Major Smith - Executive Summary |
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EXECUTIVE SUMMARY SHOAL CREEK WASTEWATER TREATMENT FACILITY, CITY OF JOPLIN, MO 64804 The Shoal Creek Wastewater Treatment Facility has been treating municipal wastewater for over 50 years while remaining committed to the safety of the community and environment. This treatment process includes the use of Chlorine and Sulfur Dioxide in the disinfection process. This facility takes pride in observing the safety precautions in preventing hazards in the workplace, and possessing structured contingency plans in the unlikely event of a mishap. The City's approach includes (1) the latest technology in monitoring detection systems, and (2) passive mitigation systems designed to diffuse the impact of a release. An offsite consequence analysis has been performed which produced the following worst case scenarios: The rupture of a 2000-pound cylinder containing Chlorine would be limited to 10 minutes in duration, and would release at a rate of 200 pounds per minute. The distance to the endpoint under winds of 3.4 miles per hour would be 2.2 miles. The rupture of a 2000-pound cylinder containing Sulfur Dioxide would be limited to 10 minutes in duration, and would release at a rate of 200 pounds per minute. The distance to the endpoint under winds of 3.4 miles per hour would be 2.1 miles. An offsite consequence analysis has been performed which produced the following alternative release scenarios: The rupture of a 2000-pound cylinder containing Chlorine would be limited to 10 minutes in duration, and would release at a rate of 200 pounds per minute. The distance to the endpoint would be 0.6 miles. The rupture of a 2000-pound cylinder containing Sulfur Dioxide would be limited to 10 minutes in duration, and would release at a rate of 200 pounds per minute. The distance to the endpoint would be 0.6 miles. Our five-year h istory contains no releases whatsoever. Our emergency response program has been designed to produce a maximum effective impact in the least amount of time. The plan includes active public notification using our reverse 911 system, emergency health care utilizing a two-county EMS system, and comprehensive training to assure competency in our toxics handling procedures. With the submission of this RMP, the City of Joplin will increase its training efforts to provide employees the maximum amount of knowledge needed to respond to an emergency. EXECUTIVE SUMMARY Major Smith manufacturers of processed foods at our plant in New Holland. We have a strong commitment to operate our facility in a safe and responsible manner. Ammonia is used at our facility as the cooling medium in our refrigeration systems. Similar to the function Freon plays in a home or car air conditioning system, ammonia is used to cool water and glycol that in turn cools our product in heat exchangers, co olers and silos. The ammonia is contained in a closed loop system; it is designed to remain inside the piping and vessels in our facility. We believe that ammonia provides the safest and most efficient cooling choice for our operation. A. Describe the Accident Release Prevention and Emergency Policies Major Smith takes many precautions to prevent or minimize accidental releases of ammonia from the refrigeration system. These precautions include safety controls (alarms and automatic shutdown devices) which are designed to identify and prevent potentially unsafe conditions like pressure increases that could cause a system failure. We also have a preventive maintenance program designed to maintain the on-going integrity of the systems, a training program designed to ensure that the systems are operated by qualified personnel, and to respond quickly to system upsets. The Facilities Engineer is responsible for the management of these ammonia safety programs. B. Stationary Source a nd Regulated Substances Handled The facility operates a refrigeration system with an ammonia inventory of approximately 13,872 pounds. Ammonia is the only substance covered by the Accidental Release Prevention Regulations handled at the New Holland plant. C. Summary of Worst-Case and Alternative Release Scenarios EPA requires us to define the worst case release scenario from the New Holland plant as the release of all the ammonia from the largest vessel on site. At our New Holland plant, this would be 3750 pounds of ammonia over a 10-minute period due to the failure of the high-pressure receiver. The 3750 pounds represents the maximum amount of ammonia that would be contained in the receiver at any time. EPA also requires us to assume that the weather conditions are such that there is almost no wind and no mixing in the atmosphere. The alternative release scenario at the New Holland plant would involve the release of 2700 pounds of ammonia over a 5-minute period due to the rup ture of a = high-pressure liquid line. The duration of the release was estimated for the alternative release scenario by estimating the amount of time required to stop the leak. Again, EPA required us to estimate the impacts of this release under low wind and stable weather conditions. Both of these releases are unlikely for many reasons. Our equipment and system were designed using industry standards for ammonia refrigeration. We have taken precautions to protect our equipment from obvious threats, like vehicular traffic. We have a preventive maintenance program to maintain the on-going integrity of the refrigeration equipment. Training programs are in place to ensure that qualified personnel operate the systems, and our emergency response procedures allow us to respond quickly in the event of an accident. And lastly, the weather conditions used in estimating the extent of the releases are uncommon. D. Description of the Accidental Release Prevention Program The facility has an accident release prevention program that complies with Occupational Safety and Health Acts Process Safety Management Standard and EPAs Risk Management Program Regulation. The prevention program consists of the following elements: - Employee Participation Program - Process Safety Information - Process Hazard Analysis - Operating Procedures - Training Program - Contractor Safety Program - Pre-Startup Safety Review Procedures - Mechanical Integrity Program - Hot Work Permit Procedures - Management of Change Procedures - Incident Investigation Procedures - Compliance Audit Procedures E. Five-Year Accident History There has been one ammonia-related accident at the New Holland plant in the past five years. F. Description of the Emergency Response Program An emergency response program has been implemented at the New Holland plant. This program contains procedures describing how the facility will respond to ammonia spills and other emergencies, including evacuation procedu res. The plant response team utilizes employees and our refrigeration contractor who are trained to enter and stop an accidental ammonia release. G. Planned Changes to Improve Safety Major Smith is committed to operating our ammonia refrigeration system in a safe and responsible manner. We are continually evaluating our equipment and procedures to meet this objective. Planned improvements include replacement of equipment such as evaporators and ice builders. |