AmeriCold Logistics Plant # 78403 - Executive Summary
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, Inc. Plant #78403 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 year. This Pla
n 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, Inc. Plant #78403 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 is condensed back into a liqu
id. 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 14,070 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) - 2,883 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 (0.14 mg/L) reached .81 miles
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, Inc. Plant #78403 has implemented a Process Safety Management program for compliance with the OSHA 1910.119 regulation since 5-26-92.
FIVE YEAR ACCIDENT HISTORY
There have been no reported releases of ammonia at this facility over the last five years 6-21-94 through 6-21-99
EMERGENCY RESPONSE PROGRAM
The AmeriCold Logistics, Inc. Plant #78403 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 was recommended that the facility conduct annual evacuation drills to ensure all employees understa
nd 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 (1-5-96) generated mitigation measures that would improve safety at the AmeriCold Logistics, Inc. Plant #78403 facility located at 455 South 75th Avenue in Phoenix, Arizona. These action items are as follows:
R-01 Replace all Relief Valves on a (5) year schedule and document results
R-02 Develop PI&D's
R-03 Develop a valve list from the PI&D's
R-04 Update all Operating Procedures for Process Equipment
R-05 Update Process Safety Management notebook with training records of all Employees and document refresher training annually
R-06 Conduct annual Engine Room safety trip test and document results in Mechanical Int
egrity potion of the Process Safety Management Book
R-07 Emergency Response Guidebook is incomplete, develop and maintain a guidebook in accordance with SARA title III and distribute to the proper agencies i.e.Fire Dept, EPA, Facility Manager, Office Personnel, and throughout the warehouse
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 the Emergency Response Program for preparation of the Risk Management Program and Plan. These recommendations are as follows:
R-08 Update Process Safety Management Book with Mechanical Integrity Process Information Sheets (i.e. compressors, vessels, condensers, evaporators ,etc. )
R-09 No Mechanical Integrity records on file, gather all necessary data and submit all d
ocuments into the Process Safety Management Book
R-10 Emergency Response Guidebook is incomplete, develop and maintain a guidebook in accordance with SARA title III and distribute to the proper agencies (i.e. Fire Department, Facility Manager, Office Personnel, and throughout the warehouse.)
R-11 Train all employees on the Emergency Response Guidebook
R-12 Conduct annual Engineroom safety trip test and document results
R-13 Conduct Compliance audits of the Process Safety Management every (3) years
R-14 Update Process flow diagram to reflect Management of Change
R-15 Update PI & D's to reflect Management of Change
R-16 Update Haz-Op to reflect Management of Change
R-17 Update Standard Operating Procedures to reflect Management of Change
R-18 Update Contractor Safety to reflect Management of Change
R-19 Complete valve tagging on all major piping and valves
R-20 Install additional ammonia sensors near evaporators and conden
R-21 Consider installing sufficient amount of emergency eyewash/shower stations
R-22 Fabricate and stock an Emergency Response Cabinet with all mandated items
R-23 Consider making available additional M.S.D.S. books for employees
R-24 Implement Emergency Response Training (i.e. S.C.B.A., 24 hour technician, etc.)
R-25 Include in maintenance program an annual Engineroom alarm test
R-26 Implement a program to inspect for corrosion in liquid feed lines
R-27 Consider installing covers over engineroom drains and remove only for washdowns
R-28 Consider installing metal plugs in piping and fittings that could drain to atmosphere
R-29 Consider installing one common relief manifold and piping to rooftop near condensers
R-30 Consider re-piping diffuser station to operate correctly or remove system completely