AmeriCold Logistics Plant # 75102 - 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, L.L.C. Plant 75102 (Lakewood) 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 yea r. 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, L.L.C. Plant 75102 (Lakewood) 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 co ndensed 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 11,231.05 lbs. 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) - 4,622 lbs. 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 1.2 miles 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 .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, L.L.C. Plant 75102 (Lakewood) has implemented a Process Safety Management program for compliance with the OSHA 1910.119 regulation since September 9, 1994. FIVE YEAR ACCIDENT HISTORY There have been no reported releases of ammonia at this facility over the last five years (June 21, 1994 through June 21, 1999). EMERGENCY RESPONSE PROGRAM The AmeriCold Logistics, L.L.C. Plant 75102 (Lakewood) 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 rec ommended 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 program at this facility, the initial Process Hazard Analysis study (March 13, 1998) generated mitigation measures that would improve safety at the AmeriCold Logistics, L.L.C. Plant 75102 (Lakewood) facility located at 3300 Lakewood Ave. in Atlanta, GA.. These action items are as follows: 1. Consider developing a relief valve replacement schedule that includes relief valve size and pressure settings. 2. Consider reviewing the high pressure cut out settings and alarms are below 20% of the relief valve setting. 3. Consider monitoring relief valve header for relief events. 4. Consider evaluating the need for high level shutdown on high temp recirculator. 5. Consider completing pipe labeling. 6. Consider continued development of PI&D drawings. 7. Consider labeling key valves. 8. Consider evaluating evaporators and piping exposed to forklifts for adequate guards. 9. Consider instituting regular inspection of ammonia detection system. 10. Consider evaluating the ability of the ammonia detection system activating the ventilation system. 11. Consider putting a check valve on compressor filling oil pump discharge. 12. Consider adding annual pipe support inspection to your PM Program. 13. Consider evaluating the need to install a high level cut out on the high temp recirculator. 14. Consider reviewing the relief valve vent lines to see if improvements can be made to keep moisture from accumulating in piping. 15. Consider evaluating the need for a high temperature cut out on the reciprocating compressor. 16. Consider completing operating limits and consequences of deviation. 17. Consider piping discharge pressure switches f or compressors, to compressor discharge. 18. Consider installing one common system discharge pressure cut out. 19. Consider having spill kit for oil on hand. 20. Consider adding " check the manhole covers" to the screw compressor PM requirements. 21. Consider using back up nuts on manhole covers. 22. Consider reviewing accessibility of the valves on the condenser. 23. Consider periodically checking condenser water with litmus paper for ammonia. 24. Consider developing periodic check of system non-condensable. 25. Consider evaluating purger foul gas lines for adequate support. 26. Consider instituting regular inspections to insure relief valve outlet caps are in place. 27. Consider developing procedure for pumping out condensers. 28. Consider adding, "inspect condenser supports" annually to PM requirements. 29. Consider adding, "inspect piping for corrosion" to PM Requirements. 30. Consider developing a written pump out procedure for all vessels. 31. Consider verifying the relief st ub from the receiver, high temp recirculator and low temp recirculator are of adequate size and capacity for the relief valves. 32. Consider installing a guard on the receiver sight glass. 33. Consider evaluating the low temp recirculator for unnecessary corroded piping, remove, clean or paint as necessary. 34. Consider evaluating the need to install low level protection on the high temp recirculator. 35. Consider adding regulator PM to your positive displacement pumps PM checklist. 36. Consider periodic testing of all safeties. 37. Consider tying the ventilation system into the ammonia detection system. 38. Consider evaluating the need for relief valves for oil pots. 39. Consider documenting a pump out procedure for isolating ammonia pumps. 40. Consider writing a procedure for pumping out evaporators. 41. Consider evaluating the condition of evaporator #26. 42. Consider evaluating the need for ladders to accessing valves throughout the facility. 43. Consider adding "inspect condition of evaporator supports" to PM requirements. 44. Consider inspecting piping that penetrates the walls. 45. Consider developing a procedure for opening the system. 46. Consider when writing PM Requirements for inspecting piping supports to verify proper return line slope. 47. Consider evaluating evaporators and piping exposed to forklifts for adequate guards. 48. Consider evaluating the ice load on piping that penetrates load-bearing walls when performing annual pipe support inspection. 49. Consider evaluating the need for annual maintenance on key isolation valves. 50. Consider developing valve maintenance procedure. 51. Consider providing refresher training for keeping valves clear of ice. 52. Consider evaluating structural integrity of liquid line piping to 1968 addition. 53. Consider reviewing and documenting the design basis of the ventilation system for adequate capacity. 54. Consider activating engine room exhaust fans with the ammonia detector. 55. Consider conducting a mock spi ll at this facility. 56. Consider pressure testing of all encapsulated suits. 57. Consider evaluating the communication systems. 58. Consider reviewing the inclement weather plan. 59. Consider providing air horns for employee notification during power outage. 60. Consider conducting an emergency evacuation. 61. Consider evaluating the facility for areas where employees step or lean against piping and determine possible e/a controls. 62. Consider evaluating the use of correct PPE when chipping ice on ammonia lines. 63. Consider reviewing MOC with employees and clearly defining set points that are not to be changed without going through MOC procedures. 64. Consider establishing priority system for maintaining and repairing safety related items. 65. Consider instituting regular safety meetings and PSM meetings. 66. Consider writing a procedure for adding/draining oil on a compressor. 67. Consider some type of back flow preventer at charge connection on HP receiver. 68. Consider requiring emergency stop procedure for ammonia charging truck. 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 including the following information about the process equipment in the Process Safety Information section of your PSM manual: Materials of construction PI&D Drawings Electrical Classification Relief system design and design basis Ventilation system Design codes and standards employed Material and Energy Balances Safety Systems 4. Consider completing PHA action items as so on as possible. 5. Consider adding safety systems and their function to your operating procedure. 6. Consider completing and updating all Standard Operating Procedures. 7. Consider including operating limits and consequences of deviation to all of your Standard Operating Procedures. 8. Consider reviewing all Standard Operating Procedures and certifying annually. 9. Consider making all Standard Operating Procedures available to all employees working with the system. 10. Consider implementing safe work practices for confined space and opening the system. 11. Consider updating training information about the process and operating procedures 12. Consider giving written test to verify employee training. 13. Consider maintaining an injury and illness log on contract employees. 14. Consider assuring that contract employees are trained to safely perform their jobs as they relate to the safety and health hazards on site. 15. Consider obtaining the following safety training documentat ion from the contractor: a. The identity of the trained contract employee. b. Date of training. c. Means used to verify that employee understood training. 16. Consider ensuring employer is notified of any hazards presented by contractor's work. 17. Consider conducting an annual evacuation drill to ensure employees understood the Emergency Response Procedures. 18. Consider contacting your local Fire Department to participate in this drill. 19. Consider updating Emergency Responders fit test for respirators. 20. Consider holding regular Process Safety Management team meetings |