AmeriCold Logistics Plant # 80543 - 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, Inc. Plant 80543 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 P lan 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 80543 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 liq uid. 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 11,040 pounds. HAZARD ASSESSMENT SUMMARY Worst Case Release Result Summary # Scenario Description: Release of the maximum quantity of ammonia that can be stored in the two high pressure receivers - 4,264 pounds - in 10 minutes. No passive mitigation measures were used. The most pessimistic meteorological conditions were used: 1.5 m/s and F stability. # Distance to Toxic Endpoint, SLAB model: The one hour, time averaged concentration of 200 ppm (0.14 mg/L) reached 969 meters or 0.60 miles. # Distance to Toxic Endpoint, Look-up Table: The one hour, time averaged concentration of 200 ppm (0.14 mg/L) reached 4,345 meters or 2.7 miles. Alternative Release Result Summary # Scenario Description: A 0.25 inch diameter leak of high pressur e 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 m/s and D stability. The SLAB dispersion model was used. # Distance to Toxic Endpoint: The one hour, time averaged concentration of 200 ppm (0.14 mg/L) reached 547 meters or 0.34 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: o IIAR Bulletin 107, "Suggested Safety and Operating Procedures When Making Ammonia Refrigeration Tie-ins" o IIAR Bulletin 109, "Minimum Safety Criteria for a Safe Ammonia Refrigeration System" o IIAR Bulletin 110, "Startup, Inspection, and Maintenance of Ammonia Refrigeration Systems" o IIAR, "A Guide to Good Practices for the Operation of an Ammonia Refrigeration System" In addition, the AmeriCold Logistics, Inc. Plant 80543 has implemented a Process Safety Management program for compliance with the OSHA 1910.119 regulation since April 1994. FIVE YEAR ACCIDENT HISTORY There have been no reported releases of ammonia at this facility over the last five years (August 1993 through August 1998). EMERGENCY RESPONSE PROGRAM The AmeriCold Logistics, Inc. Plant 80543 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 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 p rogram at this facility, the initial Process Hazard Analysis study (April 1994) reveled mitigation measures to improve safety at the AmeriCold Logistics, Inc. Plant 80543 facility located at 720 W. Juniper Street, Connell, Washington. These two measures are listed below: 1. Implement pressure relief valve maintenance program that requires all pressure relief valves to be recertified or replaced every five years. 2. Repair and upgrade the ammonia detection system so that notification of a release is provided to the key operators. 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: R01: Ensure that the PHA study is reviewed and re validated by April 1999. The result of the revalidation must be documented and included with the initial PHA study. R02: Formalize procedure to replace/recertify all relief valves every five years or any time a valve unseats by June 1. 1999. R03: Consider replacing the existing ammonia detection/monitoring system. R04: Ensure that all operators to review the PSM notebook at least once a year and to sign the certification. Include this policy in the Operating Procedure document. R05: Develop and maintain a training summary page for each employee/operator (associated with the ammonia system) with the PSM documentation. R06: Document on-the-job training by having supervisor and operator sign certification that operator understands procedures enough to work independently. R07: Ensure that the PSM programs are covered in the plant wide monthly safety meeting. R08: Conduct an annual emergency evacuation drill with local Fire Department. R09: Replace the "sample" Daily Log Shee t in PSM notebook with "actual" Daily Log Sheet used at the facility. R10: Cross-reference the system Integrity Checks in the equipment log books with the PSM Mechanical Integrity program and update the PSM Mechanical Integrity program to reflect the actual PM schedule in place at the facility per each equipment. R11: Include the plant wide monthly safety meeting in the PSM Employee Participation program. See Recommendation R06. R12: Ensure that all contractors that work on or near the ammonia refrigeration system have received a contractor safety package as outlined in the program documentation and that they have supplied AmeriCold Logistics, Inc. Plant 80543 with the applicable training and safety (injury and illness) information. R13: Consider having contractors that work at the facility but not on or near the ammonia refrigeration system complete a modified Employee Awareness Training Certification form included in the Training section of the PSM notebook. (This form would ha ve to be modified slightly to reflect the use for contractors.) R14: Include information on emergency health care (first aid) for ammonia and medical/hospital location. R15: Date each document and include revision numbers and corresponding dates. |