Llano Logistic, Inc. - Executive Summary
EXECUTIVE SUMMARY |
This Risk Management Program is designed to comply with the Environmental Protection Agency regulations detailed in 40 CFR Part 68. The stationary source is the Llano Distribution Center located at 5801 Martin Luther King Blvd., Lubbock, TX 79404. The site is owned by Llano Logistics, Inc. The only RMP regulated substance at this facility is anhydrous ammonia--which is classified as a toxic substance, liquefied under pressure.
This is a new cold storage warehousing that is scheduled for completion by May 2000. This new refrigeration system in this facility will have an inventory of approximately 14,000 pounds of anhydrous ammonia. This process does not meet the requirements of Program 1. It is subject to OSHA's PSM standard. Therefore, this RMP is written to meet the EPA Program 3 level of compliance.
ACCIDENTAL RELEASE PREVENTION PROGRAM
This facility follows a rigorous thirteen volume Process Safety Management Program to prevent the accidental release of ammon
ia. The PSM program is in compliance with Occupational Safety and Health Administration (OSHA), Process Safety Management (PSM) of 29 CFR 1910.119. Employees and management participate and cooperate in the PSM program to maintain a work environment that is safe to employees, the community, and the environment.
EMERGENCY RESPONSE POLICY
The facility has a comprehensive emergency response plan that meets established criteria. The plan is being provided to the local LEPC for review.
This food distribution facility operates one ammonia refrigeration process. The system operates at three-temperature separate suction pressures, all with single-stage compressors. The refrigeration system capacities are 128 tons of refrigeration (TR) @ -28?F for the low temperature suction, 584 TR @ +16?F for the medium temperature suction, and 183 TR @ +36?F for the high temperature suction. The refrigeration system is a liquid re-circulation system and is designed to operate at with overfe
ed ratio of approximately 3:1 for all evaporators. Anhydrous ammonia (R-717) refrigerant is a Group II refrigerant. Rotary screw and reciprocating compressors are used in the refrigeration system.
This ammonia refrigeration system contains six interconnected sub-systems:
Low temperature re-circulating system (-28?F @ 0.0 PSIG).
Medium temperature re-circulating system (+16?F @ 29.4 PSIG).
High temperature re-circulating system (+36?F @ 52.9 PSIG).
Thermosyphon oil cooling system (95?F @ 181.1 PSIG).
Condenser system (95?FCT / 73?F W.B.).
Low temperature compressor system (-28?F @ 0.0 PSIG).
Medium temperature compressor system (+16?F @ 29.4 PSIG).
High temperature compressor system (+36?F @ 52.9 PSIG).
Major equipment located inside the engine room includes:
Two low temperature compressors (both Vilter model 601 Screws @ 64 TR/ 156 BHP with one compressor also piped to the medium temperature system - rating adjusted to 87 TR/ 350 BHP).
Two medium temperature compressors (both Vilter
model 751 Screws @ 292 TR/ 317 BHP with one compressor also piped to the high temperature system - rating adjusted to 475 TR/ 351 BHP).
One high temperature compressor (Vilter model A-11KX458-XL @ 182.6 TR / 143.2 BHP).
One 30" dia. X 9'-7" thermosyphon pilot-receiver.
One 54" dia. x 12'-7" OAL vertical accumulator package @ +36?F.
One 72" dia. x 13'-4" OAL vertical pump re-circulator package @ +16?F.
One 60" dia. x 10'-10" OAL vertical pump re-circulator package @ -28?F.
One-Hansen APC Auto-Purger.
Major equipment located outside on the roof includes:
One evaporative condenser (EVAPCO model PMCB-1175, rated @ 14,275 MBH, for +95? FCT/ 73? FWB).
There are some mitigating measures in place. The location of the ammonia vessels is inside the engine room. Although there are doors and windows, the overall enclosure acts as a dike creating liquid pooling and limiting the liquid run-off. Ammonia leak detection is installed in this area that sounds alarms and starts eme
rgency ventilation. The emergency ventilation is automatically controlled and discharges the engine room air through the roof which creates a lower level of concentration in the engine room for responders. It also starts air dispersion at lower concentration levels and disperses the ammonia with greater air turbulence.
SUMMARY OF HAZARD ASSESSMENT
This hazard assessment was conducted to meet the RMP Off-site Consequence Analysis requirements for the ammonia refrigeration system. The only RMP regulated substance at this facility is anhydrous ammonia which is classified is as a toxic substance, liquefied under pressure. The definitions and parameters for the following release scenarios are based on the "Risk Management Program Guidance for Ammonia Refrigeration" as described in Chapter 4: Off-site Consequence Analysis.
The worst-case release scenario (OCA-1) used in this assessment identifies the high temperature accumulator (V-2) as the vessel with the potential to hold the largest qu
antity of ammonia. This is based on the system design, without a high pressure receiver, that uses this vessel as a pump-down holding receiver. The worst-case release scenario is based on over-filling this vessel causing the released quantity to be equal to the total vessel volume with no piping volume included.
The alternative release scenarios evaluated in this hazard assessment include two possible scenarios. First alternate scenario (OCA-2) is the direct release of ammonia vapor from the largest pressure relief valve with a duration of sixty minutes. The size of the release is based on the rated capacity of the pressure relief valve (79.6 lbs/min) with a release duration of sixty (60) minutes.
The second alternative scenario (OCA-3) is the direct release of liquid from a ?" diameter hole/valve in a vessel having an internal pressure of 181.1 psig. The size of this release is based on a ten (10) minute release duration at a release rate calculated from the simplified Bernoulli
equation found on page 4-14 in Chapter 4 of the "Risk Management Program Guidance for Ammonia Refrigeration."
ACCIDENT PREVENTION PROGRAM
This facility follows the OSHA Process Safety Management Program. Various special elements have been incorporated into the PSM Program to meet the EPA requirements for the RMP. Following is an overview:
Participation - The Participation Program is an asset to both employees at the site and to the community as a whole. As a general rule, employees who are fully involved have a greater sense of responsibility; they are more likely to catch the problems that can cause accidents. Employee awareness is for employees, not directly involved with the process, this includes knowing the hazards, the safety rules, warning signs, and evacuation procedures. All employees have access to the PSM Program. Involved employees participate directly in every phrase of the PSM program, including conducting the PHA, developing or reviewing operating procedures, revi
ewing incident investigations, and conducting mechanical integrity and compliance audits.
Community involvement is through coordination and cooperation with the local Fire department and LEPC.
Process Safety Information - Process Safety Information includes a wide variety of books, manuals, and process information. These are available to employees that operate, maintain, or repair the process equipment or piping. There are three major categories of information: ammonia data such as MSDS, safety information, first aid, chemical properties, IIAR safety bulletins, etc.; process information such as piping & instrumentation diagrams (P&ID's), block flow diagram, mass flow balance, design codes and standards, pressure safety relief settings, safety system/devices, ventilation system design, operating procedures, safe operating limits, and ramification of process deviation; and process equipment information such as equipment specifications, electrical classifications, materials of constructi
on, installation manuals, operating and maintenance manuals, and manufacturer's manuals.
Process Hazard Analysis - A PHA was completed using the "What-if" technique. This addressed hazards, engineering and administrative controls, consequences of failure of engineering and administrative controls, facility siting, human factors, and a qualitative evaluation of the possible safety and health impact. The results of the PHA were prioritized and incorporated into a PHA Findings Report for follow-up as a corrective action log.
Standard Operating Procedures - SOPs are provided for each compressor, condenser, ammonia vessel and oil pot, and evaporator. Topics include general information such items as objectives, hazards, location, equipment needed, P&ID's, task flow diagrams, and step-by-step procedures with specific warnings and comments. The SOPs cover different phases of operations such as: initial startup; normal, temporary and emergency operations; emergency shutdowns; and startup fol
lowing a shutdown.
Training - All employees are who are involved with anhydrous ammonia have been properly trained, at a minimum, in understanding the MSDS, routine refrigeration system operation, emergency refrigeration system operation, emergency and normal refrigeration safety practices, and, if appropriate, the individual's role in the emergency response plan.
Contractors - This site follows strict guidelines for qualifying contractors who directly influence the safety of the process or the system. The contractor qualification procedure ensures that contractors and their employees are fully aware of the potential dangers involved with the ammonia process, that contractors understand their responsibility and train their people, and that a contractor's safety record is considered in reviewing the bids.
Pre-Startup Review - Safety reviews are required on all new or modified equipment/systems. This involves process safety information, process hazard analysis, training, safety proce
dures, operating procedures, and verification that construction and equipment are in accord with the design specifications.
Mechanical Integrity Audits - The purpose of the Mechanical Integrity Audit program is to ensure that the equipment is maintained in good working condition. These are performed on all compressors, condensers, evaporators, pressure vessels, piping system, relief and vent systems and devices, emergency shutdown systems, controls, and pumps.
Hot Work Permits - This permit process is to protect against fire, explosion and other dangers resulting from hot work (welding and cutting outside the designated areas). Hot work permits must be obtained before any work is done outside the shop area. The Maintenance Supervisor reviews and issues the permits to insure all fire prevention and protection rules are met. Permits indicate the appropriate dates and the work to be done. The permits are kept on file until workers have completed the hot work operations.
Change - The MOC procedure requires that all changes (even "replacement in kind") be reviewed to see if there is a possible negative effect. The MOC review addresses the technical basis for the change, the impact on safety and health, modifications to operating procedures, and authorization requirements for the proposed change. Employees affected by the change are informed of the change before startup and trained in the proper procedures.
Incident Investigation - An investigation shall be performed any time there is an incident which resulted in, or which could reasonably have resulted in, a catastrophic release of ammonia. The purpose is to gain information that could prevent further accidents and to identify weaknesses in the emergency response plan that need to be addressed. Investigations are initiated promptly using a trained team. The findings and recommendations will be studied and appropriate corrective action taken.
Emergency Response Plan - This facility has a comprehensi
ve emergency response plan that meets established criteria. This plan will be provided to the local fire department and the LEPC.
Compliance Audits and RMP Revisions - To insure that all the other 12 areas of PSM program are followed, the company requires compliance audits. At a minimum, these must be completed every three years.
Resubmission of the RMP shall be done according to Section 6.2 to meet the OCA requirements.
ACCIDENT HISTORY - LAST FIVE YEARS
This is a new facility and process for this location and has no history.
PLANNED CHANGES TO IMPROVE SAFETY
This is a new facility and process. It was designed and built to meet current industry standards for safety and reliability. Maintenance programs are being generated to insure safe operation.