AmeriCold Logistics Plant # 78419 - 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 78119 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 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, Inc. Plant 78119 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 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 61,932 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) - 10,010 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 1.20 miles. Alternative Re lease 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 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 Saf e 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 78119 has implemented a Process Safety Management program for compliance with the OSHA 191.199 regulation since May 30 1997. FIVE YEAR ACCIDENT HISTORY There have been no reported releases of ammonia at this facility over the last five years (May 30, 1997 through June 1, 1999 ). EMERGENCY RESPONSE PROGRAM The AmeriCold Logistics, Inc. Plant 78119 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 continue annual evacuation drills to ensure all employee s 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 28,1997) generated mitigation measures that would improve safety at the AmeriCold Logistics, Inc. Plant 78119 facility located at 121 Roseway Drive in Thomasville, GA.. These action items are as follows: 1. Consider establish PM of changing oil filters 5,000 hours initially and 10,000 thereafter. 2. Consider ensuring that a supervisor is present any time the refrigeration system is to opened by including this requirement in the SOP's. 3. Consider ensuring that the maintenance technicians are trained in the refrigeration system Establish SOP. 4. Consider establishing PM for oil drain of thermoshphon. 5. Consider ensuring that the floats on the intercooler and receivers are included in the PM program. 6. Consider written procedures for draining oil. 7. Consider a spring loaded oil drain valve on each compressor oil separator. 8. Consider ensuring that the maintenance technicians check that the pump run indicator lights coincide with the switch position and include this check on the daily walkthrough checklist. 9. Consider including the pump run indicator lights located on the main refrigeration panel in the PM program. 10. Consider Verifying that there is some way of preventing unauthorized access to the roof and associated equipment. 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: 1. Consider completing safe upper and lower operating limits for the process. 2. Consider completing consequences of deviation for the process. 3. Consider completing PHA action items as soon as possible. 4. Consider adding safety systems and their function to your operating procedures. 5. Consider completing and updating all Standard Operating Procedures. 6. Consider including operating limits and consequences of deviation to all of your Standard Operating Procedures. 7. Consider reviewing all Standard Operating Procedures and certifying annually. 8. Consider obtaining the following safety training documentation from the contractor: a. The identity of the trained contract employee. b. Date of training. c. Means used to verify that employee understood training. |