AmeriCold Logistics Plant # 75158 - 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 75158 (Southgate) 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 ye ar. 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 75158 (Southgate) 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 11,145.93 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) - 10,049 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 1.6 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" $ I IAR 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 75158 (Southgate) has implemented a Process Safety Management program for compliance with the OSHA 1910.119 regulation since January 7, 1997. 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 75158 (Southgate) 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 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 (February 18, 1999) generated mitigation measures that would improve safety at the AmeriCold Logistics, L.L.C. Plant 75158 (Southgate) facility located at 1845 Westgate Pkwy. in Atlanta, GA.. These action items are as follows: 1. Consider reviewing the relief valve settings and capacities on all equipment. 2. Consider reviewing the high-pressure cutout settings to ensure they are 20% below the relief valve setting. 3. Consider continued development of PI&D drawings. 4. Consider labeling key valves. 5. Consider continuing valve marking. 6. Consider putting a check valve on portable oil pump discharge. 7. Consider completing operating limits and consequences of deviation. 8. Consider developing procedure for pumping out condensers. 9. Consider developing a written pumpout procedure for all vessels. 10. Consider documenting a pump out procedure for isolating ammonia pumps. 11. Consider developing a procedure for pumping out a sight glass column. 12. Consider writing a procedure for pumping out evaporators. 13. Consider inspecting piping that penetrates the walls. 14. Consider developing a procedure for opening the system. 15. Consider evaluating the need for annual maintenance on key isolation valves. 16. Consider developing valve maintenance procedure. 17. Consider reviewing and documenting the design basis of the ventilation system for adequate capacity. 18. Consider developing an enclosed Emergency Response trailer to be kept outside the facility. 19. Consider providing air horns for employee notification during power outage. 20. Consider condu cting an emergency evacuation. 21. Consider writing a procedure for adding/draining oil on a compressor. 22. Consider developing a procedure for changing relief valves. 23. Consider updating training on red rag and lock out/ tag out. 24. Consider some type of back flow preventer at charge connection on HP receiver. 25. Consider investigating safety training record of ammonia supplier. 26. Consider requiring emergency stop procedure for ammonia charging truck. 27. 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 PHA action items as soon as p ossible. 2. Consider adding safety systems and their function to your operating procedure. 3. Consider updating all Standard Operating Procedures. 4. Consider ensuring all Standard Operating Procedures are reviewed annually. 5. Consider maintaining an injury and illness log on contract employees. 6. Consider assuring that contract employees are trained to safely perform their jobs as they relate to the safety and health hazards on site. 7. Consider obtaining the following safety training documentation from the contractor: a. The identity of the trained contract employee. b. Date of training. a. Means used to verify that employee understood training. 8. Consider updating Emergency Responders fit test for respirators. 9. Consider holding regular Process Safety Management Team meetings. |