AmeriCold Logistics Plant # 80511 - 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 80511 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 80511 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 18,791 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) - 2,244 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 0.62 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 0.19 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 80511 has implemented a Process Safety Management program for compliance with the OSHA 1910.119 regulation since 1-1-94. 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 80511 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 unders tand 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 (1-1-94) generated mitigation measures that would improve safety at the AmeriCold Logistics, Inc. Plant 80511 facility located at 10 West Magnolia Blvd. in Burbank, California. These action items are as follows: R-01 Consider installing a sensor and a solenoid actuated King valve R-02 Consider removing the intercooler and excess piping R-03 Reinstall the high level shut off switch on the low pressure receiver that will shut off the compressors R-04 Examine different methods for determining if a relief valve has failed or relieved (i.e. installing a rupture disk with an alarm in the relief valve piping) R-05 Interlock the King valve and compressor shut down with a remotely located shut off switch R-06 Consider installing ammonia sensors throughout the storage rooms R-08 Install eyewash/shower stations in the engine room and on the roof R-09 Implement response procedures to absorb ammonia with carbon dioxide when the release is inside a storage room. Also ensure that the operators are properly trained to use the carbon dioxide R-10 Implement drills that require the operators to suit up with the SCBA's R-11 Check equalizing lines and correct P&Ids on condensers 1,2,3,4 R-12 Consider installing a sensor on the roof near the condenser that is interlocked with the King valve and a alarm. The operator can remotely shut off the compressors and stop the flow to condensers R-13 Consider installing a sensor by the Low pressure receiver R-14 Consider installing a sensor by compressors 1 and 2 R-15 Clarify P&ID and edit dra wing of Surge Drum R-16 Install a check valve in the fill line to prevent back flow in the event of a hose failure 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-07 Fabricate and stock a Emergency Response Cabinet with all mandated items |