Murry's Inc. - Executive Summary |
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EPA RMP Required Executive Summary Introduction: Murry's Incorporated of Lebanon, Pennsylvania is a frozen food product manufacturer located at 1501 Willow Street on the northwestern fringe of the city, and has been located on this site since 1970. It provides employment to more than two hundred people from the surrounding area. In the process of manufacturing extensive use of refrigeration systems are employed for the purpose of freezing and storage of the products produced. One of the systems that provide this service makes use of the chemical compound Anhydrous Ammonia as the refrigerant. Anhydrous Ammonia is classified an extremely hazardous substance by the United States Department of Environmental Protection Agency (EPA). EPA has determined that any facility having a quantity of Anhydrous Ammonia in excess of their determined threshold level of ten thousand pounds in storage or used in a process system must have a Risk Management Plan and Program (RMP) in place, and on file wi th them. The RMP being a device to assure the community there are prudent measures in place at facilities using or storing these substances that will minimize environmental impact upon that community. Murry's has a nominal fourteen thousand pounds of Anhydrous Ammonia in use on this particular system. Anhydrous Ammonia is a liquid and in this system weighs in at a nominal five pounds per gallon. Murry's has twenty eight hundred gallons in use throughout this system, and the largest quantity in any one location during operation is a nominal six hundred and forty gallons. A characteristic of Anhydrous Ammonia that is of concern to Murry's and its impact upon the community is the change from liquid to vapor when it is exposed to the atmosphere. This transition is only possible should there be a loss of integrity (leak or release) in our closed loop system. This is also EPA's concern and the driving force of their RMP and the application thereof to any facility that has the extremely h azardous substance Anhydrous Ammonia as a refrigerant in excess of threshold limits being used in their processes. Murry's implementation of the RMP standards is not a difficult task as we operate under and have been reviewed by OSHA for compliance with their Process Safety Management Plan (PSM), developed in the past for this site. This is also a program dictated by the same quantity stored or used in process threshold levels of extremely hazardous substances. All of the release prevention methods that are in place to protect the employee and satisfy the PSM standard bring us to compliance with the applicable portions of RMP. Enclosed with this submittal is copy of our Process Hazard Analysis and summary of the PSM Plan which is the nucleus of our Risk Management Program. It addresses release prevention, emergency action protocol, operating protocol, and overall prudent handling of Anhydrous Ammonia as a refrigerant. In order to meet these onsite standards it is obvious that should an event transpire the impact on the community is minimized as humanly possible. In conjunction with these programs there is an emergency response plan in place that has been developed over the years by the Local Emergency Planning Committee (LEPC) and the Lebanon County Emergency Management Agency (LCEMA) should there ever be an event of a magnitude requiring that type of action. This plan is also a mandate of the state of Pennsylvania and the Pennsylvania Emergency Management Agency (PEMA). This mandate assures the resources of that agency should an event of catastrophic proportion occur. The plan is reviewed, and exercises are conducted to assure proper response with modifications made if necessary. This plan has determined the worst case, and more than likely impact upon the community should a catastrophic system failure occur. The plan exceeds the area impacted as calculated when using EPA's provided computer program and will not be modified because of the insurance fa ctor it now provides. It is available for all to see by contacting the LCEMA office at (717) 272-7621 and making an appointment. In the past five years there has been only one reportable release from this site involving this system and it occurred on 11/02/94 at 1:30 AM. The event was triggered by a truck trailer striking an outside structure that had a refrigeration line attached which carries Anhydrous Ammonia in a gas form under pressure. The total release was calculated at two hundred pounds, and was a gas release to atmosphere. All appropriate agencies were notified, but the insignificant quantity required no response. The closing off of the release and repairs were made by Murry's personnel. The release was not detectable offsite and had no impact upon the community. Property damage was confined to the structure from the vehicle with none derived from the release on or offsite. To prevent a repeat of this incident additional protective barriers were installed. Murry's con tinues the process of improvement in the protection of our employees by use of a Safety Committee for periodic audits and vigilance by those entrusted with the care and maintenance of this system. That translates to offsite assurance that we are doing everything possible to eliminate or minimize any impact to the community should an event occur. 2 2 |