American Cold Storage Boonville - Executive Summary |
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American Cold Storage - Boonville, Indiana Facility Risk Management Plan Executive Summary The Clean Air Act (CAA) Amendments of 1990 added Section 112(r) to the CAA, which mandated the U.S. Environmental Protection Agency (EPA) to establish a regulatory program to prevent serious chemical accidents that may potentially affect public health and the environment. The CAA makes it clear that facility that handle hazardous substances bear the primary responsibility for ensuring their safe use. This statutory mandate required EPA to establish a list of regulated substances as well as propose elements of an accidental release prevention program. Under the requirements of Section 112(r), stationary sources (facility) must identify and assess their chemical hazards and implement certain activities that are designed to reduce the likelihood and severity of accidental chemical releases. Also, facility must submit a risk management plan (RMP) that summarizes these activities, and the plans wi ll be available to state and local governments, the public and other stakeholders. The hazard assessment data disclosed by facility can be used by local emergency planning committees (LEPCs) and other local response agencies to improve community emergency response planning. Also, the information in the risk management plan gives citizens the opportunity to work with industry to reduce risks to the community from chemical accidents. The final RMP rule spells out requirements for the following basic components of a risk management program that regulated facility must implement: ? A hazard assessment program that identifies and analyzes the potential on-site and off-site impacts of worst-case and alternative accidental release scenarios of regulated substances, and includes documentation of five-year accident histories involving regulated substances; ? A prevention program that covers operating procedures, maintenance, training, management of change, process safety information, etc., f or operations involving regulated substances; ? An emergency response program to mitigate any accidental releases that occur; and ? An overall system to manage the development and implementation of a risk management program. A description of the regulated substances handled: The ACS-Boonville facility is a cold storage warehouse. Ammonia is the only RMP regulated substance, at this facility, above the threshold quantity levels established by EPA. This facility uses an anhydrous ammonia as a refrigerant in quantities requiring an RMP (under present EPA regulation.) Anhydrous ammonia, NH3, is a colorless gas at ambient temperature or pressure; it is, however, usually stored as a liquid under pressure or refrigeration. The gas is less dense than air, but when liquid ammonia is released it may aerosolize and behave as a dense gas. The effects of ammonia inhalation range from irritation to severe respiratory injuries to death. Ammonia is self-alarming; its strong odor is noticeable at small concentrations. In general, people will not remain in the presence of ammonia so that the primary threat is to people who are unable to flee. The ammonia refrigeration system is a series of interconnected vessels and piping, that compress and pump anhydrous ammonia to several rooms to cool, chill, and freeze items to specific temperatures. Refrigeration equipment includes low pressure receivers, compressors, condensers, accumulators, evaporators, pumps, piping, instruments, controls, and valves. The quantity of ammonia in the system is approximately 14,000 pounds. The accidental release prevention and emergency response policies: This facility complies with requirements for anhydrous ammonia use, and it is American Cold Storage's (ACS) policy to adhere to all applicable federal, state, and local laws. If an emergency were to occur, it is ACS's policy to notify the Warrick County LEPC, the Boonville Fire Department, and respond to the emergency. A site specific emergenc y plan has been developed to address emergencies. The worst case scenario: As required by EPA, the worst case scenario evaluates the failure of a filled ammonia accumulator, resulting in a vapor cloud inside the building. According to EPA guidance the distance around the facility with EPA established concentrations of concern is approximately 1.3 miles. The 1.3 mile radius includes an estimated residential population of 490 people, a recreational area, a school, and office or industrial areas. Five-year accident history: The ACS-Boonville facility has not had an accident in the past five years involving anhydrous ammonia that caused death, injuries, property or environmental damage, evacuations, or sheltering in place. The general accidental release prevention program and chemical-specific prevention steps: This facility complies with EPA's accident prevention rule and all applicable state and local codes and regulations. The anhydrous ammonia system is designed, installed, and maintained in accordance with the International Institute of Ammonia Refrigeration (IIAR) guidelines, manufacturer specifications, best management practices, and state law. The ACS-Boonville facility is required to comply with the most stringent EPA RMP and OSHA prevention programs. The emergency response program: In the event of an emergency involving the ammonia system, ACS-Boonville takes the following actions. If any anhydrous ammonia release is likely to impact off site, the local emergency services will be notified. ACS-Boonville has an in-house team trained to Operations Level for initial response/containment. ACS-Boonville employees are trained to use self-contained breathing equipment and have taken OSHA worker right-to-know training. |