National Frozen Foods Corporation - Executive Summary |
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1.0 EXECUTIVE SUMMARY 1.10 Accidental Release Prevention And Emergency Response Policies The National Frozen Foods refrigeration system uses pure anhydrous ammonia as the heat transfer medium in the refrigeration cycle. Anhydrous ammonia is considered a hazardous substance by EPA. Many of the properties that make ammonia valuable as a refrigerant also requires that precautions and procedures be in place to protect employee and public health and safety during a chemical emergency. It is the policy of National Frozen Foods to be in compliance with all applicable federal and state rules and regulations. Safety at our facility is inherent on the manner in which anhydrous ammonia is handled. While the design of the facility incorporates a multitude of safety devices, safe handling procedures combined with appropriate training of our personnel are key aspects to maintaining safety at our facility. We have a written Process Safety Management (PSM) plan that complies with the regu lations stipulated by OSHA 1910.119 or in Washington, WAC 296 - 67. A crucial component of this plan is the Emergency Response Plan, developed in compliance with the Emergency Response provisions of OSHA 1910.120 or WAC296 - 62 - 300. The Emergency Response Plan includes pre-emergency planning and coordinating with outside parties. This enables those who deal with emergencies to have a course of action to effectively deal with unplanned events. 1.20 Facility Description And Substances Handled ? National Frozen Foods is a manufacturing facility that processes and freezes vegetables. Production requires the use of a refrigeration system to preserve the integrity of processed foods. This refrigeration process uses ammonia as a refrigerant. Access to the facility is restricted to authorized employees, management personnel, and contractors. ? The regulated substance handled at this facility is anhydrous ammonia. ? The maximum inventory for the new ammonia refrigeration system is 2 5,000 pounds of anhydrous ammonia. A part of the adjoining AmeriCold refrigeration system enters the National facility. There may be an additional 10,000 pounds in this system. The two systems are not directly connected. There is no standby make-up inventory kept on-site. 1.30 The worst-case release scenario(s) and the alternative release scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario Release scenarios were modeled using RMP*Comp (Version 1.06), a software program developed by the National Oceanic and Atmospheric Administration (NOAA) and EPA. Offsite receptors were defined using the LandView III (Version 1.0) system. This system estimates residential population within the circle defined by the endpoint of the worst-case and alternative release scenarios. In addition, it lists whether certain types of public receptors and environmental receptors are within the circles. ? Worst-Case Scenario. Catastrophi c failure of the High Pressure Receiver located in the engine room when filled to the greatest amount would release 25,000 pounds of liquid ammonia. This scenario presumes that the entire contents are released. The distance to the toxic endpoint for the worst-case scenario is 2.2 miles from the point of release. This distance extends beyond the facility fence line, and would encompass a population of 77 with the closest residences within this release zone. The closest school and hospital are more than three miles from the site, outside of this release zone. There are no national or state parks, sanctuaries, preserves or refuges within the release area. No other public or environmental receptors are located within this zone. This worst-case scenario would not likely occur unless an act of nature (e.g., earthquake) physically compromised the High Pressure Receiver. The structural integrity of the tank is safeguarded by periodic inspection for mechanical integrity to prevent a rupture due to tank degradation. The tank is also safeguarded from rupture from over-pressurization with pressure relief valves. It is a rated pressure vessel hydro-tested to 375 psi and equipped with 250 psi pressure relief valves. The design specification of the tank only allows a maximum capacity of 80% at 80?F, limiting the total amount of ammonia in the system. During high demand, the High Pressure Receiver may only be filled to a fraction (~30%) of capacity. ? Alternative Scenario. Several alternative scenarios can generate the equivalent of a 1" opening in a high-pressure liquid line. Alternative scenarios could include an opening created by a valve sheared off, a large gasket leak, or a pressure relief valve release. These scenarios presume release duration is 10 minutes resulting in a loss of 25,000 pounds of liquid ammonia. This scenario was selected because a release of this type would occur outdoors resulting in the highest potential exposure to offsite receptors. The distance to the toxic endpoint for the alternative scenario is 0.9 miles from the point of release. This distance extends beyond the facility fence line, and would encompass a population of 13 with the closest residence within the release zone. As with the worst case release scenario, no school, hospital, other public or environmental receptors are located within this zone. The severity of release from this scenario would likely be less since safety system provisions are in place to limit the release duration to less than ten minutes through the use of appropriately placed isolation valves. 1.40 General Accidental Release Prevention Program And Chemical-Specific Prevention Steps National Frozen Foods complies with EPA's Accidental Release Prevention Rule and with all applicable state codes and regulations. The design and construction of this facility was in accordance with published standards, tests or recommended methods of trade, industry or governmental organizations. National Frozen Foods written PSM plan incorporates many policies and procedures to ensure safe operation and maintenance of this facility. Plan elements essential to safe operation of the refrigeration system include employee participation, process hazard information, process hazard analysis, operating procedures, training, contractor safety, pre-startup safety review, mechanical integrity, management of change, hot-work permits, incident investigation, emergency response and planning, and compliance audits. This plan will be reviewed annually and updated as necessary by the National Frozen Foods Plant Superintendent. Training is provided to ensure that each employee involved in operating a process has been trained in an overview of the process, the operating procedures, and safety considerations. This training uses guidelines developed by the International Institute of Ammonia Refrigeration (IIAR) and Refrigeration Engineers Technology Association (RETA). Only qualified main tenance personnel operate and interact with the refrigeration system. This minimizes the chances of inadvertent error in operation that could lead to a release of ammonia. Startup, shutdown, and any onstream adjustments are handled by these qualified persons. 1.50 Five-Year Accident History There has been no significant release of ammonia at National Frozen Foods since this is a new facility. 1.60 Emergency Response Program National Frozen Foods has a written Emergency Response Plan to ensure that precautions and procedures are in place to protect employee and public health and safety during a chemical emergency. It complies with the provisions of WISHA Emergency Response regulations, WAC 296-62-3112. The Emergency Response Plan includes pre-emergency planning and coordinating with outside parties. This enables those who deal with emergencies to have a course of action to effectively deal with unplanned events. This plan has been reviewed with the Grant County District 5 Fi re Department. The approach in the development of this plan has been to identify the ammonia emergencies most likely to occur at National Frozen Foods and establish precautions and procedures to protect life safety and health during an emergency. The refrigeration process has back-up prevention systems to keep processing malfunctions from becoming ammonia release emergencies. If an emergency does occur, the following response personnel, facilities, and equipment are in place: ? Incident Command Center ? Emergency Alarm and Communication System ? Emergency Response Team ? Evacuation Plans and Assembly Points ? Personal Protective Equipment The role and procedures for obtaining external emergency assistance have been formally established with the Grant County Fire District 5, including their HazMat trained members stationed in Moses Lake. The Emergency Response Plan also includes procedures for notification of any potentially affected neighbors. All National Frozen Foods personn el will be trained to fulfill their designated responsibilities in an emergency. Mock emergency drills will be held periodically to maintain familiarity with response actions and identify plan elements requiring improvement. This plan will be reviewed annually and updated as necessary by the National Frozen Foods Plant Superintendent. 1.70 Planned Changes To Improve Safety This facility will start production operations with the new refrigeration system in May, 2001. All system components meet design specifications in ANSI/IIAR 2-1999, equipment, design, and installation of ammonia mechanical refrigerating systems. All pressure vessels are built according to American Society of Mechanical Engineers (ASME), Section VIII, Division 1, 1995 Edition (1996 Addenda), ASME Boiler and Pressure Vessel Code, pressure vessels. Any upgrades or extensive maintenance work performed in the future will be in compliance with those standards applicable at that time. All National Frozen Foods perso nnel are trained to fulfill their designated responsibilities in an emergency. Mock emergency drills will be held periodically to maintain familiarity with response actions and identify elements requiring improvement. The Process Hazard Analysis (PHA) and high priority list of recommendations were completed in February, 2001. |