AmeriCold Logistics Plant #75165 - 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 75165 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 75165 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 35,000 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) - 10,800 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 1.8 miles. Alternative Rele ase 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 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 75165 has implemented a Process Safety Management program for compliance with the OSHA 1910.119 regulation since December 30, 1997. FIVE YEAR ACCIDENT HISTORY There have been no reported releases of ammonia at this facility over the last five years (June 1, 1994 through June 1, 1999). EMERGENCY RESPONSE PROGRAM The AmeriCold Logistics, Inc. Plant 75165 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 emplo yees 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 (April 23, 1999) generated mitigation measures that would improve safety at the AmeriCold Logistics, Inc. Plant 75165 facility located at 205 S Airport Drive in Montezuma, GA.. These action items are as follows: 1. Consider inserting relief valve replacement schedule in PM manual. 2. Consider reviewing the high pressure cut out settings and high pressure alarm settings to insure they are below 20% of the relief valve setting. 3. Consider documenting a concise policy of replacing relief valves after a relief event. 4. Consider adding inspect piping for corrosion to piping to PM Requirements. 5. Consider continued development of P&ID's. 6. Consid er developing a written policy of replacing caps and plugs after using valves. 7. Consider Continue development of valve tagging. 8. Consider installation of IIAR recommended pipe labeling. 9. Consider reviewing the relief valve vent lines to see if improvements can be made to keep moisture from accumulating in piping. 10. Consider installing an ammonia detection system. 11. Consider scheduling regular testing of the compressor / booster safeties. 12. Consider completing pipe labeling. 13. Consider monitoring relief valve header for relief events. 14. Consider adding, " Check the manhole cover monthly" to the screw compressors. 15. Consider putting plugs in pipe when not draining oil. 16. Consider evaluating the need for single-phase protectors. 17. Consider clearly marking refrigeration oil. 18. Consider adding annual pipe support inspection to the PM program. 19. Consider adding vibrasorbers when changing out relief valves. 20. Consider documenting company policy of never over-ridin g safeties. 21. Consider changing relief valves on the condenser. 22. Consider placing plastic caps in the relief valves on the condensers. 23. Consider adding, "inspect condenser supports" annually to PM Requirements. 24. Consider reviewing accessibility to the valves on the condenser. 25. Consider developing periodic check of non-condensable. 26. Consider installing high pressure pre-alarm. 27. Consider developing a written pump-out procedure for all vessels. 28. Consider periodic testing of all safeties. 29. Consider writing a procedure for pumping out evaporators. 30. Consider reviewing the need for the additional hazard placards on evaporators in freezers and docks. 31. Consider labeling valve groups to correspond with evaporators. 32. Consider adding, " inspect condition of evaporator supports" to PM requirements. 33. Consider inspecting pipe that penetrates the walls. 34. Consider evaluating all refrigeration pipes for external corrosion. 35. Consider developing a line breaking procedure. 36. Consider evaluating the line size of relief headers. 37. Consider adding annual pipe support inspections to PM requirements. 38. Consider including excess ice load when writing PM Requirements for piping inspections. 39. Consider when writing PM Requirements for inspecting pipe supports to verify proper return line slope. 40. Consider evaluating the use of placards and danger for exposed ammonia lines. 41. Consider evaluating the need for annual maintenance on key isolation valves. 42. Consider a policy of annual maintenance on hand valves. 43. Consider providing refresher training for keeping valves free of ice. 44. Consider annual inspection of catwalk supports. 45. Consider painting catwalk pipe support structures. 46. Consider replacing windsock. 47. Consider reviewing and documenting the design basis of the ventilation system for adequate capacity. 48. Consider providing air horns for employee notification during power outage. 49. Consider evaluating the ammonia tu bes on hand. 50. Consider evaluating emergency response communication system. 51. Consider conducting a mock spill. 52. Consider reviewing inclement weather. 53. Consider developing emergency action plan for earthquakes. 54. Consider evaluating facility for areas where employees step-on or lean against piping and determine possible e/a controls. 55. Consider adding back flow check valve to oilier. 56. Consider insuring pressure-rating hose for oilier is adequate. 57. Consider reviewing MOC with employees and clearly defining setpoints that are not to be changed without going through MOC procedures. 58. Consider training employees on location and use of P&Ids. 59. Consider providing training on red-rag and lockout tag-out. 60. Consider establishing priority system for maintaining and repairing safety related items. 61. Consider back flow preventer at charge connection on HP receiver. 62. Consider investigating safety training record of ammonia supplier. 63. Consider adding, " ammonia ch arging must be supervised" to charging SOP. 64. Consider requiring emergency stop producer for ammonia charging truck. 65. Consider including system gauges and safeties in PM Requirements. 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 Electrical Classification Relief system design and design basis Ventil ation system Design codes and standards employed Material and Emergency Balances Safety Systems 4. Consider completing PHA action items as soon as possible. 5. Consider adding safety systems and their function to your operating procedures. 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 maintaining an injury and illness log on contract employees. 13. 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. 14. Consider ensuring employer is notified of any hazards presented by contractor's work. 15. Consider conducting an annual evacuation drill to ensure employees understood the Emergency Response Procedures. 16. Consider contacting your local Fire Department to participate in mock drill. 17. |