Interstate Warehousing, Inc. - Executive Summary
EXECUTIVE SUMMARY |
Interstate Warehousing, Inc., Denver, CO 80239
Interstate Warehousing, Inc. (hereafter referred to as IWI) have implemented PSM and RMP at the Denver facility in order to operate in accordance with regulations and industry standards. The ultimate objective is to minimize the risks of an accidental ammonia release. The facility management, along with corporate and an outside consulting firm have developed the above plus, an Emergency Response Plan along with training to ensure a fast and efficient response in the event of an accidental hazardous material release, fire or other emergency situation.
In order to prevent a potential accidental ammonia release at IWI, the Company has an ongoing review process for design and operating procedures. This assists in ensuring the refrigeration systems comply with OSHA, EPA and all other local, state and federal regulatory agency safety standards, as well as its own internal standards.
IWI has an emergency response training
program that follows the guidelines of federal, state and local regulatory agencies. The management believes that cooperative emergency response training must include company employees, local emergency responders and regulatory agency people in order to provide a safe workplace and a safe environment. In an emergency, all personnel are trained to cooperate with fellow employees and other support personnel (outside agencies take over upon arrival) as directed by the Emergency Response Incident Commander.
IWI in Denver is a refrigerated warehousing facility. The vast majority of the product stored is refrigerated foods for human consumption and inherently poses no known environmental or safety risks. Ammonia, a regulated substance, is the commonly used refrigerant in industrial grade refrigeration systems that maintain low storage temperatures and can be safely managed by trained operators. The ammonia refrigeration process functions within enclosed piping network and vessels serving t
he facility operations. The refrigeration system in this facility contains approximately 15900 pounds of ammonia inventory for this process.
In accordance with the EPA's requirements, various accidental release scenarios are performed in order to develop a radius of potential impact around the facility. The primary purpose of this is to assist the local Emergency Planning Commission with additional information if an accidental release was to occur. The release model used was the EPA supplied RMP *Comp.
In the worst case scenario, a pipe at the high-pressure receiver liquid outlet is broken allowing the entire liquid ammonia charge of 4,000 lbs in that vessel to be released in ten minutes.
Based on the RMP *Comp models, this scenario without mitigation could have a potential off site area of concern extending to an endpoint of .8 miles.
In an alternate scenario, the above was again used this time with mitigation (in building). Based on the RMP *Comp model, this scenario could presen
t a potential off site area of concern extending to an endpoint of .3 miles.
These release scenario plans are maintained at the site and are used for training and provide information for company responders and for the FIRE DEPARTMENT, HAZMAT TEAM AND LOCAL EMERGENCY PLANNING COMMITTEE.
IWI is committed to safe management and operation of the closed Ammonia Refrigeration System. Maintenance employees are trained to observe operational procedures designed to be as fail-safe as possible to prevent accidental release of ammonia at any time. Should any accidental release occur, all maintenance employees, shift supervisors and management are certified Emergency Hazardous Material Responders to the technician level and are required to observe safe emergency response procedures. They are trained to work in conjunction with the local Emergency Planning Commission to minimize the impact of any accidental releases. In planning with the local HAZMAT team, IWI maintenance employees serve as tech
nical assistance in the event of a spill/leak to the Incident Commander of the HAZMAT team.
As part of IWI safety programs, we have adopted the OSHA Process Safety Management Plan using the "What If " methodology in our PHA's. The OSHA PSM 1910.119 Program has been implemented and covers the entire scope of safe operation procedures of the ammonia refrigeration system from start-up and normal operations to potential emergency response operations and subsequent clean-up and restoration of systems. Normal operations, Accidental Release Prevention Program and Chemical- Specific Prevention Steps rely partially on the following 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 Am
monia Refrigeration Systems".
IIAR, "A Guide to Good Practices for the Operation of an Ammonia Refrigeration System".
In addition, we are currently taking steps to address and complete all issues/recommendations suggested from our PHA's completed in March of 2000.
FIVE YEAR ACCIDENT HISTORY
There have been no reported releases of ammonia at this facility over the last five years (5-95 through present).