Utah Olympic Park - Executive Summary |
|
The Utah Olympic Park (hereinafter "UOP"), a wholly owned operating unit of the Salt Lake Organizing Committee (hereinafter "SLOC") is home to the bobsled/luge track as well as the 90-meter and 120-meter Nordic ski jumps for the 2002 Olympic Games. SLOC operates the UOP venue year round, however the refrigeration system for the sledding activities is not operated during the off-season (May through September). During the Season, the UOP employs over 50 staff, and in the off-season, the venue is minimally manned. The UOP relies on Mother Nature and some snow making equipment to keep snow on the ski jump. However, the UOP relies on a state of the art ammonia refrigeration system to keep ice on the track. The system has a maximum refrigerant charge exceeding 10,000 pounds of anhydrous ammonia, and as such, the UOP is subject to EPA regulation under 40 CFR 68, Accidental Release Risk Management of Highly Hazardous Chemicals. Pursuant to the Risk Management Plan (RMP) regulations (40 CFR 68) and the Process Safety Management (PSM) standard (29 CFR 1910.119), SLOC has developed a comprehensive PSM written program to protect UOP employees and the surrounding Park City, Utah community from exposure to ammonia. The facility completes Pre-Startup Safety Review through checklist analyses prior to the beginning of each Season. The facility used the industry standard What-If?/Checklist Analysis developed through the International Institute for Ammonia Refrigeration to conduct a process hazards analysis (PHA) of the track ammonia refrigeration system in September 2000. SLOC is committed to the safe operation of the ammonia refrigeration system at the UOP. SLOC's implementation of the revised PSM program includes employee education in the hazards of ammonia and measures that can be used to reduce employee and community exposure to accidental releases of ammonia. The plan includes preventive maintenance programs (mechanical integrity) for the ammonia system that incorporates inspections of the system in accordance with IIAR Bulletin 110, the recognized standard of equipment inspection within the ammonia refrigeration industry, as well as tests of system components in accordance with component manufacturers' recommendations. The PSM program includes programs for pre-startup safety reviews and management of changes (MOC) to the refrigeration system. The program also includes specific requirements for safe work practices (such as safe approaches to welding and similar hot work) and safety requirements for contractors who may be hired to work on the systems. The PSM program also includes a program for the evaluation of contractors' qualifications. SLOC facilitated a compliance audit of the PSM program in September 1999. In addition, the facility was subject to a Chemical Safety Audit (CSA) completed by a Team consisting of representatives of U.S. EPA, OSHA, and Utah OSHA. Recommendations from the CSA are in the process of evaluation and implementation. The PSM written program incorporates the comprehensive emergency response plan for the UOP and places special emphasis on handling accidental releases of hazardous chemicals and coordination of emergency response with local fire departments and other emergency response organizations. The response plan details the emergency response structure and includes personnel responsibilities and procedures within that structure. In addition, the plan includes procedures for notification of local agencies in the event of an incident, facility evacuation, and decontamination. Finally, the plan discusses emergency preparedness and planning, including facility plans for conducting emergency response team training and drills. The UOP has never experienced a release of ammonia involving consequences that affected residents or the environment, nor has the facility experienced a near-miss situation that should have been investigated. However, as part of the RMP requirements, SLOC undertook a review of the potential offsite consequences of the accidental release of the largest vessel in the systems. Although such a release is highly unlikely, the regulation requires this worst case scenario review. |