AmeriCold Logistics Plant # 75101 - 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 75101 (Gateway) 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 75101 (Gateway) 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 condense d 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 40,648.54 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) - 8,333 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) rea ched 1.4 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 Bulle tin 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 75101 (Gateway) has implemented a Process Safety Management program for compliance with the OSHA 1910.119 regulation since February 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, Inc. Plant 75101 (Gateway) 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 (April 20, 1998) generated mitigation measures that would improve safety at the AmeriCold Logistics, Inc. Plant 75101 (Gateway) facility located at 6150 Xavier Dr. in Atlanta, GA.. These action items are as follows: 1. Consider monitoring relief valve header for relief events. 2. Consider continued development of PI&D drawings. 3. Consider labeling key valves. 4. Consider evaluating evaporators and piping exposed to forklifts for adequate guards. 5. Consider installing relief valves on the thermosyphon liquid for C6, C7 and C8. 6. Consider evaluating the need for a relief valve o n the pump out compressor in machine room #1. 7. Consider evaluating the ability of the ammonia detection system activating the ventilation system. 8. Consider continuing valve marking. 9. Consider evaluating howden, compressors for start limit switches. 10. Consider developing procedure for pumping out condensers. 11. Consider developing a written pumpout procedure for all vessels. 12. Consider tying the ventilation system into the ammonia detection system. 13. Consider evaluating the need for relief valves for oil pots. 14. Consider writing a procedure for pumping out evaporators. 15. Consider developing a procedure for opening the system. 16. Consider evaluating evaporators and piping exposed to forklifts for adequate guards. 17. Consider evaluating the need for annual maintenance on key isolation valves. 18. Consider developing valve maintenance procedure. 19. Consider evaluating the need for replacing the high-pressure liquid line from ER-2 feeding dock units. 20. Consider providi ng air horns for employee notification during power outage. 21. Consider conducting an emergency evacuation. 22. Consider writing a procedure for adding/draining oil on a compressor. 23. Consider developing a procedure for changing relief valves. 24. Consider some type of back flow preventer at charge connection on HP receiver. 25. Consider investigating safety training record of ammonia supplier. 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 developing consequences of deviation for the process. 2. Consider completing PHA action items as soon as possible. 3. Consider adding safety systems and their function to y our operating procedure. 4. Consider updating all Standard Operating Procedures. 5. Consider reviewing and certifying all Standard Operating Procedures annually. 6. Consider maintaining an injury and illness log on contract employees. 7. Consider assuring that contract employees are trained to safely perform their jobs as they relate to the safety and health hazards on site. 8. 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. 9. Consider updating all Emergency Responders fit test for respirator. |