Burris Refrigerated Logistics, Sumter, SC, 29154 - Executive Summary |
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1. Facility Policy: The management and employees of Growers Cooperative, Inc. are committed to the prevention of any accidental releases of anhydrous ammonia through the use of proper equipment, regular inspections, maintenance and training of all persons that work with anhydrous ammonia. Should an accidental release occur, this facility has worked with the local fire department and local emergency planning committee so they can plan for response to a release and minimize the impact of the release to people and the environment. 2. Facility Information: The primary activity at this facility is the storage and handling of anhydrous ammonia for sale to farmers. Anhydrous ammonia is received, stored and distributed for direct application to the soil as a crop production nutrient. The maximum quantity stored is 170000 pounds. This facility stores anhydrous ammonia in 2 tanks. 3. Worst-Case Scenario: Failure of the largest storage tank when filled to the maximum allowed capacit y of 85% would release the total contents or 80000 pounds of anhydrous ammonia as a gas in a period of ten minutes. Company procedures and equipment design standards limit the maximum filling capacity of tanks to 85% of capacity. The distance to the endpoint of dispersion based on the model used is 1.9 miles. Alternative-Case Scenario: The alternative-case scenario is assumed to be a release of 11908 pounds of anhydrous ammonia in a period of two minutes from the rupture of a 2 inch transfer pipe. The distance to the endpoint of dispersion is 0.6 miles. 4. Accidental Release Program: This facility complies with the various rules and regulations governing the storage and handling of anhydrous ammonia including ANSI K61.1, OSHA 29 CFR 1910.111 and regulations administered by the Department of Agriculture. Training is provided on safe anhydrous ammonia operations for employees. 5. Five-year Accident History: There have been no accidental releases of anhydrous ammonia for th e covered process at this facility in the past five years. 6. Emergency Response Program: This facility has a written emergency plan in accordance with OSHA Standards 29 CFR 1910.38 and 1910.120. Emergency planning and community right-to-know information is provided to the state emergency response commission, local emergency planning committee and local fire department as required by SARA Title III of EPCRA. 7. Planned Changes to Improve Safety: Safety improvement is an on-going process at this facility. Periodic inspections and evaluations are performed to assess the maintenance of safe practices and operations. There are no additional specific anhydrous ammonia safety recommendations for implementation at this time. 2. Facility Information: The primary activity at this facility is the storage and handling of anhydrous ammonia for sale to farmers. Anhydrous ammonia is received, stored and distributed for direct application to the soil as a crop production nutrient. The maximum quantity stored is 170000 pounds. This facility stores anhydrous ammonia in 2 tanks. 3. Worst-Case Scenario: Failure of the largest storage tank when filled to the maximum allowed capacity of 85% would release the total contents or 80000 pounds of anhydrous ammonia as a gas in a period of ten minutes. Company procedures and equipment design standards limit the maximum filling capacity of tanks to 85% of capacity. The distance to the endpoint of dispersion based on the model used is 1.9 miles. Alternative-Case Scenario: The alternative-case scenario is assumed to be a release of 11908 pounds of anhydrous ammonia in a period of two minutes from the rupture of a 2 inch transfer pipe. The distance to the endpoint of dispersion is 0.6 miles. 4. Accidental Release Program: This facility complies with the various rules and regulations governing the storage and handling of anhydrous ammonia including ANSI K61.1, OSHA 29 CFR 1910.111 and regulations administered by the D epartment of Agriculture. Training is provided on safe anhydrous ammonia operations for employees. 5. Five-year Accident History: There have been no accidental releases of anhydrous ammonia for the covered process at this facility in the past five years. 6. Emergency Response Program: This facility has a written emergency plan in accordance with OSHA Standards 29 CFR 1910.38 and 1910.120. Emergency planning and community right-to-know information is provided to the state emergency response commission, local emergency planning committee and local fire department as required by SARA Title III of EPCRA. 7. Planned Changes to Improve Safety: Safety improvement is an on-going process at this facility. Periodic inspections and evaluations are performed to assess the maintenance of safe practices and operations. There are no additional specific anhydrous ammonia safety recommendations for implementation at this time. HS Gathering's Hambert Compressor Station is not covered u nder OSHA's PSM Standard because it is a normally unoccupied remote facility. However HS Gathering has elected to use OSHA's PSM Standard as a model of good business practice at this compressor station even if it is "normally unoccupied remote facilities". Accidental Release Prevention and Response HS Gathering LLC has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, HS Gathering personnel are trained on how to respond to such emergencies. If the situation requires, HS Gathering will notify, cooperate with, and support the various emergency response agencies. Location and Regulated Substances HS Gathering's Hambert Compressor Stati on is located in Weld County, Colorado near the intersection of WCR 38 and WCR 35 in a rural area which is used primarily for farming. The Hambert Compressor Station consists of two compressor unit, #51 and #52, that discharge 18 MMCF/D through glycol dehydration to delivery points via a 20" cleanable pipeline. The discharge pressure is not to exceed 180 psig. The station is equipped with inlet seperation. Liquids separation (condensate) goes to four 225 barrel storage tanks. The purpose of a compressor station is to increase the pressure of the gas being transported in the pipelines and to reduce the dew point of the gas to a level that is acceptable for pipeline transmission. Each compressor station receives gas from various gathering lines and supplies the pipeline(s) that transports the gas to a processing plant. Control of the dew point is critical since the incoming gas contains moisture (water and heavy hydrocarbons). The amount of moisture in the gas varies from day to day depending on a great number of variables at the well heads. The dew point increases as the concentration of moisture in the inlet gas increases. As gas flows through the pipeline, its temperature will decrease to about the same temperature as the surrounding environment. If this temperature is below the dew point of the gas, the water and heavy hydrocarbons will tend to condense. The resulting buildup of hydrates can begin to restrict gas flow, particularly at orifices and bends in the pipe. In extreme cold, the hydrates may form a potentially dangerous ice plug. In order to reduce the dew point of the gas (minimize the formation of hydrates), the inlet gas is put through a slug catcher, an inlet separator, and a glycol contactor with scrubber to remove moisture. Compression of the gas causes some of the naturally occurring hydrocarbons, which are in the vapor phase of the inlet gas stream, to condense out of the stream. This allows heavy hydrocarbons and water to condense out of the gas resulting in a lower dew point. These condensed raw natural gas liquids (NGL), also called condensate, are stored in tanks until there is a sufficient volume to be pumped into a tank truck for transportation for processing into marketable products. The glycol is regenerated and used again. The flammability and volume of the raw NGL stored at The Hambert Compressor Station triggered coverage under the EPA RMP Standard. History and Ownership The Hambert Compressor Station was built by Panhandle Eastern Co in the mid 1970's. HS Resources entered into a purchase and sale agreement with Kinder Morgan Inc., formerly known as KN Energy, in December of 1999. KN Energy operated the system from April 1993 through December 1, 1999. Program Level HS Gathering has determined that Program Level 1 applies to the Hambert Compressor Station since it has a documented Emergency Response Plan which has been coordinated with the local Fire Department and has had no accidental relea se of the regulated substance (condensate) that directly or indirectly caused a death, injury, or response or restoration activity for an environmental receptor in the previous five years. Also, the facility's distance to a "public receptor" is greater than the distance to the calculated endpoint for the worst-case scenario of 0.1 miles. Offsite consequence Analysis Results The worst-case scenario (WCS) associated with flammable substances in a Program Level 1 process at the Hambert Compressor Station is a vapor cloud explosion resulting from a catastrophic tank failure in the condensate tank storage area. A written procedure is in place to limit the storage inventory to 80% of the maximum tank capacity. Therefore the reduced inventory is assumed, resulting in a release of 31,000 lbs. (approximately 5700 gals.) of condensate over a 10-minute period. Although we have various controls to prevent such releases and to manage their consequences, no credit for passive mitigation measure s (such as dikes or berms) was taken into account in evaluating this scenario. The maximum distance to the 1-psi overpressure from a vapor cloud explosion of this material was 0.1 miles. No Program Level 2 or 3 processes containing regulated flammable substances were identified at the Hambert Compressor Station. Emergency Response Program The Hambert Compressor Station has established and maintains an emergency response plan that is coordinated with local response agencies. The goals of the program are to protect employees and the general public from the hazardous effects of releases and to minimize the effects of any releases. The program is routinely reviewed and updated to reflect station, personnel, and regulatory changes. Accident History During the last five years, there have been no accidents that meet the criterion for inclusion in this submittal Planned Changes for Improved Safety Ideas for changes to improve safety are actively sought from employees. Employee safet y meetings that focus on safety issues, such as flammable substances, are held regularly. Employees are encouraged and trained to recognize hazards and present ideas to eliminate them or to minimize the potential consequences of those hazards. HS Gathering's Hambert Compressor Station is not covered under OSHA's PSM Standard because it is a normally unoccupied remote facility. However HS Gathering has elected to use OSHA's PSM Standard as a model of good business practice at this compressor station even if it is "normally unoccupied remote facilities". Accidental Release Prevention and Response HS Gathering LLC has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. H owever, if a release does occur, HS Gathering personnel are trained on how to respond to such emergencies. If the situation requires, HS Gathering will notify, cooperate with, and support the various emergency response agencies. Location and Regulated Substances HS Gathering's Hambert Compressor Station is located in Weld County, Colorado near the intersection of WCR 38 and WCR 35 in a rural area which is used primarily for farming. The Hambert Compressor Station consists of two compressor unit, #51 and #52, that discharge 18 MMCF/D through glycol dehydration to delivery points via a 20" cleanable pipeline. The discharge pressure is not to exceed 180 psig. The station is equipped with inlet seperation. Liquids separation (condensate) goes to four 225 barrel storage tanks. The purpose of a compressor station is to increase the pressure of the gas being transported in the pipelines and to reduce the dew point of the gas to a level that is acceptable for pipeline transmission. E ach compressor station receives gas from various gathering lines and supplies the pipeline(s) that transports the gas to a processing plant. Control of the dew point is critical since the incoming gas contains moisture (water and heavy hydrocarbons). The amount of moisture in the gas varies from day to day depending on a great number of variables at the well heads. The dew point increases as the concentration of moisture in the inlet gas increases. As gas flows through the pipeline, its temperature will decrease to about the same temperature as the surrounding environment. If this temperature is below the dew point of the gas, the water and heavy hydrocarbons will tend to condense. The resulting buildup of hydrates can begin to restrict gas flow, particularly at orifices and bends in the pipe. In extreme cold, the hydrates may form a potentially dangerous ice plug. In order to reduce the dew point of the gas (minimize the formation of hydrates), the inlet gas is put through a s lug catcher, an inlet separator, and a glycol contactor with scrubber to remove moisture. Compression of the gas causes some of the naturally occurring hydrocarbons, which are in the vapor phase of the inlet gas stream, to condense out of the stream. This allows heavy hydrocarbons and water to condense out of the gas resulting in a lower dew point. These condensed raw natural gas liquids (NGL), also called condensate, are stored in tanks until there is a sufficient volume to be pumped into a tank truck for transportation for processing into marketable products. The glycol is regenerated and used again. The flammability and volume of the raw NGL stored at The Hambert Compressor Station triggered coverage under the EPA RMP Standard. History and Ownership The Hambert Compressor Station was built by Panhandle Eastern Co in the mid 1970's. HS Resources entered into a purchase and sale agreement with Kinder Morgan Inc., formerly known as KN Energy, in December of 1999. KN Energy ope rated the system from April 1993 through December 1, 1999. Program Level HS Gathering has determined that Program Level 1 applies to the Hambert Compressor Station since it has a documented Emergency Response Plan which has been coordinated with the local Fire Department and has had no accidental release of the regulated substance (condensate) that directly or indirectly caused a death, injury, or response or restoration activity for an environmental receptor in the previous five years. Also, the facility's distance to a "public receptor" is greater than the distance to the calculated endpoint for the worst-case scenario of 0.1 miles. Offsite consequence Analysis Results The worst-case scenario (WCS) associated with flammable substances in a Program Level 1 process at the Hambert Compressor Station is a vapor cloud explosion resulting from a catastrophic tank failure in the condensate tank storage area. A written procedure is in place to limit the storage inventory to 80% of the m aximum tank capacity. Therefore the reduced inventory is assumed, resulting in a release of 31,000 lbs. (approximately 5700 gals.) of condensate over a 10-minute period. Although we have various controls to prevent such releases and to manage their consequences, no credit for passive mitigation measures (such as dikes or berms) was taken into account in evaluating this scenario. The maximum distance to the 1-psi overpressure from a vapor cloud explosion of this material was 0.1 miles. No Program Level 2 or 3 processes containing regulated flammable substances were identified at the Hambert Compressor Station. Emergency Response Program The Hambert Compressor Station has established and maintains an emergency response plan that is coordinated with local response agencies. The goals of the program are to protect employees and the general public from the hazardous effects of releases and to minimize the effects of any releases. The program is routinely reviewed and updated to refl ect station, personnel, and regulatory changes. Accident History During the last five years, there have been no accidents that meet the criterion for inclusion in this submittal Planned Changes for Improved Safety Ideas for changes to improve safety are actively sought from employees. Employee safety meetings that focus on safety issues, such as flammable substances, are held regularly. Employees are encouraged and trained to recognize hazards and present ideas to eliminate them or to minimize the potential consequences of those hazards. 2. Facility Information: The primary activity at this facility is the storage and handling of anhydrous ammonia for sale to farmers. Anhydrous ammonia is received, stored and distributed for direct application to the soil as a crop production nutrient. The maximum quantity stored is 170000 pounds. This facility stores anhydrous ammonia in 2 tanks. 3. Worst-Case Scenario: Failure of the largest storage tank when filled to the maximum a llowed capacity of 85% would release the total contents or 80000 pounds of anhydrous ammonia as a gas in a period of ten minutes. Company procedures and equipment design standards limit the maximum filling capacity of tanks to 85% of capacity. The distance to the endpoint of dispersion based on the model used is 1.9 miles. Alternative-Case Scenario: The alternative-case scenario is assumed to be a release of 11908 pounds of anhydrous ammonia in a period of two minutes from the rupture of a 2 inch transfer pipe. The distance to the endpoint of dispersion is 0.6 miles. 4. Accidental Release Program: This facility complies with the various rules and regulations governing the storage and handling of anhydrous ammonia including ANSI K61.1, OSHA 29 CFR 1910.111 and regulations administered by the Department of Agriculture. Training is provided on safe anhydrous ammonia operations for employees. 5. Five-year Accident History: There have been no accidental releases of anhydrous ammonia for the covered process at this facility in the past five years. 6. Emergency Response Program: This facility has a written emergency plan in accordance with OSHA Standards 29 CFR 1910.38 and 1910.120. Emergency planning and community right-to-know information is provided to the state emergency response commission, local emergency planning committee and local fire department as required by SARA Title III of EPCRA. 7. Planned Changes to Improve Safety: Safety improvement is an on-going process at this facility. Periodic inspections and evaluations are performed to assess the maintenance of safe practices and operations. There are no additional specific anhydrous ammonia safety recommendations for implementation at this time. Purpose To ensure a controlled and safe workplace by identifying hazards. This type of analysis applies to and is required for every hazardous (toxic & reactive) chemical listed in section 1910.119. Process Hazard Analysis (PHA) shall include, but is not limited to the following items: 1. The hazards of each process; both chemical and mechanical hazards should be noted. 2. Identification/examples of previous incidents, which did, or could, have become catastrophic. 3. The used or site available chemical detection methods. 4. Consequences of loss of system/process control. Factors causing loss of control should include both operator and mechanical error/malfunction. Requirements I. Employer shall perform an initial PHA on all ammonia equipment. PHA's shall be done as soon as possible and in order of relative danger to personnel and equipment that a failure would cause (Required schedule is 100% complete by May 26, 1994). II. The employer shall use one or more generally accepted methodologies to evaluate the process hazards; What If/Checklist, Hazard and Operability Study (HAZOP), Failure Mode Effects Analysis (FMEA), Fault tree Analysis, or other appropriate equivalent methodology. III. The PHA shall address: A. Haza rds of the process. B. Identification of any previous incident that did or had a likely potential for causing catastrophic consequences in the workplace. C. Engineering and administration controls applicable to the process (controls, alarms, detection equipment, ect.) D. Consequences of failure. E. Facility sighting. F. Human factors. G. Qualitative evaluation of the range of safety and health effects of failure of controls. IV. PHA shall be performed by a team with expertise in engineering and process operating and the PHA methodology being used. V. The employer shall promptly address the team's findings and recommendations and document actions taken or scheduled to be completed. The employer shall communicate any changes to all affected employees and update any relevant information (operating procedures, training, ect., refer to Management of Change section). VI. Review and update PHA for the entire system on a regular basis, not more than five (5) years. VII. Retain PHA informat ion and updates along with all supporting documentation for the life of the process. Process Hazard Analysis Content of Hazard Analysis A Process Hazard Analysis (PHA) comprises three parts: 1: preparation (Operating Procedures , P & ID's, PSI, ect.), 2: conducting the hazard analysis (PHA Worksheet), and 3: follow-up actions resulting from the hazard analysis (PHA Action Items). The preparatory phase for a process hazard analysis requires the gathering of data, drawings, procedures and formation of a team. Typically, each of the acceptable methods will require up-to-date process flow diagrams, piping and instrumentation drawings, and data regarding process materials and conditions. Certain hazard analysis techniques may require additional, more detailed materials. The hazard analysis is conducted with the clear goal of identifying potential hazards. Recommendations may be made with the intent of reducing or eliminating a potential hazard. Items of concern may be identified f or further, more detailed study. The follow-up phase involves evaluating the proposed recommendation to determine the appropriate course of action. The action taken may include: 1. Accepting and implementing the recommendations as made; 2. Accepting the recommendations in principle but developing an alternative approach to meet the intent; or 3. Accepting the current situation and not implementing the recommendation. The current situation may be the course of action taken if there appears to be no technically feasible solution identified, if any recommendation considered would pose additional, more serious hazards, or if it is determined that the risk is not significant enough to justify implementing any recommendation. Implementing engineering and/or administrative controls may be used to reduce the risk of a hazard. Further study may be required to determine if certain hazards identified are indeed significant to exposed workplace employees. This further study initially may requir e a more detailed hazard analysis, possibly with a different technique from a group of approved methods. Followed by a consequence analysis, that will more precisely evaluate the consequences of the potential hazards. RMP Executive Summary Burris Refrigerated Logistics Sumter, SC 29154 Regulated Substance Handled Burris Refrigerated Logistics, located at 1900 Corporate Way, Sumter, SC, 29154, is a public cold storage/frozen food facility. The prime Refrigerant used is Anhydrous Ammonia in a closely controlled and monitored environment. The Refrigeration system is Computer controlled with built in safeguards which is monitored 24 hours a day, 365 days a year. The facility has personnel "on call" at all times that are trained and qualified to handle any emergency situation that may arise. The system is monitored in each Room that the process takes place by a computer linked detection system. Ammonia is a self-alarming substance with a distinctive pungent odor. Due to this odor, persons exposed to ammonia vapor will not voluntarily stay in the area of even small concentrations (these concentrations would not result in health risks). The Department of Transportation classifies ammonia as a non-flammable. Ammonia will burn however, but only in a very narrow and high range of concentration with high temperature. The U.S. Occupational and Health Administration (OSHA) have made a determination on the permissible exposure of ammonia to people. The maximum allowable exposure for eight hours is 50 PPM (parts per million). Worst Case Scenario The worse case scenario of an ammonia spill at the Sumter, SC facility was chosen to be a vessel rupture. We have conducted our own modeling as guidance for this report. The RMP Ammonia Program Plan was closely followed to ensure compliance. As a result we have found that should a catastrophic incident occur, there would be very limited private residences in the areas of release. The businesses that would be affected in t he immediate area are on a "call list" and would be contacted by a designated person if an emergency would occur during normal business hours. The worse case release of Anhydrous Ammonia would come from a rupture of the high-pressure vessel that is located in the machine room. The amount of the release in the study was 5,000 pounds. The release rate is 500 pounds per minute in a 10-minute period, with a 1.5 mph wind; the distance to the end point equals 0.3 miles. There are no schools, hospitals, prisons or recreational areas within the scope of this model. There are however, office and industrial buildings in the affected area. Along with the consideration to public receptors, environmental considerations are: National and State Parks, Wildlife Sanctuaries, and Federal Wilderness areas. None of the environmental considerations listed above are a factor in this report. Alternative Release Scenario The alternative release scenario of Anhydrous Ammonia at the Sumter, SC facility wa s chosen to be a rupture from a pipe. We have conducted our own modeling as guidance for this report using the same guidelines as in the worse case scenario. The conclusion of this study has found the same results as in the worse case scenario. The amount of the release that is used is two (2) pounds. The rate of release is 0.5 lbs./min., with release duration of six (4) minutes, with a wind speed of 1.5 mph. This resulted in an endpoint of contaminated area of 0.10 miles. The type of mitigation that would be used is as follows: 1. Sprinkler Systems 2. Neutralization 3. Emergency Shutdown Systems Five-Year History Due to our planned maintenance system, Corporate Engineering and the engineering department at Burris Refrigerated Logistics, Sumter, SC, conduct an audit quarterly. There hasn't been an accidental release of Anhydrous Ammonia from this location in the past five (5) years, or since the facility was opened in 1977. Emergency Response Program The emergency resp onse program at this facility is a current and ongoing process. 1. Evacuation drills are conducted annually. This requires the participation of all employees. 2. The call list to surrounding businesses along with the designated person to make the calls is in place. 3. Alarms and automated computer controlled safety's are in place. 4. Response personnel are current with the HAZWOOPER training required by law. Planned Changes to Improve Safety Since safety is an ongoing concern at Burris Foods we have recently designated a Corporate Safety Administrator to oversee safety at all Burris facilities. This employee's responsibility will be to keep our employees and our facilities current and up to date with any new laws or procedures that become effective. Burris Refrigerated Logistics RMP has been produced in order to comply with "The Clean Air Act-Section 112(r). Burris Refrigerated Logistics is a responding facility. In that we are a responding facility it is our intention to ut ilize our RMP to assess possible hazards, prevent them from happening and in the unlikelihood a hazard should arise, be prepared with an emergency response. Burris Foods strives to be stewards of our community and industry. We are committed to working with federal, state and local governments, as well as the public to ensure the continued safety of our employees as well as our neighbors. |