AmeriCold Logistics Plant # 730 - Executive Summary |
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7.0 RISK MANAGEMENT PLAN AND DATA ELEMENTS The following subsections outline the Executive Summary requirements of the EPA's 40 CFR Part 68.155. ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The AmeriCold Logistics, L.L.C. Plant 730 (Murfreesboro) facility abides by the emergency response procedures and policies detailed in the Emergency Response Plan manual. This Plan was designed to meet the following objectives: 1.) To save lives. 2.) To minimize and avoid injuries. 3.) To protect the environment. 4.) To minimize property damage. AmeriCold Logistics maintains an emergency response committee whose members are the designated emergency coordinators for the facility. The Plan provides the response organization and notification procedures, evacuation routes, ammonia health hazards, and mitigation procedures which will be implemented to respond effectively to emergency situations that may arise at the facility. This Plan is reviewed and updated at least once per y ear. This Plan will be reviewed and updated to ensure compliance with the PSM and RMP regulations, as well as to incorporate any facility changes. STATIONARY SOURCE AND REGULATED SUBSTANCE # The AmeriCold Logistics, L.L.C. Plant 730 (Murfreesboro) facility chills and stores a variety of food products in their cold storage warehouse. The refrigeration process, consisting of piping, valves, and equipment, cycles ammonia through various physical states (high pressure liquid, low pressure liquid, low pressure vapor, high pressure vapor, then back to high pressure liquid) in order to provide refrigeration for cold storage rooms. Changes in pressure are directly related to changes in temperature. For example, lowering the ammonia pressure lowers its temperature. Low pressure (cold) liquid ammonia provides refrigeration by removing ambient heat. Removal of ambient heat causes the liquid ammonia (contained within the system) to vaporize. Heat is later removed from the ammonia as it i s condensed back into a liquid. Typical operating conditions range from vacuum (approximately 6" Hg) on the low pressure side of the system to 150-160 psig on the high side. # Ammonia is used as the refrigerant in the refrigeration process. # The total ammonia inventory is 18,830.84 lbs. pounds. HAZARD ASSESSMENT SUMMARY Worst Case Release Result Summary # Scenario Description: Release of the maximum quantity of ammonia that can be stored in a vessel (accounting for administrative controls) - 15,520 lbs. pounds - in 10 minutes. No passive mitigation measures were used. The most pessimistic meteorological conditions were used: 1.5 meters/second wind speed, and F stability. Reference Table 15 from the EPA RMP Off-Site Consequence Analysis Guidance Document was used. See Appendix A. The toxic endpoint was determined using EPA's "RMP -Comp" computer program downloaded from their Website. # Distance to Toxic Endpoint: The one hour, time averaged concentration of 200 ppm (0.1 4 mg/L) reached 2.0 miles miles. Alternative Release Result Summary # Scenario Description: A 0.25 inch diameter leak of high pressure liquid ammonia for one hour. The quantity of ammonia released in one hour at this rate is 6000 pounds. The meteorological conditions used were 3 meters/second wind speed, and D stability. Reference Table 5 from the EPA RMP Off-Site Consequence Analysis Guidance Document was used. See Appendix A. The toxic endpoint was determined using EPA's "RMP -Comp" computer program downloaded from their Website. # Distance to Toxic Endpoint: The one hour, time averaged concentration of 200 ppm (0.14 mg/L) reached .19 miles ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS The facility operates in accordance with the International Institute of Ammonia Refrigeration (IIAR) guidelines and standards including the following: $ IIAR Bulletin 107, "Suggested Safety and Operating Procedures When Making Ammonia Refrigeration Tie-ins" $ IIAR Bulletin 109, "Minimum Safety Criteria for a Safe Ammonia Refrigeration System" $ IIAR Bulletin 110, "Startup, Inspection, and Maintenance of Ammonia Refrigeration Systems" $ IIAR, "A Guide to Good Practices for the Operation of an Ammonia Refrigeration System" In addition, the AmeriCold Logistics, L.L.C. Plant 730 (Murfreesboro) has implemented a Process Safety Management program for compliance with the OSHA 1910.119 regulation since March 15, 1999. FIVE YEAR ACCIDENT HISTORY There have been no reported releases of ammonia at this facility over the last five years (June 21, 1994 through June 21, 1999). EMERGENCY RESPONSE PROGRAM The AmeriCold Logistics, L.L.C. Plant 730 (Murfreesboro) has an Emergency Response Program in place. The facility has an Emergency Response Team that is trained to First Responder Operations Level on an annual basis. All Emergency Response Team members are fit tested and respiratory trained annually. During the RMP Development Review, it w as recommended that the facility conduct annual evacuation drills to ensure all employees understand the emergency response procedures. In addition, it was recommended that the facility contact the local Fire Department regarding participation in the evacuation drills. PLANNED CHANGES TO IMPROVE SAFETY During the development of the Process Safety Management program at this facility, the initial Process Hazard Analysis study (May 12, 1999) generated mitigation measures that would improve safety at the AmeriCold Logistics, L.L.C. Plant 730 (Murfreesboro) facility located at 2641 Stephenson Dr. in Murfreesboro, TN.. These action items are as follows: 1. Consider reviewing the relief valve settings and capacities on all equipment. 2. Consider documenting a concise policy of replacing relief valves after a relief event. 3. Consider monitoring relief valve header for relief events. 4. Consider continued development of PI&D drawings. 5. Consider inspecting system for missing plugs, caps, or blind flanges. 6. Consider labeling key valves. 7. Consider evaluating evaporators and piping exposed to forklifts for adequate guards. 8. Consider updating employee training and awareness of ammonia. 9. Consider reviewing the high pressure cut out settings and high pressure alarm settings to insure they are below 20% of the relief valves settings. 10. Consider installing plastic caps on all relief valve outlets. 11. Consider developing SOP's for starting compressors and training employees on their use. 12. Consider continuing valve marking. 13. Consider completing operating limits and consequences of deviation. 14. Consider changing disconnect label from compressor #1 to #3. 15. Consider continued pipe labeling on the old section of the facility. 16. Consider completing Emergency Response team members. 17. Consider making a spill kit for ammonia. 18. Consider developing SOP's for spills and leaks. 19. Consider posting set points on all compressors. 20. Consider instituting regular inspections to insure relief valve outlet caps are in place. 21. Consider installing visual indicators on relief valves not piped into a relief header. 22. Consider developing procedure for pumping out condensers. 23. Consider adding, "inspect condenser supports" annually to PM requirements. 24. Consider replacing wooden condenser supports on old condenser. 25. Consider periodically checking condenser water with litmus paper for ammonia. 26. Consider adding weekly check of system non-condensibles to condenser check list. 27. Consider adding, "inspect piping for corrosion" to PM Requirements. 28. Consider developing a written pumpout procedure for all vessels. 29. Consider documenting a pump out procedure for isolating ammonia pumps. 30. Consider developing a pump out procedure for pumping out sight glass columns. 31. Consider inspecting all sight glass column for adequate guards. 32. Consider adding an oil pot to your -30 vessel. 33. Consider developing a SOP for starting and stopping pumps. 34. Consider writing a procedure for pumping out evaporators. 35. Consider verifying proper valve tagging. 36. Consider verifying all evaporators hanging rods are double nutted. 37. Consider inspecting piping that penetrates the walls. 38. Consider verifying all piping is adequately supported 39. Consider when writing PM Requirements for inspecting piping supports to verify proper return line slope. 40. Consider evaluating the need for annual maintenance on key isolation valves. 41. Consider developing valve maintenance procedure. 42. Consider providing refresher training for keeping valves clear of ice. 43. Consider adding support to and deicing the suction lines between room #2 and #3. 44. Consider evaluating all piping for excess ice. 45. Consider conducting a mock ammonia spill. 46. Consider providing air horns for employee notification during power outage. 47. Consider conducting an emergency evacuation. 48. Consider updating assigned responsibilities for your Emergency Ac tion Plan. 49. Consider purchasing a 150 lb. fire extinguisher. 50. Consider evaluating the need to install ballards outside the machine room. 51. Consider putting check valve on oil pump discharge. 52. Consider writing a procedure for adding/draining oil on a compressor. 53. Consider completing all Standard Operating Procedures. 54. Consider developing a procedure for changing relief valves. 55. Consider updating training on red rag and lock out/tag out procedures. 56. Consider updating all employees training. 57. Consider updating all training records 58. Consider some type of back flow preventer at charge connection on HP receiver. 59. Consider including system gauges and safeties in PM requirements. In addition to the equipment related mitigation measures recommended to improve safety at this facility, the RMP Development Team made several procedural/managerial recommendations to improve safety. These recommendations are a result of the review of the PSM prevention programs and t he Emergency Response Program for preparation of the Risk Management Program and Plan. These recommendations are as follows: 1. Consider developing a block flow diagram of your system. 2. Consider developing safe upper and lower operating limits for the process. 3. Consider developing consequences of deviation for the process. 4. Consider including the following information about the process equipment in the Process Safety Information section of your PSM manual: Materials of construction PI&D Drawings Electrical Classification Relief system design and design basis Ventilation system Design codes and standards employed Material and Energy Balances Safety Systems 5. Consider completing all Standard Operating Procedures. 6. Consider including operating limits and consequences of deviation to your SOP's. 7. Consider including safety and health considerations to your SOP's. 8. Consider developing a Standard Operating Procedure book for employees to use. 9. Consider completing PHA actio n items as soon as possible. 10. Consider adding safety systems and their function to your operating procedure. 11. Consider reviewing all Standard Operating Procedures annually. 12. Consider maintaining an injury and illness log on contract employees. 13. Consider assuring that contract employees are trained to safely perform their jobs as they relate to the safety and health hazards on site. 14. Consider providing refresher training on lock out/tag out and confined space entry. 15. Consider updating all training records for all employees working with the system. 16. Consider providing operating procedure training to all employees. 17. Consider obtaining information about your contractors safety performance. 18. Consider obtaining the following safety training documentation from the contractor: a. The identity of the trained contract employee. b. Date of training. a. Means used to verify that employee understood training. 19. Consider conducting an annual Emergency Evacuation drill. 20. Consider inviting your local fire department to participate in your evacuation drill. 21. Consider providing training on maintaining the integrity of the process. |