic endpoint. 4.0 Accidental release prevention program ('68.155(d)). Bar-S Foods Altus, OK facility standard policy requires daily monitoring and inspection of the anhydrous ammonia refrigeration system by trained employees, or contracted services personnel. The facility has implemented an OSHA PSM program which is equivalent to the EPA RMP Program 3 Prevention Program. Other accidental release prevention practices at Bar-S Foods Co. include: 7 Annual operator refresher training. 7 Routine preventative maintenance and inspections. 7 Refrigeration system repairs made in a prompt, safe manner. 7 Labeling of ammonia system pipes and components. 7 Safe work practices followed. 5.0 5 year accidental history ('68.155(e)). No releases or accidents, involving anhydrous ammonia, that are reportable in accordance with 40 CFR Part 68 (RMP Rule), have occurred at this facility. 6.0 Emergency response program ('68.155(f)). During normal workday operation, the facility emergency response plan consists of employee notification (alarm system) and evacuation, followed by notification of the Altus Fire Department Station #1 by dialing "9-1-1". A facility emergency response plan and evacuation plan has been prepared and disseminated to facility personnel. Selected personnel receive annual HAZWOPER training. 7.0 Planned changes to improve safety ('68.155(g)). Future plans to improve anhydrous ammonia refrigeration system safety consis t of continuing annual operator and HAZWOPER training, addressing the PSM audit and Emergency Response Plan audit findings, and fully implementing all PSM Program elements. |