National Service Center, Inc. - Executive Summary

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EXECUTIVE SUMMARY 
Accident Release Prevention Program and Emergency Response Policy 
It is the policy of the National Service Center, Inc. (NSC) Olathe, Kansas facility management to implement the requirements of this Risk Management Program (RMP) in accordance with the USEPA regulations under 40 CFR Part 68 and with the corresponding regulations under OSHA's Process Safety Management (PSM) program.  The objective is to minimize the risk of a release of a hazardous material and if a release occurs, to minimize the potential impact to NSC employees, the public and the environment.  This objective will be accomplished by utilizing general good operating procedures, providing appropriate training to all employees, and coordinating response activities, as necessary, with the local emergency response providers.  This plan covers all NSC owned activities at this facility. 
NSC's management is committed to providing the resources necessary to implement this policy. 
Facility Description 
National 
Service Center (NSC) operates a cold storage warehouse and distribution center at this location.  Support operations include receiving, shipping and administrative offices.  The facility was constructed in 2000.  Figure 1 shows the location of the facility.  Figure 2 is a site plan of the facility. 
One chemical is utilized at the facility in sufficient quantities to be subject to the requirements of 40 CFR Part 68.  This chemical is ammonia and is used as a refrigerant throughout the facility. 
Worst-Case and Alternative-Release Scenarios 
RMP regulations require that each facility identify worst-case and alternative case release scenarios.  EPA has defined a worst-case release as the release of the entire contents of the largest vessel that contains a regulated substance in a 10-minute period.  This release rate is then evaluated using modeling techniques and/or reference tables to define the distance to a specified endpoint (concentration or overpressure).  The distance to the endpoin 
t is affected by several factors including molecular weight, volatility, heat of combustion, and physical setting (urban or rural). 
The alternative release scenario must be one that is more likely to occur than the worst-case scenario and that reaches an endpoint offsite, unless no such scenario exists.  The alternative release scenario is also evaluated to define the distance to the specified endpoint. 
Under 40 CFR 68 Subpart B ?68.22(e), the RMP rule identifies surface roughness as a parameter to be used in the hazard assessment to determine the physical setting of the site, urban or rural.  "Urban means there are many obstacles in the immediate area; obstacles include buildings or trees.  Rural means there are no buildings in the immediate area and the terrain is generally flat and unobstructed." 
Due to the presence of trees, hills, and/or other structures in the immediate vicinity of the Olathe, Kansas facility, an urban dispersion environment was assumed. 
Ammonia 
The data provided 
in the document EPA's guidance document "Risk Management Program Guidance For Ammonia Refrigeration" (November 1998) was used to estimate the toxic endpoint distance for the worst-case ammonia release scenario.  Since the worst-case ammonia release would involve liquid and would come from a pressurized system containing liquid; the released gas should be classified as a dense gas (a result of evaporative cooling).  The ammonia refrigeration document provides calculated endpoint distances for typical meteorological conditions. 
The worst-case release scenario for an anhydrous ammonia release included a release of all the contents of the low suction recirculator in a 10-minute period (per EPA guidelines).  This release translates to a release of 58,700 pounds of ammonia in 10 minutes or 5,870 lbs/min.  Other assumptions included in the worst-case assessment are: the ammonia is a liquefied gas; the low suction recirculator is not diked; the release does not take place indoors; the nearfie 
ld dispersion environment is characterized as urban; 10-minute averaging period; the wind speed is 1.5 meters/sec and the atmospheric stability is classified as F (stable).  The results of the worst-case assessment for ammonia show that the plume must travel 2.8 miles (4.5 kilometers) before dispersing to the endpoint concentration of 201 ppm.  Figure 3 shows the worst-case release radius. 
The data provided in the document EPA's guidance document "Risk Management Program Guidance For Ammonia Refrigeration" (November 1998) was used to estimate the toxic endpoint distance for the alternative ammonia release scenario.  The ammonia refrigeration document provides calculated endpoint distances for typical meteorological conditions (3 m/s wind speed, D atmospheric stability, 50% relative humidity).  The selected alternative-release scenario for the ammonia systems is a liquid release from one of the pumps, located inside the engine room, due to the failure of mechanical seals in the pump.  T 
he leak potential of such a seal failure is approximately five gallons per minute (gpm).  The leak would be detected by the ammonia detectors in the engine room and an alarm would sound.  NSC personnel would respond and stop the leak by taking the pump out of service within five minutes of the alarm. 
The release rate of five gpm of liquid ammonia for five minutes results in an evaporating pool of 25 gallons (approximately 140 pounds) of liquid ammonia.  Assuming total evaporation of the pool in five minutes results in a dense vapor release rate of 28 lb/min.  The table from the ammonia refrigeration document (Exhibit 4-5, page 4-15) was used to determine the endpoint distance for the worst-case release scenario.  The results of the alternative release scenario for an ammonia release indicates that the endpoint concentration of 201 ppm is reached at 0.1 miles (160 meters) from the release point.  Figure 4 shows the alternative release radius. 
General Accidental Release Prevention Progra 
m and Chemical Specific Prevention Steps 
The Olathe, Kansas facility is governed by a set of OSHA and USEPA regulations that require planning and facility activities intended to prevent a release of hazardous material, or if a release inadvertently occurs, to minimize the consequences of a release to the employees of the facility, the public and to the environment.  These regulations include: 
? 40 CFR Part 68, Accidental Release Prevention 
? 29 CFR Part 119, Process Safety Management 
? 40 CFR Part 302, Emergency Planning and Community Right-to-Know Act (EPCRA) 
The key concepts in NSC's release prevention program are employee participation, appropriate design and maintenance of equipment, and appropriate training of all employees.  NSC has developed and documented these elements in their process safety management plan (PSM).  The PSM plan is incorporated with this document by reference. 
Employee participation in the release prevention program is encouraged and supported by NSC managemen 
t.  Key personnel are responsible for conducting and implementing the findings from the Process Hazard Analysis (PHA) for the ammonia systems.  NSC employees are not trained in emergency response, therefore the Olathe Hazardous Material Response Team will respond to any ammonia releases. 
NSC policy is to construct all new equipment, systems, and facilities to ensure the appropriate safety and release prevention systems are included from the beginning of each project.  NSC maintains a computerized program of maintenance activities to ensure that key systems are maintained appropriately to minimize the risk of a release. 
NSC is committed to providing appropriate training to all employees regarding safety procedures.  Each new employee is provided comprehensive safety training during their initial orientation for the facility.  In addition, NSC conducts regularly scheduled safety training for all employees each year.  Additional training is provided to maintenance personnel for the system 
s they are responsible for. 
Five Year Accident History 
NSC has not had a release of ammonia from the Olathe, Kansas facility that has affected the public or the environment.  The facility was constructed in 2000.  The five-year history is not available for this facility. 
Emergency Response Program 
NSC employees are not trained in emergency response, therefore the Olathe Hazardous Material Response Team will respond to any ammonia releases. 
Planned Changes to Improve Safety 
NSC completes a thorough review of the ammonia systems each time a design change is implemented.  NSC is committed to using these methods to identify and implement ways to improve the safety of these systems.
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