Super Cool Cold Storage, Inc. - Executive Summary |
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Super Cool Cold Storage, Inc. is a complex of four (4) freezer warehouse buildings, designated #1 - #4, used for temporary freezer storage of food grade items destined for truck transport to retail outlets The refrigerant used to cool the freezers is ammonia. Ammonia is a hazardous substance (toxic) and its use in large quantities in industry is regulated by the EPA. Super Cool #3 & #4 maintain systems that contain 32,756 lbs. & 25,000 lbs. of ammonia, respectively, which exceeds the EPA mandated threshold of 10,000 lbs. of hazardous substances in a process. Therefore, Super Cool is subject to the Risk Management Plan (RMP) regulations of Section 112(r) of the Clean Air Act. The use of these quantities of ammonia has also triggered OSHA's Process Safety Management (PSM) regulation and many of the RMP requirements were met in coming into compliance with PSM. Accidental Release Prevention and Emergency Response Policies- Super Cool policy demands a proactive approach to equipment maintenance. Equipment failure is the primary hazard facing a refrigerated storage facility. Frequent monitoring of equipment reduces the chances of an accidental release. Super Cool uses a rigorous inspection program to ensure that equipment is functioning properly and pays close attention to routine equipment maintenance. Super Cool employs only 2-3 people to work on the refrigeration system, and these employees are thoroughly trained prior to conducting maintanence activities on the refrigeration process. Much of equipment maintenance is performed by licensed mechanical contracting companies. Super Cool refrigeration employees have received "Hazardous Materials Technician" & "First Responder" training and they are annually refreshed in the event of a release. The Emergency Response (ER) Plan includes procedures for "quick response" to a release and notification of local ER authorities (fire, hazmat, etc.), as well as notification of potentially effected neighbors. Super Co ol extends their rigorous inspection/maintenance program to include emergency equipment, as well. Worst-Case Scenario & Alternate Scenario of Accidental Release- The worst-case release scenario will emanate from SC #3 because its system is largest. An EPA model was used in which the release occurs inside the warehouse building and then migrates to the surrounding community. Should a major refrigeration line be significantly damaged or a major piece of equipment seriously malfunction and all 32, 756 lbs of ammonia are released, an area approximately 9.5 miles in diameter could potentially be affected. A much more likely scenario involves a leaking seal (gasket, valve, etc.) that requires 15 minutes to stop. SC #3 or SC#4 are both included in this scenario as such a release could occur from any seal at any of the four freezer warehouses. This release was also modelled using EPA guidance. This particular type of release would not leave the property and would affect only Super Coo l employees. General Accidental Release Prevention Program and Chemical Specific Prevention Steps- Super Cool adheres to 29 CFR 1910.119 (OSHA's PSM regulation) and thoroughly documents inspections and maintenance procedures. All Super Cool refrigeration employees are trained per the requirements of 29 CFR 1910.120 and training is refreshed annually. Super Cool employs a guard 24 hr/day that makes visual rounds every three hours to ensure that leaks will not go undetected during off-hours. Five Year Accident History- None of the regulated processes at Super Cool Cold Storage, Inc. have experienced an acidental release in the past five years. A relief valve at SC #2 gave and approximately 2 lbs of ammonia was released in October, 1996. No one was injured, however a slight odor was noted at the property boundary. Emergency Response Plan_ Super Cool has coordinated its ER Plan with the local ER authority (Central Florida LEPC) and the Polk County Fire Department & HazMat Team (PCF DHM). The PCFDHM conducted a full dress rehearsal of a mock emergency response in June, 1998 in order to acquaint themselves with the facility should a ER action ever be required. The CFLEPC will handle community notification in the event of a catastrophic release. Super Cool conducts monthly inspections of their Emergency Response equipment to ensure that cartridges and/or supplied air, etc. has not expired or is not malfunctioning. Planned Changes to Improve Safety- Super Cool plans to install automatic ammonia leak monitors to improve their leak detection capabilities. |