Alaska Pacific Seafoods, Inc. - Executive Summary

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EXECUTIVE SUMMARY 
 
This Risk Management Plan (RPM) is submitted to the United States Environmental  
Protection Agency (EPA) to meet the requirements of section 112(r) of the Clean Air Act  
Amendments of 1990, codified in the Code of Federal Regulation Title 40 Part 68. 
 
Stationary source and chemical of concern 
Alaska Pacific Seafoods is located on Kodiak Island in the city of Kodiak, Alaska. The  
facility is staffed year-round and also employs a large seasonal workforce during the  
spring and summer months. The plant produces fresh, fresh frozen, and thermally  
processed seafood products.  The facility uses Anhydrous Ammonia in a closed system  
as a refrigerant in freezers and cold storage.  Ammonia is the safest refrigerant available  
and has excellent warning properties; it is extremely pungent at levels far below  
dangerous concentrations.  The maximum inventory of ammonia in the plant system is  
20,918 pounds. In calculating worst-case and alternative scenarios, eff 
orts were made in  
all cases to overestimate rather than underestimate the effects of a release. The plant  
has been operating safely since 1962. 
 
Worst-case Scenario 
A worst-case scenario is required to be documented in the RMP.  Failure of the largest  
vessel in the system, the High Pressure Receiver (HPR), when filled to capacity would  
release 11,781 pounds of ammonia.  The HPR is located in the machinery room.  Based  
on the requirements of the RMP rule, it is assumed that the HPR fails catastrophically,  
releasing its entire contents over a 10-minute period.  To obtain the most conservative  
assumption, it is assumed that the building does not mitigate the rate of release, but the  
ammonia exits to the outdoors via doors and ventilation shafts in the machinery room  
roof. The release is modeled using RMP CompTM software.   
 
Alternative Release Scenario 
The alternative release scenario for the ammonia refrigeration process is based on a  
potential hazard identified 
during the Process Hazard Analysis conducted during  
documentation of the facility prevention plan.  In this scenario, a pipe to a plate freezer in  
the cold storage complex breaks resulting in a liquid ammonia release to atmosphere.   
The release occurs indoors.  The release is evaluated according to the procedures  
documented in Chapter 4 of the EPA's "Risk Management Program Guidance for  
Ammonia Refrigeration" (EPA GAR) and calculated by RMP CompTM software. 
 
Release Prevention Program 
Alaska Pacific Seafoods has a prevention program in place to comply with the  
requirements of the OSHA Process Safety Management (PSM) standard, which is  
designed to prevent accidental releases of ammonia.  The PSM program addresses all  
required elements including employee participation, process safely information and  
system drawings, operating procedures, hot work permits, management of change,  
mechanical integrity, training, pre-startup review, compliance audits, process hazard  
 
analysis, contractor safely, incident investigation and emergency response.  The system  
itself has many safety features built in including high and low level controls and alarms,  
pressure relief valves, automatic and manually controlled valves and shutoffs, and check  
valves.  Plant personnel responsible for the system have had extensive training in  
ammonia systems and hazardous material handling and response.  
 
Five Year Accident History 
Per the requirement of 40 CFR 68.42, facilities must include a five-year accident history  
for all accidental releases from covered processes that resulted in deaths, injuries, or  
significant property damage on site or known offsite deaths, injuries, evacuations,  
sheltering in place, property damage, or environmental damage.  There have been no  
such accidents at this facility in the past five years. 
 
Emergency Response Program 
Alaska Pacific Seafoods maintains a written emergency action plan as part of the PSM  
plan to facilitate  
response to accidental ammonia releases.  The plan identifies  
personnel designated and trained to conduct the necessary duties during a response.   
Responsibilities include notification of and communication with local responders and  
authorities, coordinating and conducting responses, as well as maintenance of  
emergency equipment and trained personnel. The facility has coordinated its emergency  
response plan with local authorities and responders and conducts drills periodically to  
practice responses.
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