MIA Products - Executive Summary |
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EXECUTIVE SUMMARY A. MIA Products accidental release prevention policy involves a unified approach that integrates technologies, procedures, and emergency management practices. All applicable procedures of the U.S. Environmental Protection Agency (EPA) prevention Program are adhered to. MIA Products emergency response policy involves the preparation of a response plan and the emergency response services available in the community. MIA Products is in compliance with all OSHA and EPA Emergency Response Program requirements. B. MIA Products, is a producer of novelty ice products. On site we have 15,500 lbs. of ammonia. MIA Products uses anhydrous ammonia as a refrigerant to cool product and chill liquids. The plant is normally manned around the clock during production hours. Holidays and weekends the plant is monitored by alarm systems. C. The offsite consequence analysis includes consideration of two anhydrous ammonia release scenarios, identified as "worst case release" and "al ternative scenario". The first scenario is defined by EPA, which states that "the owner or operator shall assume that the maximum quantity in the largest vessel is released as a gas over 10 minutes, due to an unspecified failure. The alternative scenario is defined as "more likely to occur than the worst-case release scenario". Atmospheric dispersion modeling has to be performed to determine the distance traveled by the anhydrous ammonia release before its concentration decreases to the toxic endpoint selected by EPA of 3 PPM, which is the Emergency Respouse Planning Guideline Level 3 (ERPG-3). The American Industrial Hygiene Association (AIHA) defines this as the maximum airborne concentration below which it is believed that all individuals could be exposed irreversible or other serious health effects or systems, which could impair an individual's ability to take protective action. The residential population within a circle with a radius corresponding to the toxic endpoint distan ce has to be defined; "to estimate the population potentially affected". The worst case release scenario at the MIA Products involves a failure of the receiver, which is connected, to 15,500-lbs. system. The offsite consequence analysis for the scenario was performed for two sets of conditions. The first set followed conditions pre-defined by the EPA, namely release of the entire amount as a gas in 10 minutes, use of the one-hour average ERPG-3 as the toxic endpoint, and consideration of the population residing within a full circle with radius corresponding to the toxic endpoint distance. EPA set these conditions to facilitate the performance of the offsite consequence analysis EPA-mandated meteorological conditions, namely Stability F, wind speed of 1.5 m/sec, highest daily maximum temperature (116 degrees F.), and average humidity (65%) were used for both sets. When atmospheric dispersion modeling for the worst case scenario was performed using the EPA assumptions, a distance t o toxic endpoint of .8 miles and an estimate of residential population potential affected 2550. The alternate release scenario involves the rupture of a Pipe. The amount of release anhydrous ammonia released is 24 lbs./min. at an average rate over one hour (the duration of the release) of 44 lb./min. Toxic endpoint distances to ERPG-2 and -3 levels were obtained. The latter is defined by AIHA as "the maximum airborne concentration below which it is believed that all individuals could be exposed for up to one hour without experience or developing life threading health effects". The typical meteorological conditions used were Stability E, wind speed 3.0m/s, average air temperature of 62 degree F., and 63% average humidity. The estimated distance traveled to the toxic endpoint is .43 ft. The estimated of residential population affected is 1520. D. The general MIA Products accident release prevention program is based on the following key elements: 7 High level of training of the operators. 7 Preventive maintenance program 7 Use of the state-of-the-art process and safety equipment 7 Use of accurate and effective operating procedures, written with the participation of the operators 7 Performance of a hazard of a review of equipment and procedures 7 Implementation of an auditing and inspection program. Prevention steps include availability of self-contained breathing apparatus (SCBA), worn by the maintenance mechanic's during connection/disconnection of anhydrous ammonia, awareness of the hazardous and toxic properties of anhydrous ammonia, and the presence of ammonia detectors. E. No accidental release of anhydrous ammonia has occurred at this facility in the past five years. F. The plant has an emergency response program, which has been coordinated by the Greenwood and Moosic Fire Department, and DATOM which are all members of the Local Emergency Response Planing Committee (LEPC). This program includes an emergency response decision tree and a notificatio n plan. Emergency response drills and drills evaluations are conducted every six months: emergency operation and response procedures are also reviewed at that time. |