AmeriCold Logistics - Executive Summary
ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES |
The AmeriCold Logistics, Inc. Plant 1 facility abides by the emergency response procedures and policies detailed in the Emergency Ammonia Action 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.
SOURCE AND REGULATED SUBSTANCE
The AmeriCold Logistics, Inc. Plant 1 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.
a is used as the refrigerant in the refrigeration process.
The total ammonia inventory is 27,566 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) -8,220 pounds - in 10 minutes. The building was used as a passive mitigation measure. The release rate was calculated as 820 lbs./min. The most pessimistic meteorological conditions were used: 1.5 meters/second wind speed, and F stability. The EPA's Risk Management Program Guidance for Ammonia Refrigeration, Exhibit 4-4 for an urban area, was used to determine the distance to the toxic endpoint of 200 ppm. This release reaches offsite and may affect public receptors. No environmental receptors were affectted by this potential release.
Alternative Release Result Summary
Scenario Description: A 0.25 inch diameter leak of high pressure liquid ammonia (180 psi). The release rate w
as calculated (using a simplified version of the Bernoulli equation) as 134 lbs./min. 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. The EPA's Risk Management Program Guidance for Ammonia Refrigeration, Exhibit 4-5 for an urban area, was used to determine the distance to the toxic endpoint of 200 ppm. This release reaches offsite and may affect public receptors. No environmental receptors were affected by this potential release.
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, "Start
up, 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 1 has implemented a Process Safety Management program for compliance with the Cal-OSHA regulation since April 1994.
FIVE YEAR ACCIDENT HISTORY
There have been no reportable releases of ammonia from Plant 1 within the last five years (June 21, 1994 through June 21, 1999).
EMERGENCY RESPONSE PROGRAM
The AmeriCold Logistics, Inc. Plant 1 has an Emergency Ammonia Action Plan 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.
The facility conducts annual evacuation drills to ensure all employees understand the emergency response procedures.
PLANNED CHANGES TO IMPROVE SAFETY
The RMP Development Team made several proced
ural/managerial recommendations to improve safety at the facility. 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 planned to be completed by December 31, 1999 and are as follows:
R01 Include the P&IDs from the Standard Operating Procedures notebook in the PSI section of the PSM notebook. Separate the P&IDs by plant number.
R02 Include a copy of the ammonia MSDS in the PSI section of the PSM notebook.
R03 Move the Ammonia Inventory Calculation sheets from the back of the PSM notebook to the PSI section.
R04 Complete the Ammonia Inventory Calculation sheet for Plant 3. AmeriCold Logistics would like to note that this recommendation has been completed.
R05 Compile the following data to complete the PSI section of the PSM notebook:
process chemistry (description of refrigeration process)
maximum intended inventory at each plant
safe upper and lower limits
materials of construction
piping and instrumentation diagrams
relief system design and design basis
ventilation system for each engine room
codes and standards employed
R06 Complete the Process Hazard Analysis for Plants 1, 2, and 3 prior to June 21, 1999. AmeriCold Logistics would like to note that this recommendation has been completed as of April 22, 1999.
R07 Review and re-certify the standard operating procedures as soon as possible.
R08Consider labeling the critical valves throughout the facility to match the valve numbers used on the P&IDs in the Standard Operating Procedures.
R09 Install a check valve on the fill lines to prevent backflow from the receiver in the event of a release at the delivery hose.
R10: Include in the PSM notebook a reference to the PSM/ammonia awareness training and certification forms (located in personnel files).
R11: Develop and utilize training certification forms for refrigeration operators. One form for exis
ting operators and one form for initial training of new operators to document on-the-job training. Form 1 is the "Grandfather" form. OSHA allows facilities to certify that the operators who started working at the facility and on the regulated process, prior to May 26,1992, are qualified to carry out their responsibilities outlined in the operating procedures. Form 2 is the Initial Training Form. This form should be signed by the supervisor and operator to certify that the operator understands the operating procedures enough to work independently.
R12:Include a compressor safety switch test in the Preventive Maintenance Record book.
R13: Complete the Preventive Maintenance Record book for Plant 3. AmeriCold Logistics would like to note that this recommendation has been completed.
R14: Document the Pre-Startup Safety Review program and include in the PSM notebook.
R15: Complete the contractor forms for contractors that work on or near the ammonia system, in particular, the ammon
ia delivery contractor. Ensure that the training records for the contract employees are collected.