SSI Food Service Inc. - Executive Summary |
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SSI Foods Service Inc. is committed to protect the health and safety for all on site personnel, visitors, the environment, and local community. To ensure the safe operation of our process, SSI has complied witrh OSHA's Process Safety Management (PSM) Title 29 Code of Federal Regulation(CFR) 1910.119, EPA's Risk Management Program regulations (RMP) Title 40 CFR Part 68, and ANSI/IIAR 2-1992 Standard for Equipment, Design, and Installation of Ammonia Mechanical Refrigeration Systems. To deal with the risks involved with ammonea refrigeration, programs have been developed to prevent the occurence of a release and or minimize the consequences of a significant release of anhydrous ammonia, fires, explosions, and other types of catastrophic accidents. Programs developed for the PSM/RM plan include employee participation, process safety information, process hazard analysis, pre-startup safety review, standard operating procedures, training, management of change, mechanical integrity, hot w ork permit, contractor qualifications, and incident investigation. To help coordinate the plan, a management program has been established as well as an internal audit program which will help identity compliance status and possible deficiencies in the program. In the event of a toxic release , an emergency responce plan coordinated with the locan emergency planning commission (LEPC), rural fiire department and trained company personnel has been written. Annuall drills are held to ensure that all emergency responding agencies are familure with the plan and their responsibilities. The ultimate goal for SSI's PSM/RM plan is to prevent accidental fatalities, injuries, illness and avoid physical damage to the environment. These programs enable our facility to operate a refrigeration system safely because they focus on the rules, procedures, and guidelines which govern the industry. SSI Foods Service Inc. processes fresh meat products and uses a refrigeration system for freeze tunnels, storage and plant cooling. The maximum inventory of ammonia onsite is 60,000 (lbs). RM regulations require hazard assessments, including offsite consequence analysis. EPA categorizes release scenarios as worst case (WCS) or alternate case (ACS). To evaluate potential WCS's and ACS's for toxic chemicals, the distance to endpoint is determined. The toxic endpoint for ammonia is 0.14 mg/L (200 ppm). Following EPA guidance the largest vessel/release rate was used to estimate the WCS. All of the major ammonia vessels are located indoors and many would have significant passive mitigation factors. The highest 10-minute release rate was determined to be from the high perssure receiver which contains 12,000 (lbs) of ammonia liquefied under pressure. While the high pressure receiver is located inside a building, it is also adjacent to a door; therefore, the building mitigation calculations in EPA's Risk Management Program Guidance for Ammonia Refrigeration were not used. Instead the m ore conservative and more suitable passive mitigation factor provided in RMP*Comp was used to calculate the mitigated release rate. The WCS release quantity is 12,000 (lbs) at a rate of 660 (lbs/min) for a distance endpoint of 1.5 miles before dispersing enoughto no longer pose a hazard to the public. The following public and environmental receptor locations are within the WCS toxic endpoint radius: Wilder Head Start School, Holmes Elementary School, Wilder Junior, Senior High School, Industrial and Commercial establishments (including commercial agriculture), with a estimated population of 1,426, and Hwy 95. This scenario is unlikely to happen for the following reasons; worst case weather conditions are uncommon; the vessel is located in a building that would help control the release; industry standards for the manufacture and quality control of process vessels; ammonia is not corrosive; the accident prevention program including mechanical integrity, inspection and testing for e quipment, and replacement of equipment if necessary; installed ammonia area sensors to warn operating personnel of process upsets; and the emergency response plan and equipment in place at the facility. To select a plausible ACS, SSI considered three scenarios, the one selected for the RMP Submit was the recharging of the ammonia system. A break or rupture of the 1-inch recharging hose that occures during the system recharge, resulting in a vapor phase release. Recharging is performed by loading vapor phase ammonia from pony tanks. The pony tanks are placed just outside of the south entrance door to the machine room while recharging. The release is assumed to happen under worst case summer conditions (190 psig and 105 degrees fahrenheit). The temperature in the tank will drop due to the ammonia evaporation (latent heat) ; however, to be conservative this effect has not been considered. It is assumed that this release can be controlled within 10 minutes. The vapor release rate c alculated is 127 (lbs/min) for 10 minutes for a quantity of 1,270 (lbbs) at a distance of 0.3 miles to toxic endpoint. The following public and envirnmental receptor locations are within the ACS endpoint radous: Four (4) residences, with a total estimated population of 12, Commercial Agriculture and Hwy 95. This scenario is unlikely for the following reasons; the accident prevention program inplace at the facitity including operationg procedures to have personnel present at all times during the transfer process; the mechanical integrity program for regular maintenance, inspection and testing, and replacement of equipment if necessary; and the emergency response plan and equipment in place at the facility. The accidental release prevention program in general starts with good operating and manufacturing practices. All ammonia process equipment, piping and valves are inspected on a regular schedual depending on manufacture and industry recommendations, for example; all compress ors are inspected on a monthly basis for oil leaks, pressure and temperature guage calibrations, vibration analysis, oil pressure, and amp reading for motors; alignment of compressor motor and compressor, filter change, vibrating readings and sensor calibrations are performed every 6 months; the condensor 24 point air purger system is inspected weekly, this includes checking and cleaning nozzles and strainers, motors are greased, fans are checked for cracks, and piping is inspected for leaks; low and intermediate pressure reciever oil pots are drained, pump pressure is recorded and pumps and valves are defrosted for excessive ice build up weekly; visual inspection for equipment and vessel operating limit conditions, piping and valves are assessed for leaks, integrity, material deformity daily; pressure relief valves are replaced on a five year preventative maintenance schedual or when one has been activated. Area ammonia sensors are installed in the compressor room as well as a seperate detection system strategicly located throughout the facility. The facility's emergency response plan is based on OSHA requirements for Emergency Action Plan (29 CFR 1910.38 and 1910.119) and Hazwoper (29 CFR 1910.120). Onsite personnel have been trained and are quilified to respond aggressively to isolate and control a release. Equipment such as self contained breathing apparatus, respirators, serivex body suits, encapsolated level A suits, gloves, boots and personal monitors are available for the emergency response team (ERT). During the past five years there have been two releases. On August 31, 1996 a strainer valve was opened instead of a service valve. The strainer valve had not been plugged from a previous service resulting in a release. There were no injuries on or offsite the facility. Evacuations included only facility personnel and the approximate release quantity was less that 200 (lbs) ammonia. The second release occured on April 5, 1999 when a valve was opened on a existing pipe that had not been capped. Evacuations included only facility personnel and the approximate release quantity was 192 (lbs) ammonia. The local rural fire department was dispached but were cancelled enroute prior to arrival. There were no offsite injuries but one contract security personnel on site reported some respiratory discomfort and requested a medical observation. The security employeel was seen by a local physician and released. On both inccidents, the National Response Center was notified and incident investigations were conducted. On the 1999 incident a report was sent to the Local Emergency Planning Commission (LEPC) and State Emergency Response Commission (SERC). Corrective actions included retraining process operators, valves tagged and locked out, and a plan to remove and cap the existing line from the system. Continued improvements for the ammonia refrigeration process is a top priority for SSI Foods Service Inc. The management plan a s well as our prevention programs will be monitored and updated as neccessary to ensure that all elements for the PSM/RM plan is complete. |