S&S Foods, LLC - Executive Summary |
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ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES The S&S Foods facility has an emergency action plan in effect. The Emergency Action Plan (Plan) is detailed in the Emergency Planning and Response section of the PSM/RMP document which is maintained at the facility. This Plan was designed to meet the following objectives: 1.) To save lives. 2.) To minimize and avoid injuries. 3.) To protect the environment. 4.) To minimize property damage. S&S Foods maintains a safety committee whose members include the designated emergency coordinators for the facility. The Plan provides the response organization and notification procedures, evacuation routes, ammonia health hazards, and mitigation procedures which will be implemented to respond effectively to emergency situations that may arise at the facility. This Plan is reviewed and updated at least once per year. This Plan was reviewed and updated to ensure compliance with the PSM and RMP regulations. S&S Foods ha s coordinated emergency response efforts with the local fire department and with the contracted refrigeration operation and maintenance firm. In the case of an ammonia-related emergency, it is the policy of S&S Foods to evacuate and to allow the fire department/HazMat Team to respond to the emergency. The S&S Foods Chief Engineer / Engineer will be available for guidance and assistance. STATIONARY SOURCE AND REGULATED SUBSTANCE The S & S Foods facility began operation of the facility in 1998. The building was constructed in 1984 with several additions/modifications taking place since then. The ammonia refrigeration system was designed and constructed in accordance with all applicable federal, state, and local regulations including the Uniform Mechanical Code (1994 updated to 1997), Uniform Building Code, and the Uniform Fire Code. The refrigeration system at the facility was installed with and has operated using R-22, a freon-based refrigerant. It was designed with the intent o f switching refrigerants to ammonia so that very few equipment/piping modifications were necessary. The initial ammonia charge is to be received by the system at the time that the Phase 3 expansion is finalized which includes the addition of a process spiral freezer (IQF), several evaporators for new cold rooms, one compressor, and two vessels. The refrigeration system was shut down, purged of R-22, and restarted using ammonia in November 2000. The facility processes meat and meat products that are distributed to fast food establishments. The facility is located at 1120 W. Foothill Blvd. in Azusa, California, just north of the Interstate 210 freeway, between Irwindale Avenue and Vernon Avenue. The immediate area is primarily commercial with some light industrial and residential areas. The ammonia system was upgraded to meet the requirements of the current applicable federal, state, and local regulations including the Uniform Fire and Mechanical Codes. The refrigeration system us es approximately 14,000 pounds of ammonia to maintain low temperatures for cold storage and for blast freezing product. The cold storage areas include: Finished Goods, Raw Goods, Blend/Grind, Dock, Freezer, IQF (Individual Quick Freeze), Fajita Process. There are also multiple spiral production freezers. The refrigeration cycle begins with the transfer of high pressure liquid ammonia from the Thermosyphon Receiver (TSV-1) to the High Pressure Receiver (HPR-1), which is the main liquid storage vessel in the system. The HPR transfers high pressure liquid through the Intercooler (IC-1) in order to subcool it prior to routing to each of three Low Pressure Receivers (LPR-1, LPR-2, LPR-3). Each Low Pressure Receiver operates an independent system with a specific process or storage freezer(s). The HPR also supplies high pressure liquid to the Controlled Pressure Receiver (CPR-1), which maintains a constant pressure through the use of pressure regulating valves. CPR-1 is the main liquid supply vessel for the evaporators. As the liquid ammonia enters the various evaporator/freezer coils, it expands, reducing the temperature. As heat from the room (or product in the Spiral Freezers) is transferred to the low temperature liquid ammonia in the coils, the ammonia is (partially) vaporized. The suction from the evaporators is pulled to the Suction Accumulator vessel (AC-1). The suction from each of the spiral freezers is returned to the corresponding Low Pressure Receiver. Four compressors (HC-1, HC-2, LC-1, and BC-1) pull the gaseous ammonia from the suction vessels and work in combination to compress the low pressure ammonia to high pressure gas (hot gas). The hot gas is discharged through a common header to the Condensers (EC-1, EC-2), where fans and sprayed water are used to condense the ammonia in the coils back into a liquid. As the ammonia changes phase into liquid, the heat from the system is discharged to the atmosphere. The liquid is then drained into TSV- 1. Hot gas (high stage compressor discharge) is also used for defrost in the evaporators and for pressurizing liquid transfer tanks associated with the recirculator vessels. The system also has an emergency dump tank (into which a common relief header vents), which is kept full of water. HAZARD ASSESSMENT SUMMARY * Worst Case Release Result Summary Scenario Description: Release of the maximum quantity of ammonia that can be stored in a vessel - 8,000 pounds in 10 minutes. (The maximum rated capacity of the High Pressure Receiver is approximately 8,000 pounds of ammonia.) The most pessimistic meteorological conditions were used: 1.5 meters per second wind speed, and F stability. Reference tables in the EPA-approved Risk Management Program Guidance for Ammonia Refrigeration were used to determine the maximum distance to the toxic endpoint of 200 ppm in urban conditions. This release reaches off site and may impact population receptors. No environmental receptors were affected by this potential release. * Alternative Release Result Summary Scenario Description: A release of ammonia from resulting from a 1/4 inch diameter hole in a pipe. The release rate of ammonia due to the pressure of the tank is 134 pounds per minute. The meteorological conditions used were 3 meters per second wind speed, and D stability. Reference tables in the Risk Management Program Guidance for Ammonia Refrigeration were used to determine the maximum distance to the toxic endpoint of 200 ppm in rural conditions. This release reaches off site and may impact population receptors. No environmental receptors were affected by this potential release. ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-SPECIFIC PREVENTION STEPS The S&S Foods ammonia refrigeration system has many safety features. Much of the safety of the system is inherent in the policies and procedures that govern the operation of the system. For example, the S&S Foods facility operates in accordan ce with OSHA's Process Safety Management regulation. The S&S Foods facility including the ammonia system was designed and constructed in accordance with the Uniform Mechanical Code which specifically outlines requirements for the safe operation of the ammonia refrigeration system. These safety features include a water diffusion tank, ammonia sensors in the machine room as well as sensors in the cold storage areas, and automatic shut down systems that prevent equipment damage and ammonia releases. The ammonia sensor in the machine room is interlocked to: 1) provide alarms for facility operators (via a telemetry system), 2) shut down the system, and 3) activate emergency ventilation that scrubs ammonia through a water reservoir. There is also an emergency button located outside the machine room that when manually activated, will shut down the machine room equipment. In addition, the majority of the ammonia inventory is centrally located (inside the machine room and just outside of t he machine room). All pressure vessels are equipped with pressure relief valves that automatically engage in case of a high pressure situation and vent through a common header to a water diffusion tank. Ammonia refrigeration systems do not experience any chemical reactions or internal corrosion. The only composition change that occurs within the systems are phase changes, as ammonia is cycled through various stages of liquid and vapor, similar to a household refrigerator. The refrigeration system is a closed-loop system without any regular emissions or releases. Any leaks are noted and repaired immediately. In addition to the Uniform Mechanical Code, the facility will operate in accordance with the International Institute of Ammonia Refrigeration (IIAR) guidelines. In particular, the IIAR Bulletin 110, "Startup, Inspection, and Maintenance of Ammonia Refrigeration Systems." FIVE YEAR ACCIDENT HISTORY Since ammonia is new to the facility as of November 2000, there have been no ammonia accidents at the facility. EMERGENCY RESPONSE PROGRAM S&S Foods has an emergency action plan in effect at the facility. The Emergency Action Plan (Plan) is detailed in the Emergency Planning and Response section of this PSM/RMP document. Emergency response activities are coordinated with the Los Angeles County Fire Department and the City of Azusa. In case of a major ammonia emergency, the facility will first call 9-1-1 to alert the local Police and Fire Departments. Other responders will be called as needed, including the LA County Hazardous Materials Response Team. If a release exceeds the federal reporting quantity of 100 pounds for ammonia, the National Response Center is called. The S&S Foods facility has an Incident Command System in place. The General Manager will assume command in an emergency situation with backup personnel appointed to serve if he is not available. S&S Foods maintains a safety committee whose members include the designated emergency coordi nators for the facility plus corporate representation. The Plan provides the response organization and notification procedures, evacuation routes, ammonia health hazards, and mitigation procedures which will be implemented to respond effectively to emergency situations that may arise at the facility. The facility holds evacuation drills at least once per year. PLANNED CHANGES TO IMPROVE SAFETY The Process Hazard Analysis (PHA), including a Hazard and Operability (HAZOP) study, and a Facility "What If" Walkthrough, provided mitigation measures to improve safety at the S&S Foods facility located at 1120 W. Foothill Blvd. in Azusa, California. Many of the recommendations are complete and implemented as of the system startup date. All recommendations are scheduled to be complete by November 1, 2001. R01 Decide on and implement an emergency response plan, including whether S&S Foods employees will offensively respond to ammonia emergencies. R02 Coordinate emergency response policies (including spill cleanup) with the local fire department. R03 Ensure that every employee at the facility has the following information: general awareness of ammonia at the facility, how to report an ammonia release, where to go when they are told to evacuate. R04 Establish a policy so that flammable materials are not stored in the vicinity of the outside equipment (HPR area, LPRs) or in the ammonia engine room. R05 Ensure that all relief valves are replaced or recertified on a 5 year schedule. Also, replace any relief valve that engages to vent pressure. R06 Ensure that a periodic (at least annual) visual inspection is included in the maintenance program for all vessels. Paint all vessels as needed. R07 Ensure that the filters downstream of the High Pressure Receiver are completely pumped down before changing cartridges. R08 Install a solenoid king valve with the appropriate controls and instrumentation on the main liquid line downstream of the High Pressure Receiver. R09 Educate operators that liquid is not to be isolated in piping or vessels in order to prevent hydraulic expansion. R10 Establish a policy that requires two operators to perform abnormal operations on the refrigeration system. R11 Establish a policy to require that system operators wear protective eye goggles while performing system maintenance. R12 Install an eye wash station/safety shower outside near the High Pressure Receiver. Also, ensure that a water source is also available on the roof (i.e. portable water bottles, hose, eye wash station). R13 Interlock the temperature sensors in the cold areas with the computer monitoring system. R14 Interlock the Controlled Pressure Receiver King Solenoid Valve with the liquid feed solenoid valves at each set of evaporators. R15 Interlock the CPR solenoid king valve with the emergency kill switch. R16 Install an additional float switch on the High Temperature Accumulator vessel as a pre-ala rm to the existing high level shut down switch. R17 Ensure that the oil draining procedures are documented and followed by the refrigeration operators including contractors. R18 Continue to implement a daily log sheet for the ammonia engine room to be completed by an S&S Foods employee. R19 Ensure that an annual test of all high level shut down switches (High Temp Accumulator, Intercooler) is performed and documented annually. R20 Compile a list of how to electrically shut down all Low Pressure Receiver packages. R21 Interlock the liquid inlet solenoid valves to the pump shut down on the Low Pressure Receivers. R22 Document a procedure to re-start the ammonia refrigeration system following a loss of power. R23 Install a hose bib (or other water source) outside near LPRs. R24 Ensure that all evaporator and spiral freezer coils are periodically maintained by cleaning the pans and coils. R25 Establish a maintenance program for all ammonia equipment that includes manufacturer recommendations and/or industry standards. R26 Ensure that the Condensers are periodically maintained including a water treatment service and cleaning out the water reservoir. R27 Implement a procedure to ensure that a (contracted) ammonia operator checks in with a facility supervisor prior to performing work on the roof (or in another isolated location). R28 Consider installing wind socks or other wind direction indicators around the facility. R29 Ensure that (at least) annual evacuation drills are held at the facility that include all shifts. R30 Consider providing portable lighting for maintenance work performed on the roof and/or outside. R31 Consider installing a visual alarm on the outside on the Ammonia Engine Room door that is activated by the ammonia detectors inside the room. R32 Install and upkeep ammonia warning signs outside near the Low Pressure Receivers and at the Ammonia Engine Room. |